Skip to main content
Skip to content
Case File
dc-26223474Court Unsealed

Epstein _ 001

Date
November 12, 2025
Source
Court Unsealed
Reference
dc-26223474
Pages
1935
Persons
0
Integrity
No Hash Available

Summary

yl . on on TRI ILITYUIY & JOHN CONNOLLY WITH Tim MALLOY A POWERFUL BILLIDNAIRE. THE SEX SEANDAL THAT UNDID HIM. AND ALL § THE JUSTIGE THAT MONEY CAN BUY: : | THE SHOCKING TRUE STORY OF JEFFREY EPSTEIN ‘ de HOUSE_OVERSIGHT_010477 5 ~ I] i A { doit see what it adds to the Rf ¥ ? Bl pois atm Desc . rely . BY crn nal ” CRE! hat © MO — Ju, a that time, no criminal L : 2 a irs had been lnuached. And In fa od he curaors of Fpstein's dealings [5 > a 110 be just that — Tumors. a J ie lawyers, his ed

Ask AI about this document

Search 264K+ documents with AI-powered analysis

Extracted Text (OCR)

EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
yl . on on TRI ILITYUIY & JOHN CONNOLLY WITH Tim MALLOY A POWERFUL BILLIDNAIRE. THE SEX SEANDAL THAT UNDID HIM. AND ALL § THE JUSTIGE THAT MONEY CAN BUY: : | THE SHOCKING TRUE STORY OF JEFFREY EPSTEIN ‘ de 5 ~ I] i A { doit see what it adds to the Rf ¥ ? Bl pois atm Desc . rely . BY crn nal ” CRE! hat © MO — Ju, a that time, no criminal L : 2 a irs had been lnuached. And In fa od he curaors of Fpstein's dealings [5 > a 110 be just that — Tumors. a J ie lawyers, his editors, and his | — ug odd and disturbing happend Rd i : of Ejsieius 2 Billo Vi to the office carly. He swiped his 4 Segartmern) of he clevacor button, and arrived in S85 FA tom area on the twenty-first loot __ / 4 sme to review Wards ston 1 E 4 A 2s town house —whicli 1s sid 10 | oF “ esidence fn Nes York City at the i Jeffrey Eputein's 1969 high school + amid the flurry of menservaney | IR = Rituwkyiie afeyette High and pristine white gloves, you Gal ¥ ronkiyn, New Yor, 965) ‘conc’ private Xanadu” shed wil persons bara, but a high ville : ily : that seems 10 have no bowndatk are » [Es a ERS ed not with paintings but wit 1 | EEE oa med egeballs these, the aware H8 ¥ : mperted from Fugland, whete i i “es, Nexs mesa marble oye NS | « manger of Jean Dribuffet-Dil Jefe Epein, Coney Laud ) sisitars who painted iL Tn FE I r— 150 { Leslie Wester, phucogrephed s f 1 = Ba I | 3 Tr A | f (Lu) jefirey Epstein, Ghiclatae 2 y Y i A ; i ® a | f — 8 '; i 1535 (Davidoff Sinn) j 3 : CC \/ I Tramp, sd ory sgl. SE | Trae viodel IE 1 2X ¥ [ caer, photographed | RAE id New tock Cry (dic US 4 & 24 WN YO, | = o © 4 2 , i & * a phy a, ; | by Epa wich SR ron ; x Ol aa = JERS i I screen eas io his ] - ome. (ai: 5 | pE— of ¥ -~ o) Blohm, Jeffrey Fpicic., 3 y bl i EY Gis ins Maxwell, and 2 i sae 1 roto sored taken oy = 1905, (Davidoff Sader) Jefrey Tpscin a Zorrs Ranch, 2 5 oll | nis New Mexico prugert See Se he | 4 8 - Cr} n | Jeffrey Epstein with Professor -- 9 wk A ler Detowie in Conbrgg. A 1 PA @ . J — ; i] : Othe day the police nsesttion WE os } wat sas conc > i 0s. Ge Sklar Fasc E Mepdallen} . Fy miata held a the Hote > | SH | EB | 1 Ee er pen PS y g EE a i ede gg) HN eave ns serene, HIIOGEE ls =) Eee ar RR Wy vor lication charges and served Ee gation | irtser. months of ier TE a —— i soltaryeala the Fal Resch ‘NY aanch J DC Specs Managemen, Fa g ) ik Rail J. rie pain and ewer i west Pen Deach coutunuse June Jeffrey Epc, photographer os 300% 1 caer ics acady ts eth Aas Koes sn r : y yom aftr bag chacged (tine Sug he Lunch of Radar § PET | soot The PS ne mages bed a the Hel I ] jou | ZUMAPRESS em) QT in ew York City, May { i 2005 (he Ros Purch a 2 ll err— Satsang 0 Tet . a | fo - i gh = E \ : = 3 Ielrey Epscits arin a Gin e. Reps (National Sox —— [| he Sockads, wher Epis 8 by SHEE, FR ovis seman poi SR el Cocin Lice Som James hee re 17.2006, was hocored 10 bE EE SE nc, 115 Vugu lads COR nich, Pais. ahs ims 8 ST a pp——T BEE CR Sl i conc 0 ecrity Pcl house hE RE conn oc By roeniles, as ve ss mE = EPC IRE | 3 sash evs Conic eri hots) - Eh yi A AP | ocopuaphi 37 Le i i= | ’ a PRS ccs = = + = © \ 4 E a i pcr opie ily, ary ish 8 ] = Fe am pene Juouacy 2016. (fron ehl | se © Vii : | | ele Bran gems ota unde Fo ig i A | fiz i 2 1 Stophes: [lawking. proscs ie z obroarine that ws cutTEE 1 > by tepstein Lo accom raodHe 1 3 JERR | tcc. Hnwhin EEE RN t pra; (he conlereuce ‘Coninatiog Ca gi A k saorciop 0 xl fa Vi TOEELET WY a PI go optim CHICA 3 TACHA, Cose Wes | A I $s vce ig Core . So ¥. FRESS.com’. isin, 57 TE ty SN fess li 3 oi Bi 8 wus at the concol: uf Tpsicin’s as the Herhent N. Si ras Mar sion, 5 ORG] Eo b 0 CE Be HE = 1 St | El ahs 22 i yi NV co oideaatiod tend, serded he = Se u a0 ? 7 ribeca ball, preseoed by vee Cleef pi il i - 1 hemi Ne Yok diy asd ae | 7 rt ou Apel £, 2014, (a New York Sucphen Hing, proccacapb ANS \l J wheelchair, Hawking was sees +a workshop o explore AE L phowoguphied at thie New “pousorea by the). Epeeia ES Bl 3, 11 200% hob ch ¢ \ B Foundation tnd the Coates Sovictydllere zm) wl) A och, use Ween U8 p idl ll | ES) —— ; Tuc NASCAR rive ia Vicks, ie yi Hor ered carpe aioe 147 | mess by. Teamngie epencyOriy wre ofa Ha hari, Sova in Louie fe 4 Kemtacky. elf rend eo ei i f A Re aeaiea § Mm | ii Mictoso He = + : Gand ghee i i 4 sevemlc Erin JT ciemis 32 { i Shed ha aL ll with Var Visoski, Epoetn's pssoral , o informat ! a wig Er ic orkyitols Gn am ay; \ ¥ \ uh Wha d . aris, bu A 5 Michact and jan Rete the Pl swipe hi t A cach Police soundsion cements ves x lh. Morag, onary , 2012 (Debbie Schace Palm Back The: I Bi) Day News ZUMAERESS om) Te i hisalfic | + : | Be . ho mal cha t include Eh when he Sew ple Bach pie x of | ene or rece, (I UO L J November 2012 eghan SU ER | fone of by arty teas Bech ty SO ¢ on doc News| ZUMAFSTSS com n | - 1 s : n 7) 1 dont see what it adds to the g 0 Yi Tpsteins Pim Beach Ri & $y EET TL" ov oie i ORL Way crs paigatian had taken place, that EE Sela ows Cod N Sat, a that time, no criminal ! ys DE rs had been launched. And in] 14 a the rumors of Epstein's dealings Fy le Lo be just that — THIS: | sk his aveyess, is editors, and his Que img odd and discorbing happened. 8 Lc afied a A ain Times Square. 1 pimple iene °S Af 4 search warn wa echrough ET SAIC 3 “oirpeeniiniove SASSI en (8 x 4 10 the office carly. He swiped his SSS —— 4 a the elevator hution, and arrived in 8 PN {om area on the twenty-first loot 3 Fi », ce ime to review Ward's sory Bq Bl | os town house—which is said 18 | i EN 7 dence in New York City at tie SUNY u JE — .. amid the Qurry of wenservantsy = san pot (ere 1h aud pristine white gloves, you elf hod, Skye Meow ork, 1500 canes private Xanadu shed wil ’ person's home, but a highwaled | | y ha seems to have no bunds h ch i WL od mor with punting: but wil EE Su coed eyeballs, these, the ever E8 . ) i ported from England, where £8 1 vs. Next cones a marble foyer. VER \ - manner of Jean Dubuflet. .- PEE i }d itors who pained it. 16 S0TER ics 1950 Gmemmons) 150 | - | Leslie Visenes. photoxisphrd 1 | Ee 1989 (0 Lyow Caidsrrith) a J i { EERIE y 2A y RS: F 3 ck ry i AD tte vent ot she v2 hi iq 2 aN 1 3 f< J 00.10 R) Debusad. | & 8 a VES | w FY cri eso | 8 [ 4 [| ) pa i ) Pt i a | Sepukpeve, ending the [RES | nia 2] af pany ar ua Belle dle © & | R aver, hotcgragted | me in New York Clty. | nd Ty Golde) Wlgiain Roberts, 2g¢ 2 3 LE ion phoco cepted = -\ E== ak pricy Specs = New Yor City Gingnia S rid oberts Ai, Us a Distt Southern Cows of BE mat i Florida) p hd f= It b vl i ab i | A) | i NG 3 9 |= 6 * / Hy | b} a LT 2 IN ae L I | nd Shishine Mex pho epee : al STAY J eed tondonromn bow, 6 -_ Raber wes socuteer yous ost this > ins, (Vegi Sabeas gar, US ) Distric Sothern Cort Horde) {i Bohm, Jeliey Epstir, " pe ——— Virgo bre, age scan ay po ge Jefe Eps Zann Sach, ¥ his New Mexica property, 5 a winter (Virginie Roderis } 5 Alida, US Dir Sutter EA Court Farida) Tem R-" y= hs = | UfJiA EE I? Lm. or ll sae | Ala Dershonis in Cubrids. \ % A Sepmlers, 2006 1 ok By ; he | began, Fp: iu pogo . Sh | oi eet ino or NC ¥ tN at Cigriamtin Hew York Clay, March i 15.2005 (or Shon Patrick 1 wieder) 4 | 2 i od E Yeo 1 a , tog the laure of Kader 1 an py = JAI vi ic | 4008 ate Bch oun Sherrie (8 ~ | L Teach County Skrrtfs Ofc LTS | i ase Re i A 4 ay = ST served lus venieke. on 2P | re le BY veri, 2s veil wmalelS | [ Al CE 2 Pieter Li. sth Sori Ofc Pd PRL Epstein and Lawyer a: he Wesc Jeffrey Epstein, photographed. hl pi” 2008 to ateca pls nearly two BI C7 ia Now York City. May 1 a i 3 \ Jeltyey Epstein entry in afd / 4 I ee hors i 2005, ws ocued 6H ii BEES Liu US Vieginkimiz a al 1 ond mid ne 1 SUE LE ih ON ch Florida. Au the tu 8 pe a EL ST — vendas mit. 47d LI TL TT Pe 53 securky facil borstng BY EE cen Curis So ona workrrien< prog AB 8 RET Aerial Chote) { Ege Gilet Ch a if sett RE eS Vie a ! ; % a B ey 2015 (© A i Se pn en Ce RY I i pa ds 38 2 A Wh RE eons - uw pct : i —— a EE oats peice S ra xr i Ce onary 00. (oc oul \ “4 JE —— | pr ’ ee | = ox af = 8 I hen re nd psc se ! strolling togetner hecugh Ne ors Cenrol mt | | Og) roy ics psi elase Ee gt | on il, de dle was ues. to quit ie Sa A | Bree IE | | | i MLS Sey | gs 11 il ; oN | git [HL § | I pen Hon, omit | a a Marea 2006 shoar! a AUGER | ' 5 i a coc ci co wecomuel® | RR hoy enki =A . TER nies one oe | = 1 ( “a workshop to explore in ] | 3 gr ed yh, Fre 7 i A / CN ho q 4 ation snd BACH . i \ . te Reseve Unni | ! : rion oi Tht SHG 1 | Cn cane wow HOUSE_OVERSIGHT_0104¢1 2 a | Fal fs TTT YEE — TE 5 > ; Rothstein ofc in Fo sven, = % v/ 0 £5 3 : gpl Coe rc Se Pan ! 4 Cane fon Pen Sone EA a || NX Eas 4 5 | 8 CBX J Hf oR 8 was i: the consuls #5 Fpsetns a the Fevhert N. Straus Mansion, = Tr be New Jersey, Jowiac 2016. {Jee mel Pack, was accuteed hy Leslie SESS SS Ea a Tie H oy 5 Vid i == = = 1 EN (ET EE BE iE tl i WP ™ fees al piss vom it pn nih Se} py ms Fd itr a fo of Art om April, 200, New Tork bli dal City. ily oreall Sha. com) P—— Whtlchie, Kautking wes $1800 adi Maclnkora, Michele yo \ f - Ae conference “Conltonting GE Plager i. Saran Kellew, sod Toals. - “a workshop tw plore nde Birics, phcingraphed atthe New £2 in yt). pac EE ryote Tee : \ Felueattar and reer FE 4 ari Astrophyales (FRC! sar rove nner A en Earn ae 2 tl A i" 5 “ Sara Cormusy Kellen "ry 3 TI NASCAR river Brian Vickers, Pr ll raging of the Kearuey Decby { etela A a Churchill Diwas in Laisvalle, 9 | 0° §} Ke spouses Mort Zu | f ] = : Microso 3 Goad fight among 4 A : } several ¢ ¥ i 5 hm scientist ‘Nadia Mascinkova snd Larry - i a oh Var rams pesorsl ial 1 er Tam os i Foe cotkps of «Crate ay We r AA \ uA Wha 5 aris, Michael id Tone Biter a tc Pal swipe hi f Seach otic Fenda Boeauss | erat \ 4 120i : J J Sohn Lagu leary 3 i 302 (Debbie Schatz Pair: Bech The) 1 A To Sows TAAPRESS om En is offs | \ | oo | — 1 nr 1 Epstein dtainlld nal chu | =F include | = hen he i etired Bal Doss police | Viwective Joo Recarey, 4 . ) Shield Novenber 2013 (uegran JARI one of hu secant un each Dry 8 on docu Nov ZUMAERSS om) Stim " A i wii Err Rica sod Lushand, Brien, | guests are like pygmies next to the nearby twice lifesize sculp- bitin) | ture of a naked African warrior” Downs in Loutsvile, ‘The: journalist had confirmed that several prominent names — como Re nrrr ne a mogul and publisher; | Microsoft executive Nathan Myhrvold: and Donald Trump 1 among them—had dined a the residence. She'd interviewed iy Pan lightie | several of Epstein’ friends and ex friends: Nobel Prize-winning Bm & | scivatists, financiers who worked with Epstein at Bear Stearns, 4 hi ~ i | Shed handled Steven Tofteubery, with aplomb. And, working ny &. | with Vanity Fuir's editors, shed figured out ways to slip even more : a 7 ‘formation betwen the lines, in ways that would allow readers maT (Bo: to form their own questions abowt Epstein's finances AN He { \ In that respect, shed fulfilled her original assignment perl, \ J A What Carter needed to figure out was what to do wid: the - § artist, her sister, and their mother’s story. Buc before he could Miclae) and Janet Rie a the Fela swipe his ey curd to let himself into the wayguzine’s offices, Car- Tesch Poler Fundaun Police <a tex saw a man standing in the reception area Dall a1 Mara Lago, January The man was motionless. He'd been waiting for Caer. 3012 Tibi sare Pal Dc ’ Daily esos ZUMAPRESS com) It was Jeffrey Epstein. Nonplussed, Carter invited him into | hivafrice re ro Epstein denied the cluims involving underage women, No criti Eiri nal charges had been filed. And so Vanity Fair decided mot to or clude the clits in Wards article. But, according to Ward = | when her editor Doug Stumpf called ber, she cried. [re % Shed worked so hard on the piece, gotten so stressed out that i LE i" fon of her twins had begun to grow more slowly thn the other. wity i On doctar's anders, shed heen put ou bed rest Jonces Pazranson hy?" she asked hen she. got to speak to Carter directly “Hes sensitive about the young women. And we still get to un most of the piece. In bee notebook, Ward wrote dawn the rest of what Carter had said: “I belive him" be told he “I'm Canadian” But the piece that carne out, in Lhe March issue, still created a sensation. t ws called “The Talented] Mr. Epstein in sly refec- ace to Patricia Highsmith's celebrated suspense novel The Tal ented a: Ripley. The film adaptation. by Anthony Minghella, was sil fresh in the minds of Vanity Fair's readers. For Graydon Carter, Just posing the questiou Is Epstein some sor of scam drt like Ripley? had bec question enough. And thranghout the pice, there were canes readers woulda miss as they drew Todd Meister: June 20. their oven conclusions about Epsiein's life story. It came thronigh, cleasly isthe first he of the last parageaph of Ward's 7.500-wurd story: “Mauy people comment there is something innocent, arty CHO almost childlike about Jeley Lpstein.” H= Therion Im camext, the word innocent was rather ironic —so much 50 postof Harry's Bar that ic almost became is own apposite: ops. fn venice, Lots ith a theme resiaurant—( hedge-fund manager nase wealthy man—|effiey Lp fuer, Fpstein's sometime “Lye known Jeffrey sir et we tell you what 1 ke everybody else says. First and here's why —he hes m that for hive” Meister knows how to tie son of a superrich fathe 15 sotto speak to Carter directly. amg women. And we stl get te down the rest of what Carter her. Im Canadian.” in the March issue, still created a ented Mr. Fpstein’ ina sy eles 8 FOR lebrated suspense novel The Tal ion, by Anthony Minghella, was sity Fal’ readexs. For Graydon 1s Fpstein some sort of scam artis, enough. And thruughout the ers wouldnt miss as they drew: Todd Meister: June 2015 sscins fe story. It came through. + parageaph af Wards 7,500-word & there 3s something innaceut, arty Cipeiuns, on Fifth Avenue, is a New York nsticu- spon” H tion. The restaurant hegan its life as an American ou- newas thes ironic —so wich postof Harry's Bor — which wasitselfa famous American opposite. output in Venice. Located inside the Shecry-Netherland horel, its a theme restaurant —the theme being money. And today, a hedge-fund manager neue Todd Meister i talking about a very weakthy mani—Jeffrey Epstein—wham he knows theough his father, Epstein's sometiuue friend bob Meister Tee known Jeffrey since 1 was nineteen” Melster says. “So Jet me ul you what 1 know—whatever everyone knows and Eerybody clo says. First ff, hes no billionaire. Second off 30d here's why —he has no clue how 1a invest. He has people do that fo bien * Meister knows how to invest. He does it for ocher pecple and. as sau of a supervich facher, for himself. He also knows about the i in JRO — | 3 good ie. Pastis in Vegas: weekends in the Hamptons; rs wi The mos: charming maz youd beautiful women thet end up getting splashed al over he bloids bingeing \t makes sense that, once upon u time, he und Epstein would tn mt Bey oy parties, | have gotten along commertion to Victorias Secret, As for the girls” Meister says, “that was just business. Hed Throw in the model seat them surategieally ac client dinners. Whe be went to the Peeps Ta rovics, hid take three ar four girls with hire. They take turns But the thing is, yes Wide Sh massaghog bis back, arms, and legs. b Cpsteln, geutng on that plan nveording to Meise, Lpstein used to bosst tha he “Liked to one Cae fyshack—the goat alms because hiked to fuk crazy women ant from his cle tthe golf wha knows if its trae?” Meister adds. “But Lm telling you, SI ove slike the male a hie used to sa 5. amatter of time before hed be : 10 ask yourself was, are peopl ali? Or are their morals lke From time to time, Epstein’s friends and acquaintances would shed (along with all the othe cs sid of Eps hat hed grove mich less shy about sharing. 1 everyday working people hav poten couraged Alan Dershuwics invest with a prone Eyes Wide Shur world? hedge fund manager named Oria Kramer. Dershowitz did, and he : made a lot of aney a first. But in 2008, the fund Dershanvizz bad {vest fs lost substantial ammount. Afterward, according to or Bo Mien oh wes TA oe sociale of Epstiis, Lpsein appeared in Kramer's midtowt forross Seihe Bourdon Manhattan fice. Thre, sources say, he told Kramer: “Its vey rauch editorial director James Troms {your interest to make Alan Dershowitz whole” oa Epstcins inervenion worked, and Derstowits ecosered bis Ee bdies nua Bim ——" At Hany Cigrian, the ques To people whott known Epstein back in the: 1980s, his kid of behavior was out of character. But the thing about Cpseia was acy never could gare ims out, One mit be was charmin 154 — Frurms Rien ds in the Hamptons; affairs with The mas charming man youd ever meet. The next he was snarl, gz splashed all over the tabloids. threat, and Buster. Something didoft add wp. So youd run the ma time, he and Epscein vould ‘mumbers: this many parties, that many women. Fven with the connection to Victorias Secret, the women didnt add up, either. 1s, "that was just business. Hed Throw in the. modeling agency, it makes mere sense. Then dinners, When be went 10 the you phig in the parties. The scene brings Eyes Wide Stat to mind. rls swith him. Theyd take turns But the thing is, Eyes Wide Shut only works in the shadows. For - Cpstein, geuing on that plane with Clinton was more le a used to boast that be “liked to momen in Caddyshack —the one in which the grounihog peeks he liked to fuck crazy women aut fram his hole in the golf course. From there ou in, Jeffrey cister adds. “Bu Tim telling you, Epstein was like the mole in 2 game of whack-a-mole. le vias oaly a matter of time before he be caught, But the question you had 0 ask yourself was, are people like Epstein born sitaout mor- als? Or are their morals Tike snakeskin —just something chey ends and sequaintances would shed (along with all the other basic, day to-day couccras that it sch less shy about sharing everyday working people have) as they make their say into that dhowitz ta lavest wth a prominerit Eyes Wide Shut world? n Kamer. Dershowitz did, and he 1 2008, the fund Dershowitz had. sunt. Afterward, according to 8 Be Todd Meister, who was martied tr Nicky Hilton and stole the sin appeared. in Kramer's midtov biiress Samantha Boardman away from Condé Nasts former say, he old Kramer: "Is very unclt editorial director James Truman, should know He wonders out xshoviiiz whole, loud: ed, and Dershowitz recuvered Als “How does a yutz like Epstein yet beautiful women?” AuTlarsy Cipriani, the question Linge in the air inn back in the 1980s, this kind But the thing dboue Epstein YouL One mite he was chart 154 13 PART IV The Investigation CHAPTER 40 Michael Reiter: January 2006 i 3 fr as Michael Reiter concerned, the case that his tear has built against Epstein — slowly, meticulously, over the course of an entire year —is airtight. Even now, Detective Recarey’s finding new pieces of evidence, And already Reiter's been laying the groundwork with prosecutors. State artomey Barry Krischer hs 4 reputation for toughness. Hes kiown, satianally, for his prosecution of juvenile offenders. And Reiter's been keeping him abreast of the Investigation. With Jeffrey Epstein, its not simply 4 matter of seeing him punished. Its & mate of geting a sexual predator off the streets of Palm Reach, Krischer assures the chief that hel taking this case very ously. The state attoracy’s office will have Reiter's back ul every tn “Told hizo that we had an investigation that was very serious James Parris | thatinvolved avery noteworthy person aud that involved a num- ber of underage females? Reiter would say in his depositian for the suit that was later seuled by Epstein. “That it was of u sexual nature. 1 was concerned that we had not reached all of the vic tims, and we hadnt, I'm sure, at this point. | (wld him that 1 felt ike the suspect would probably become aware of the investiga: tion at some point and that we shouid probably expect some con- tact from... Mr. Epsteir's lawyers. And 1 told him that 1 wanted 10 ep him very well informed on this and that | hoped that he would do the same. And that we would have fo have more con. 1 cact inn making sure it was handled responsibly, intelligently, and appropriately as it moved forward" Relter would say that Epsteinis name did not seem to ring a Detective Recarey: Fel bell with the state auomey. But shortly afterward, the chief 8 became aware that in certain powerful circles his investigation was being looked upon unfavorably. “1 had many people-related or months, Joe Reca conversations ..an the cocktail-party circuit that suggested we F= brought 1 Eps approach this ina vay thal wasnt necessary.” he would say. and car-rental reconds Michael Reiter wana good cop. A good ran. But he was about according to source withis to discover that when it came to men with the power and influ: would idem forty-seven cnce Epstein wielded, falrness under the Law was a relative, mak on El Brille Way. leable concept. Recarey interviewed or David Rogers, as well as Eps He also spoke to a wun » It turned out that Epste actwal Swedish deep-tissuc. Bor him and Lis friends, ¢ ther, Did anything untoward Epsicin ever asked the wom: 10 person and that involved a nue: © would say in his deposition for Epstein. “That twas of a sexual ve had not reached all of the vie: ac this point, 1 told him that felt y become aware of the lavestiga- 3 should probably expect some con- A xs, And 1 told him that 1 wanted d on this and that 1 hoped that he sve would have to have more con dled responsibly, intelligently, and > ame did not scam 10 Ting 3 Detective Recarey: February 2006 But shortly afterward, the chet + power circles his investigation sorably. “| had many people-relited or months, Joe Recarey’s been interviewing girls whod Lail-party circuit that suggested we been brought to Lpstein's house, subpoenaing telephone sary?” he would say. and carrental records, conducting surveillance. Ultimately, a ani But he was about according to. source within the Palm Beach PD, the department a the power aud infli= would identify forty seven underege girls whod been molested + under the law was a relative, mak onl Brilla Way: Recarey interviewed one of Fpstein's pilots, 3 man named David Rogers, as well as Epsteins housemnan, Alfredo Rodriguez He also spoke to a woman who really was a massage therapist. Ie turned out that Fpstein paid Just one hundred dollars for actual Swedish deep-tissue massages that the therapist provided [for him and his friends, the lawyer Alun Dershowitz among them. Did anything untoward ever happen? Recarey asked. Had ein ever asked the woman to rub his chest? 6 Jans Pazrimsex No, she told lim, She wasa't Epsteiuis type. The gals shed seen at his house were very thin and beawiful and did not bave tattoos, his massage therapist had several tattoos that were vis- ible, andl on quite a few occasions Epstein and Ghislatme Max- well had made negative comments about ther. ‘According toa Palm Beach Police Department Incident Report fied by Recarey an July 25, 2006, the detecuive hau also heard 8 {rom Mary's ather, who said that a private eye. had been Lo his house, photographing his family aud chasing visitors away. ‘Mary's dad had gotten the license plate — Florida ET9-4EG. Recatey traced it back to one Ivan Roles of West Palm Beach. ] Robles mrned out to be s licensed private investigator: 1 Recarey informed the state's attorney's office. | Barry Krischer: April Alison also contacted Recarey and told bim that shed been 1 approached by soueone who wis in touch with Epstein. Alison had heen told that she'd receive money if she would refuse © 3 late atorney Barry | cooperate with the police. Ne taking his gost Those who help him will be compensated, she was told pvand agen Peles according to Detective Recarey’s incident port. “And those who 1992 azd 1996, he had rus hurt hz will be dealt with." and 2004, During the cou Recarey reassured the girl and told her that tampering witha. 1970 with a three-year sti witness in a case like this was a serious, avrestable offense Brooklyn, he received 2 my Then he told an assistant state attorney. from the Legal Aid Society he detective was leaving uo | nndotted sud no uncrossed. with the juvenile justice s But he did wonder if the state attorney's office itself had Protection team; the Peace become part of the problem. Bor Jeb Bush, for his work tinue achievement award fi member of the National I Wos not necessarily averse In 2003, Iie launched an in w@ Epstelns type. The gils shed and beautiful and did not have 2d several tattoos that were vis 1 Epstein and Ghislaine Max- 's abou them. | lice Department incident Report | 6, the detective had also heard. CHAPTER 42 1 2 private eye had been to his and chasing visitors away. ense plute — Florida E79. 4EG. fran Robles of West Palm each. 3 4 private investigator 3 attorney’ office Barry Krischer: April 2006 y and told him that shed been 5 1s in touch with Epstein. Alizan + money if she would refuse to ate atorney Barry Krischer was an elected. official, but Gr talking his post, hed beeu a lawyer in private practice: be compensated, she was told in and around Palm Beach. Elected twice to his office, in {neident report. “Aud those who. 1992 and 199%, he had run unopposed for state uitorney in 2000 and 2004. During the course of his long career, which began in told er tha tampering with 1970 with a three-year stint in the district auorney’s offic in serious, anestable offense. Brooklyn, he received a number of awards: the pro bono award A from the Legal Aid Society of Palin Beach County for his service » tndotted and no ¢ uncrossed: ith the juvenile Justice system and for his work with the child state attorney's office itself had procection eam; the Peace at Home award, presented by Gover oc Jeb Bush, fo his work with victims of family violence; a lfe- time achievement award from the Florida Bar, He wis a board etuber of the National District Attorneys Association. And he not necessarily averse 1o going after the rich and powerful, 2003, he launched an investigation into Rush © imbaugh's use ww iw Janes Barrens of, and means of obtaining oxycodone and hydrocodone. (A fess former law firm agreed years fier Limbaugh's arrest, which caincided with Chief Rell sand dollars in legal fees ers investigation into Jeffrey Epstein, the talkshow host setled with prasecutars, agreed to submit to random drug testing, and gave up his firearms permit) Now Chief Reiter aud Dx Krischer himself, however, had been accused of sexuil their own questions abe misconduct. went a charge Epstein I October of 1992, Jodi Bergeron. a legal scretary hail worked behavior and Jour cour for Krischer, fled a sexual harassment wsuit against him in the minor felony charges “Palm Beach County circuit court, That suit was dismissed, buta fw behind bars in the cas months later, the woman took Keischez to federal court, accusing Kellen would be charged him of aking nmvanted advances and demanding recompense for This was not the plas baery, negligence, invasion of privacy, and emationa! distress for Jeffrey Fpstein. Ketscher fiad placed his hands, violently, inside her Blouse, In cases involving th Lae woman said. Hed forcibly fondled hes breasts, forcibly kissed attorneys tend 10 have 5 her, and rubbed her shoulders while brushing her buttocks with But instead of granting b his hands sad knees, all while accompanying the gestures with 4 the police thal he would verbal advances, asked to considera broac When she declined those advances, the woman claitned, : Ina case such as Epstc Krischer fired her, | ag in and of itself. Bury Krischer dened the allegations, At the time, he was making bis only required i: capital cas first run lor the state. aworney’s office. The charges were politically | may dso be called in © motivated, he said. Members of a local chapter of NOW—the (8 Imvalving crimes committ National Organization for Women — had stood by the laviyer, Gi wasnt a public offical, au ing his efforts 0 stop domestic vielenee, among his other virus. cerned, the only controver 1 am here ta support Barty Keischer for the work his office that Epstein was rich an aid in my daughter's case” one wornan said during 4 tally thal BA. vs. Epuiin, Chief Rei 100k place. in front of the courthouse. “Her murderer received cuter had to make sure | the maximum sentence, a lie semence” able doubt. And Krischer s Thesecond lawsuit had also been dismissed —after Krischets: ofthe young women whot. 161 odane and hydrocodone. (A few former law firm agreed to pay Bergeron's attorney seven thou. hich coincided with Chief Reit- sand dollars in legal fees. stein, the talkshow host settled uit 0 random drug testing, and Now Chief Reiter and Detective Recarey were beginning 10 have had been accused of sexual their own questions about Barry Krischer. The Palm Beach PD wanted to charge Epsicin with one count of lewd and lascivious ron, a legal secretary who'd worked. behavior and four counts of unlawful sexual activity with 1 stent lawsuit against hin in the minor—felony charges that would have amounted to years That suit was dismissed, but 4 few 1 bebind bars in the case of a conviction. Wendy Dobbs and Sarah ‘rischer to federal court, accusing Kellen would be charged as accomplices. es and demanding recompense for This was not the plan that Krischer seetaed to have in mind fvacy, and emotional disress. for ellrey Epstein ads, violently, inside her blouse. In cases involving the sexual abuse of minors, prosecuting dled her breasts, forcibly kissed 5 attorneys tend to have suspects arrested, then push for a trial while brushing her buttocks with But instead of granting his approval for an arrest, Krischer told accompanying the gestures with the police that he would convene » grand jury, which would be asked to consider a broad range of charges. advances, the woman claimed, Ina case such as Fpstein's, this was highly unusual. Not damn. ing in and of itself. But very strange. In Florida, grand juries are Jus. Al the time, he was making his. Only required in capital cases. At the stare attorney's discretion, they office. The charges were politically way also be called in controversial casci—for stance, cases of a local chapter of NOW—the involving crimes committed by public officials. But Jeffrey Epstein sen—had stood by the lawyer, dit wasn't a public: official, and as far as the Palm Beach PD was con- riolence, among his ther virtues. cémed, the only controversial thing about the case they'd built was + Krischer for the work bis office tat Epstein was ich and well connected. In his depostion for +e woman said during a cally thal LB. vs. Eptets, Chief Reiter rel syrel Krischer's concerns: the pras- arthouse. “Her murderer recedt tor had to make sure that his ces: was solid, beyond a reason- PO bl dou. And Krischer did have his doubss about the credibility been dismissed —aftes Krisct the young women whoid be called to testify against Fpstein. ie 165 Joncas Parreason | Puen so, Relter was beginning to wonder if Krischer was stacking the deck in Epstein favor— if, thanks 10 the sway prosecutors have aver grand juries, assembling such a Jury wasnt an excellent way to let Epstein off with the lightest pun- ishment possible Another unusual thing: the vay Barry Krischer and the law- yers working for hiro ignored Chief Reiter's multiple phone calls ‘25 well as Detective Recatey's—even though the police had been ‘hearing, [rom Epstein's awn lawyers. s(Krischer] and 1 had an excellent relationship.” Chief Reiter <aid in his deposition. “T was the speaker at his sweariog-in cete- mony, And thas he wouldrit return my phone calls —T mean, ic | seas clear to me by his actions that he could not objectively look Palm Beach Police Depar at this case” by Detective Joseph Reca 1a the incideat ropa be ended up writing, Detective Recarey 8 On April £3 and April 14, remembered 2 phone call that he received from Guy Fronstin, 1 eral occasions with ASA | one of the lawyers representing Fpsiein. Weis and £52 fam) It was & message Epstein wanted to send, something central © 1 victims needed to report or the case that demanded explanation. The whale shit show swirling are, Wt on het voice around him was just a misunderstanding. a mistepresentation— hours of 9.00 am and 12:30 of Epstein’ actual inferests and inenvions. Weiss and ASA Belohlavek Fronstin says Mr. Ipstein is very passionate abou massages, call as had not heard from Detective Recarey would write ht rear det of to And: Mr. Epstein had donated aver $100,000 to the Ballet of At approximately 12:30 Florida for massages. ney’ Office and Located A¢ nd: The massages are therapeutic and spiritually sound for their offices. { entered ASA him. That is why he has had so many massages. me shat she was going to re @n offer was made to the: | iss mg tw wander if Krischer vs favor— if, thanks to the sway uries, assembling such a jury tein off wich the lightest pun- way Barry Krischer and the law ef Reitec’s multiple phone calls ~ even though the police had heen CHAPTER 43 ellent relationship,” Chief Reiter speaker at his swearing in cese- «ern my phone calts— | mean, it at he could not objectively look Palm Beach Police Department incident Report Filed by Detective Joseph Recarey: july 25, 2006 ! d up viting, Detective Recarey On April 13 and April 14, 2006, | attempred contact an sex- he received from Guy Fronstin, ent accasions with ASA fasistau state attorney Dut i Lpstein. Weiss and ASA [Lanna] Befohlavek ascertain when the ated to seed, something central 1a vii needed report for Grand Jury testimany. Messages tion. The whole shit show swirling ware lft on shir weet, On April 1, 2006, during ge <tiunding—a misreprescutation— Fours uf 9:00 am and 11:30 om J agin left rss — 5 atemtions. Weiss and ASA Belohlavek or either of them to retum my very passionate: about massages, all as I had not heard from the State Attorney's Office as to the time and date of the Grand Jury, : ted over $100,000 to the Ballet of AC approximately 12:30 pm, 1 wen to the State Artor ney’s Office: and Locared ASA Weiss and : ASA Welss and ASA Belohiasck in sapratic and spiritually sound fF their offices. entered ASA Betohlavel's office who informed any massages. e that she was going tw veturn iny call. Ske explained that an offer vas made to the Defense, Auty Guy Fronstin wnd 186 107 Jasess ParTeRson Atty Alan Dershowitz. The offer fs | count of Agg Assault with intent to commit a felony, five years probation, with adjudication withheld, Fpstebn would have (0 submit i psy- Chiatricisexual evaluation and ao unsupervised visits with minors, When asked about all the other victims, ASA Belohlavek stated that was the only offer made as to one vic- tim, Mary. ASA Belohlavehis] cell phone rang and went to voice mail. She checked her voice mail and played the mes sage on speaker. The calle identified himself as Atiy Guy Fronstin andl acmowledged the deal made between them. Frost stated in the message, he spoke with bis client, Jef rey Epstein, and would agree to this deal. Fronstin asked to call off the grand jury as they would accept dhs deal | Michael Reiter: May 2( Belohlavek stat probable cause vould be needed to book Epstein in the county Jail and would let me know as to where ; it was needed. 1 plained my disapproval of the deal and not denote being consulted prior to the deal being offered. However | 3 A Chief Reiter is o expressed that was only wy opiaion and the final apprival 8 Steins da would come from the Chief of Police. She: explained to have Ev Po aad or Chief Reiter call Barry Krischer abn the deal. Tet the Soe Epic got off with oa area and returned 10 the police station where | briefed the 3 ad a peych exam. Chief about the deal offered Why? J checked my voice mail messages and discovered a mes- HT sage from [the] stepmother for the victtm (Mary). She was Pieces of evidence —printoy calling because the State. Attorney's Office sill hud not To bir “A535 Me cone returned any of her cals as to when they are needed for this Ie ti eee case. | then called ASA Belohlaveles office and left messages Ee “Ever ron an, Jor her 10 cal the vicims on this case and explain (0 them “Yeah, vihat the State Attorney's Office had done. Under *Ever shoplified*: Under “Ever skinny dipp 68 er is 1 count of Agg Assault 1, five years probation, with would have to submit psy no unsupervised visits with all the other victims, ASA only offer made as to one vic cell phone rang and went ta I ice mail and played the mes- | CHAPTER 44 tentifiet himself as Atty Guy ie deal made between them he spoke wich fis client, Jef 10 this deal. Fronstin asked to hey would accept this dec. Michael Reiter: 1: May 200( ause vould be needed to book ay 2008 would lec me know as to when Jlisapproval of the deal and not Pleaalier? teal being offered. However | A Clieh Ba . citer is outraged. His fea has logy: pinion and dhe final approval sands of hours of work. They've asembled A Palice. She explained to have evidence. But instead of going 10 trial, the state ut se her about the deal. T eft the A I Mi ce station where 1 briefed the and 1 poyeh exam, *. five years of probation, Why? \essages und discovered « mes- —— io 1 owitz bas presented the pros: torney's Office sull had not i 2 when they are needed for this Mary has written “Ass and - st physical feature,” Taveks office and lft messages Niner “Ever de © “Ever drank” aud “Ever sm this cuse and explain to fhe “Yeah aud “Ever smoked pot,” she's written rhelime, Under “Ever shoplifted® “Lots” Under “Tver skinny dipped “Yeah.” 168 5 Juss Brrrensen Under {Dio} you sara ose yor virginity; Talready lost iL" E — Oni of the victims has been caught with drugs and arrested. She's also heen caught stealing from V ictoria’s Secret. From the EF TOWN OF tate attorney's perspective, these girls look like compromised cel POLICE women. And if what they say about Fipstein is Lue, wouldn't that EY sisi make them prostituies? Ns witnesses, they wanld be. weak, while the lawyers on | r—— Epics side were exceptionally Song Sim 41n Dershowitz had tepresented Clans von Blow, the Brit- Sra, i {sh socialite who was acquitted of the unurder of his wife, San. i Dershowecz had been on 0 J. Simpson's team whee the foruer | msm eg se ont sar ras acquit of the nudes of bis ex-wife, Kicole SERA Brown Simpson and Nicole's friend Ronald Lyle Goldman. And | po a Tn Heh as son Bilaw and Sianpson had been, neither one had had Ee he resources that Epstein vas willing ane able to depley in his (= awa defense. | a ether of hers had been intimate friends wich is lawyer. 8 SRR ns far as Reier was concerned, none of that matered. Even SS | ia Epstein thought that the girls hed molested were sigh. year & deve if they bad led to hi —it didot matter under Flor A ida law, The chief grew worried that in Epsteinis case exceptions - il were being sade, and he grew even more concerned w ith cach snretarned call that he made to the state atiomey’s office. On May 1, the Palm Beach PD asked the state attomey’s office Prec sircaniony 10 issue an apvest wasrant for Jeffrey Epstein. — That same day, Chief Relter took the extraordinary sie of writing Barry Krischer a letter all but demanding that he recuse himself from the case. wn survirginity’: “Lalready lost it” -— aught with drugs and arrested. | — ‘om Victoria's Secret. From the. GE TOWN OF PALM BEACH | girls look like compromised Gl§s95 POLICE DEPARTMENT & ut Epstein is true, wouldnt that | = BT PN — | « weak, while the lawyers an ——— | song SE ated Claus von Blow, the brit ERT [ {the murder of his wife, Sunny, boss pss team whe the rer | cone ts nn cv oon | nd Ronald [le Golduwan. And § ER SE RRR | (imate friends with bis lye. A LT er a | +d, none of that mattered, Even if fe die Liu Rl £2 | #d molested were eighteen years : ait didnt is Flor Muka Res) that in Epstein's case exceptous - Surin | even more concerned with each | the ste storeys office D asked the seate avorney's office: a —— | {fey Epstein. — + took the extravidinary step of all but demanding that he rec wn fa Q Can you tellus why? A Well, iol the handling - way the sate attorney's of unusual. | knew that M about this case. T felt tha 1 felt that the appropriate ” o averned the assignment 5 iR 45 f = CHAPTER that his action met the st from the statute in here, £ wouldn't return my phone The detective antempt 3 state atiorney’s office, 121 Videotaped Deposition of Michael Reiter in BB. vs. : sos th..m she Epstein, a civil lawsuit against Jeffrey Epstein ii ik November 23, 2009 3 case und ask the governor Tike that was necessary for point you sent a letter © state attorney Burry Bad been submitted to hin te. etme ow yo what wel rk a exhib 3 1 @ Could you ell us, explain ii i hance fo read through this letter again to help tivity may be licking fe refresh your recollection. you felt made It potentially ['ve read it. We ” A ie) in May of 2006, I'm assuming based on what A: Well... when 1 first told h Li told us before that you had had some conversations wilh that it was a serious case, | you her dircctly... by phone. —corsectt— prio to this and] chat the suspect was Barry Kiscl i it. Amd we were—it was i letter. meeting that he and 1 we . ccting that he and | we he wersations in persan and by phone. pi in onetheless in May—May 1, 2006—you fl the Known in 10 be a victim ay. Jue A ease of children. Well, | know tl ais letter; is that correct? h need to write this letter, Is Statute that addresses tho Yes 172 ¥ 1 Farr Rien Q Can youtell us why? A: Well, 1 elt the handling —and just concimued to fel that the way the state attorney's office handled this case was extremely wisual. T knew that Mr. Krischer was making decisions about this case. 1 fel that his objectivity was lacking, and | felt that the appropriate way, after reading the sane that ”. 1 governed the assignment of cases to other circuits — 1 felt CHAPTER 45 that bis action met the standard, 1 used some of the words from the statute in here. And 1 attempred to call kim, and he wouldut retuen my phone calls. The detective attempted (0 contact his conser In the state auarney's office, Lanna Belohlavek, however you pro- Michael Reiter in BB. vs. nounce that... and she wouldn't recur his calls, So 1 wrote winst Jeffrey Fpstein: the letter in hope that he would think about his situation and ¥ h realize that his objectivity was insufficient to prosecute the case and ask the governor to appoint someone else. And 1 lt like that was necessary fo a fair prosecution of our case that a eater 10 state acoruey Bary. had been submitted to him. a what well mark as exhibit 3. Let Q Cold yon tell us, explain to us, why you felt that his objec ad through this leer again 10 help tivity may be lacking in regards to this prosecution... ? In other wards, what evidence did yon sec here, uncover, that you felt rade it potentially nonobjective? 2006, Pm assuming hased on Fal A: Well.._when 1 first told him shout the case, and | realized had had some conversations with hat it was a serious case, [that] there were multiple victims, by phone correct! —priorio is and) that the suspect was very well known, I told him shout 7 it And we were—it was in person. T talked to him after a oo meeting that he aud 1 were both involved in. And 1 had May May 1, 2006—you 6 known him 0 be a victim adsocate snd to protect die rights {5 that carreet? of children. Well, 1 know that he even wrote « purtion of the Statute thor addresses those issues. And when I told him m Ci Jas Parrinsox originally, he said, “Let's go fori; this s au adult male in his fifties who's had sexual contact with children of the ages of {le victims" He said this is somebody veh we have 10 stop. And whatever we need, he said, in the siace attorney's office, we have a unit that’s equipped 10 fnvestigat: and prosecute these kinds of cases, And 1 did't have too many facts carly. on when 1 talks! with him, but kaiew that there were muhl- ple victims and to our detectives they were believable. So when time went on and Mr. Epstein became avare of the investigation and his lawyers contacted the site aoraey’s office, they told me that ‘And from that point on, and | believe it was Mr. Dershow- 8 r= initially, the tone and tenor of the discussions of this case Detective Recarey: May ith Mo. Krischer changed completely. [At] oue point he sug: : i gesicd that we write [Epstein] 3 notice Lo appear. which would be for a wisdemeanor. He just completely changed biel Reiter's letter to 4 from ot only our frst conversation about this|— when] ke (Cee didn't know the name Jeffrey Epstein- ill when he had Rrischer did not been informed on Mr. Epsiein's reputation and his wealth, arest wartant was issued, &1 and 1 just thought that very unusual tive Recarey received a telep 1 feel like 1 kaw him or knew him very well, the staie ney Dlich Weiss, who advis attorney, and 1 just fel like be could net objectively make he Epsicin case. decisions about this case: that is vy Twrore i. Weiss had been the perfo tember of the special victix and crimes against children, p ig rape, aggravated child al added another lawyer, aman Goldberger his auorney of re: | Goldberger was friendly late of Goldberger’ was mar wm or it his is an adult male in bis | act with children of the ages of somehody who we have to stop. aid, in the state atorne’s office, sed to tmvestigate and prosecute didnt have too many facts early ut T knew that there were multi- sctives they were believable. So CHAPTER 46 1. Epstein became aware of the 5 contacted the state attorney's and believe t was Mr. Dershow- (I Jor of the discussions of this cass J Detective Recarey: May 2006 zompletely. [At] ane point be sug: tein] u notice. to appear, shih wor. He just completely chunged. hie Retzer’s letter to the state attorne Lo wersation about chist — when] be: Co i frey Epstein ill when he had Krischer did not recuse bimself from the case. No tein's zeputation and his wealif, artes warrant was Issued. And on the aftertoar of May 3, Detec- SS} 3 tre Recatey received a telephone call from assistant state ator or knew him very well, the stale ney Daliah Weiss, who advised him tha she had been taken off lie could not objectively make the Epstein case hat is why wrote it Weiss had been the perfect person to prosecute Epstein. 4s a tember of the specie] vietims i, she. focused on sex crimes nd rites against chillren, prosecuting high-profile cases invol- ig rape, aggravated child abuse, and neglect. But Fpstein hud added another lawyer, a man named Jack Goldberger, and made Goldberger his attorney of record. | Goldberger was friendly with Barty Krischer —and am asso- of Goldberger's was marcied to Daliali Weiss, 14 ws Jaes Pacranson Poms If Epstein legal team had wanted to semave Weiss from the “I dont know how much y case, this sould have hen a good way to do it national Aicport. Its the kind Ning days later, Detective Recarey met with ASA Lanna valet parking, and waiting low Belohlavek, sho told him that ber boss, Barry Krischer, had asked youll see inn Manhatten, Its ¢ he again to take: the case Lo the grand jury: Recarey told Beloblavek Saudi princes, heads of siate. F hat be hid lady requested arrest wareants for Epstein, Sarah Kel- vacy. You can bring limousine Jen, and Weaudy Dobbs. The Palm Beach PI had finshed its iovesti- out Epstein was very secretive gacion months eackier, he aid, and had been waiting since then ox want anyone to know the tail u he case to move Forward. He asked her once more to iswe the war- But our contac did't like rants. Once again Belohlavek declined, saying that the original offer 8 how young the girls around Eg; her office had made to Epsteinis old laveyer had been resubminted to had che 727% tail number, an: dhe mew Lauwser, When Epstein reply cate, she would call someone | wom suy 100 muc! While waiting for that call, Recarey received several calls flight plan for a certain trip h from Mary's father, who told hi that he was being followed bya going to land at the airport. A green Chevrolet Monte Carlo—tatled so aggressively that other 8 the station's traffic helicopter a vehicles were being run off the. road. Recarey rau the plates and 8 hundred feet a quarter mile sou found that the Chevy was registered 10 one Zachary Bechard of “Our cameraman had a tele Jupiter, Florida. tight shot, an video, of Epstein Bechard was a licensed private eye. &d get the shot: Epstein, with flipped up over his neck, ahout that was waiting lor him, «A funny thing happened in Palm Beach, says Ti Malloy, who “Then he saw our helicopter was working as a TV newscaster in South Florida at the time. “1 was doing u live voice-av “This would have been right around the time that Michel Ritst video anyone had ou him « Reiter sent his letter asking Barry Krischer to recuse himself run back ono the plane, The from the case. | didn't even know what Epstein looked like, break, my producer told me really, ut the time. We hud pictures taken by the British tabloids Epstein wants us to stop taking where the link to Prince Andrew first broke. But we didnt have. alk 0 you. Loo many of them. What we did have was u contact in the huagtt “The cameraman kept rolll where Epstein kept his 727. Ou, or into a cur with tinted ue 5 anted to remove Weiss from the *T dont know how much you know about Palin Beach Incer- PA national Airport. 16s the kind of place that has private hangars, Recarey met with ASA Lanna valet parking, and waiting lounges that look ss chic as anything, + boss, Harry Krischer, bad wked youl see in Manhattan. Is an airport for che rich, basically and jury. Recarey told Peloblavek Saudi princes, heads of state. Powerful ten who value ther pri- stwarnants for Epstein, Sarah Kel vacy. You can bring limonsines onto the tarmac. And we found Peach PD had finished ics investi out Epstein was very secretive about his dealings there. He didrt 4 od been waiting since then or want anyone to kuow the atl numbers on his planes, d her once more to issue the war- 8 But our contact did like Epscin. And he was horrified by ined, saying that the uriginal offer how young the girls around Tpstein were. So thanks to him, we d lawyer had been resubmitzed to had the 7275 tail number, and thanks one: other source— ply cane, she would call. someone [ wont say too much about here we had Epstelris Recarey received several calls 8 flight plan for a certain crip he was miaking, We Loew he was that he was being followed bya ME joing Lo land at the wirpart. And so our producer climbed info tailed 50 aggressively that other the sation’ traffic helicopter and told the pilot to haver at five road. Recarey ran the plates and hundred feet a quarter mile south of the field. tered (0 one Zachary Bechard of “Our cameraman had a telephoto lens The idea ws to gt 2 tight shot, on video, of Epsteln deplaning. And for a mement we a did ge the shot: Epstein, with the collar of his cashmere cost lipped wp over his neck, about 10 ram down the steps into a cart Un ms elting for Li, Im Beach” says fim Malloy, who. “Thien he sax our helicopter, with the steronts markings. in South Florida at the time. “Twas doing a live voice-over on Tipstein’s arrival It was the hi around the time that Michael first video anyone had on him wp to that paint. But Epwein had iarry Krischer to recuse himself run back onto the plane. Then, during the next commercial know what Epstein looked Ie, break. my producer told me through my headpiece: Jelfrey ures taken by the British tabloids, Epstein wants us to stop taking his picure. In fact, he wants to ew first brake. But we didn't haves talk to you. 1 have was x contact ix the hang “The cameraman kept rolling. And eventally Epstein got 80 into a car with tinted windows, and was driven over the ws 7 Tases Barras bridge tn bs home in Palm Beach. So na sense we alld 10 get | he stoey, but the face that Epstein would call a news program | from his plane and comumand them 1 order the prograru's wraffic belicopter away. that says something about the mass arto: ance. And maybe his temper” Mary: July 2006 June 29, assistants would be going to a covered for July 19. On July 12, Recarey spok that she sll adit heard fc 100, was old, since Recarey pon to testify. She was hack in Palm Bez out fae relatives. Allin al, it bad beena ve “What has happened to father would say Mary bad been sent to ¢ Rett 7a the wrong place at is h. So in u sense we failed to get ein would call a news program +m 0 order the program's traffic neiling about the man's arro- CHAPTER 47 Mary: July 2006 1 Junie 29, assistant state attorney Lanna Belohlavek told would he going to a grand Jury fier all. One bad been convened for uly 19, On July 12, Recarey spoke with Mary's stepmother, wh said that she will hadnt heard from the state auweney's office. This, tou, was odd, sine Reearey knew that Mary would be called upon to testify She was back in Palm Beach now, alier months of living with out-of-state relatives. Allin ll, it had been a very tough year for Mary. “What has happence to my daughter’ life is criminal” her ther would say. Mary had been sent to a school for troubled children. [ior iL was the wrong place at the worst time in her life. She had &% ww Jans: Parrenson ” gotten nto more fights there, growing depressed and withdraw, TL from her sister and parents, Helpliessly, her parents watched hex celebrity lawyer—Ken Sta spiral owt of control. As they neared the end. of their cope, they hat hd Bill Clinton impeae ent hee out of ste, But after the move, Mary had fallen apart eam, completely. She used drugs, fell in with a bad crowd. ra away 5 far as Mary's parents from her relatives, aud shacked up with a gang of drug dealers walked into an ambush. Ew ‘When the gang was busied by local police, he dealers blaued playing defense on the side Mary for snicching and pu ot the word that they wanted bee ond girl — Alison, who cla dead. never testified in court atal We had to move her again,” Mary's father explained. “We inal got her to therapy —she’ will seing the herapist. And worst of sll, she developed [TPV. She's already had to have a seri- i ous operation” j ‘Mary's roubles didnt end there. On June 28, she vas brought in front of the grand Jury. She hadnt been briefed by the state attoraey—she. hada even met the prosecutors—and she had (8 no iden what she vould be asked. ‘Aluost immediately, she found that she was being eed ‘mare like a criminal than like a witness or viet. “The prosecutor produced a printout of our daughters Myspace page; Mary’ fathe recalls. “Mary was stuuaed She began to cry. The prosecutor accused hee of all sort of thing was like she was working for Epstein. ALL this time, we kncyr tha we were being watched. Creepy guys. Privars. investignors fram Marl. they would follow 4% caring the hell out of my wife and Mary sister My car was ais dalized. Towas like Living in hell” By this poor, Epsein's defense drearn trad included Jack Goldberger, Alan Disshowizz, and Gerald 1 four. All of te in excellent track tecords. Dershowitz and Lelconrt were (88 150 FER Furey Rien wing depressed and withdrawn, of Americas mast famous lawyers, and before long, anath lessly, her parents watched her celebricy lawyer—Kem Starr, the former solicitor " — iid ew ant of their rope, they RR bt hn 1] Clinton peach for perfory— would i +e move, Mary had fallen apart team, rjury—would join Epsteinis in with a bad crowd, ran away As far as Mary's parents were concerned, their daugh 1p with a gang of drug dealers. | alkene i —" nthe WL ied Local palice, the dealers blamed playing defense on the side of jeffrey Ipstein. And as Fi . oe the word that they wanted hes ond girl —Alison, wha claimed that she had et ih never testified in court atall, Marys facher explained. “We es still secing the therapist. And She's already had 10 have a seri ere. On June 28, she was brought hadn't been briefed by the state the prose: utors—and she had J a Jun that she was being treated | witaess or victim. 1 a printout of our daughers recalls, “Mary was stunned. She ceased her of all sort of things: rein we were being watched. Creepy m Miami. They would follow uss and Mary's sister. My car was Yar a fense dream team incloded Ja and Gerald Lefcourt. All of 8 Yershowitz and Lefcourt were we cl 1 ¥ ‘Once again, Chief Reite took the extrordinnary ste] prosecutor’ office. Atthe time, the federal Flarida wns a Republican Reicer recalls heing presen CHAPTER 48 und remembers Acosta's de: be the. prosecution, 1 the who takes whantage of th sex crimes. Disgusted with sccalls thinking hed found In Acosta, the chief saw Michael Reiter: July 2006 from confrondng a man connections. j Buti tree out that Ac «July 28, the grand jury reached a verdict that flaored Starr's high-powered multir the Palm Beach PD. | nd while Acosta had aster O The ariginal plea deal tht Krischer had offered to | clerking for futuze Supreme Epstein had been bad enough. Naw the grand jury wes vecom- only argued two cases befor mending that Lpstein be charged with just one felony count of Atthe time, Reiter id not salicitation of prostittion one hud to look much more se ‘There was no mention of undersge girks. The original accusation — our felony counts of unlawful sex acts with minots and one: felony count of lewd and lascivious molestation — had Reiter's actions did not nce simply evaporated ot in every corner of the cor Itwasnl enough to send Epsicis to prison. “1 had individuals sugges Ipstein was allowed ta surrender on # Sunday, when 10 one the investigation ad wy cel would Know hed been arraigned. A few hours Tater, be wis 8 Was mare horsepower than released on three thousand dollars bail. bad ocher individuals sugge The Palm Beach PD) was not even notified. probably fis," Reiter said in] 152 Once again, Chicf Reiter was outraged. So much so tht he took che extraordinary step of calling the 51 and the federal prosecutor's office. At the time, the federal prasecator of the Southern District of Florida was a Republican named R. Alexander Acosta. Chit Reiter recalls belug present at Acostas swearing-in ceremony CHAPTER 48 and remembers costa’ declaration that one of his goals would be the prosecution, to the fullest extent of the law, of anyone wha takes advantage of the weal — especially perpetrators of sex crimes. Disgusted with Krischer's laissez faire autitude, Reiter recalls thinking hd found his men In Acosta, che chief saw 4 prosecutor who wouldnt shy away fram confronting a man with Jeffrey Fpstein's resources and connections, a But it tured out that Acosta had worked under Ken Starr ac ry reached a verdict that floored Staer's high-powered multinational lew firm, Kirkland & Ellis And while Acosta had a sterling résume, which included a stint leal that Keischer had offered to. clerking for future Supreme Court justice Samuel Alite, be had Now the grand jury was tecom= only argued two cases before a judge. sed with just one felony count of Auth ume, Reiter did not know this. All he knew was that some- one had 10 look much more seriously neo Jeffrey Epstciis crimes of underage girls. The original sof nlaswfl sex acts with minors and lascivious molestation —had Relrer's actions did not necessarily make him a hero—at least, Bt in every corner of the: community be served teins prison. “1'had Individuals sugges! that che departueats approach to cender on a Sunday, when no af the investigation and my referral of the investigation to the FRI ened. A few hours later, he more horsepawer than the vestigation deserved. And { lars bail otier individuals suggest that—ycah, the term hack off steven notified baby fits Reiter suid in his deposition for 2.8, vs, Epstein. 152 183 Janes Parenson Fue “Thad people n the community in Palm Beach who ither made “My responsibilicy was to comments directly to te or to others who relayed them to me that Beach and preserve their con didaftneed to take the tack in the investigation that we did, which is department Fails Reiiec ash tol completly isrestigate it and then refer i to the FBI afer the particularly under the crimin state case was resolved” Reiter said in the deposition. “1 had one NN individual who came to see me couple of ime about this But along with handing ¢ According to the chief, che individual in question was & Jie Reletr dk shes prominent Palm Beach politician Ietiets—un Palm Beach PD “He said this wast necessary: this was a case that was really shotimasintie cose. very minor," Reites recalled. “The victims had lifestyles that Yio dared ie Teesh by dot make them — shouldnt make them befievable ta the police department” “I 101d him that these Kinds of suggestions to me were 8 {proper and he should stop?” said Reiter. “That he hod taken x S38 couple of steps doven the rood wivard something that could eventually constitute a crime, We talked several mes. Eacly on (8 «didnt end favorably. Yon kuow chis is an individual (whom 1 p had to interact with in my official capacity and in his official 3 capacity as well” The Palm Reach politician wasn't the only one fo pressure {le police chief. “I received comments (rom a variety of diferent viewpotnis...in some cases | had people ell me, ley, he's a Pala Beaches, why are you investigating a Palm Beacher?” Reifel auld say when deposed. “1 had people that said it was an unfa= voxable career move for we to ask the state atomey to remove himself from the case and to refer it 0 the FBL.... had plenty of people that told me that that wes a mistake. Reiter didi back off. To have done so would have been & betrayal—not only of he vizrims bu alsa of his vocation 4nd the community he had sworn he would serve. 184 rR Erms Rice yin Palm Beach who either wade “My responsibility vas to protect everyone that lies in Pal smmwhprelaged evi we hes Beach and preserve their constitutional rights and be dhe — mvestigation that we did, which is department for all,” Reiter said. "And 1 think that a then rer t. 10 the FRI afer the yaticatarly under the criminal lw, thar al people ave aid in the deposition. <1 had one the nature of one sysiem, be treated exactly pay ee ouple of times about this” But aloag with handing the case off 10 the oh lb the Bg letters —on Palm Bea ka, 4 "a AE h PD letterhead —to the parents of the The victims had lifestyles that Te delivered the letters by hand. ike them believable to the police sds of suggestions to me were sid Reiter. “That he had talena J 1 toward something that could Ve talked several times. Early on this san individual [whom] © icinl capacity and in his official yeasn the only one fo pressure uments from a variety of diffesent people tell me, leg, he's a Pals gating a Palm Boacher?” Reiter people that said it was an unfis ask the state attorney o rEMOYE fer it to the EB... had plenty of 15a mistle” ave done so would sve been ims but also of his vocation 1c would serve. 184 185 FES TOWN OF PALM BEACH | Ce] POLICE DEPARTMENT 2 8A KOMEDI (IT | ose A AS | | Jeffrey Epstein: Septem, aT ST 1 1 the winter of 2013, Sau ata rar ro G4 EBS 1 ry dare | be seutenced 10 the m " Mitoul€ lak, ing gy one char of Team Blake's crime? He sent se wine tou Beach police officer who « een boy. But in. a sense, Blake v Li cui tenced to life. The case was a LL. — —— — treatment regular Flurida foll With a minor. But nothing a y nd the ples deal he mana Paraordinary. Epstein had bought hiwse | 8ssemhbled. His connections LM BEACH ARTMENT | CHAPTER 49 [Hprraigrii] Jeffrey Epstein: September 2007 I | n the winter of 2013, Scott Blake, a forty-seven-year-old inid- yey: J school principal from Palm Beach Gardens, Florida, would ay arg sens be sentenced to the minimum mandatory sentence—ten J years in prison, with ten years of probation on top—for plead. hoo S (late, ing guilty 10 one charge of soliciting sex with a minor, aan Blake's crime? le sent sexually charged messages tn a Hoyn- son Beach police officer wha vias pretending to be » feenyear.cld in boy. But in a sense, Blake was Incky: he conld have been sen- Spires fenced to life. The case was an interesting example of the kind of ae treaument regular Florida folks could expect just for soliciting sex With a minor. Bul nothing about Jeffrey Epstein was regular — 80d the plea deal he managed 10 strike Lu 2007 wes simply Extraordinary. Epstein had bought himself une of the best defense teams ever mbled. His connections and contributions 10 Democratic 1 Juss Barensan oh causes had made him u player on that side of the political aisle. He “The parties micipate tha had a famous Republican, Bill Clinton's nemesis, Ken Stars, werk Part of any public record 1 ing the other side. And just to make sure they'd cavered the bases, United States receives a Freed Epstein’ tern also recruited Roy Black—the lawyer whoid any compulsory process comm cleared William Kennedy Smith of rape. and kept Rush Limbaugh met, it will provide notice: out of prison for his alleged illegal drug use— snd Jay Lefkowitz disclosure.” a defense attorney whod worked with US atiorney R. Slexander Remarkably, despite assur Acosta at Ken Starr's law firm. | fed, mone of the victims was. And 50 in September, the US attorney's office reached 1 for- this NPA. mal agreement with Fpsteins team; the United Stares would 1F Epstein did not sign dhe defer federal prosecution in favor of prosecution hy the state af count indictuient and a decade Florida team of lawyers had goticn him A non-prosecution agreement (NPA) was drafted; among ted ul the teeth i South Florid, ther things, i assured Epstein tha be would not be prosecuted Forall his protestations of ir in the Southern District of Florida for felony offenses involving in the world ta agree to an NPA. the sexual abuse of underage girls. (By that pon, thin known On Septewher 24, 2007, Fps victims had heeu discovered.) Instead it allowed him wo plead 3 Once again, nome of the + guilty 1a state felony alfenses for solicitation of prostitution aud notified. the procurement uf minors for prostitution, The NPA established 3 a proceduce that allowed Epstein's victiras to sue him in civil court and took the extraordinary step of ensuring that “any. potential co-conspiraars” of Epsteints would be immune from prosecution “In consideration of Epstein's agreement to plead guilty and to provide compensation in the munner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the Unlied States also agrees that i will uot institute any crimingl charges against any potential co-conspirds tors of Fstein,” the agreement stated, mentioning Sarsh Kellot and Nadia Marcinkova by name. a 189 Tosa Tuuray Riou nar side of the political aisle. He “The parties anticipate that this agreement will not be made tons nemesis, Ken Starr, work- part of any public record,” the document concludes. “If the ke sure they'd covered the bases, United States receives a Freedom of Information Act request or Roy Plack—the lawyer whod any compulsary process commanding the disclosure of the agree- 5 rape and kept Rush Limbaugh ment, it will provide notice 10 Epstein before making thu I drug use —and Jay | efkowitz, disclosure.” 2 with US attorney R. Alexander Remarkably, despite assurances theyd received from the feds, none of the victims was consulied prior to the drafting of 5 atorney's office reached a for this NEA. team: the United States would. If Epstein did not sign the grecment, he faced a fty-seven- af prosecution by the state of (count indicament and a decade o more in prison. But Epscen's teom of lawyers had gouen him a deal so sweet i could have rot ne (NPA) was drafted; among ted all the teeth in South Florida. than he vould not be prosecuted For all his protestations of innocence, there was every reason da for felony offenses involving in the world to agree to an NPA Tr ds. (By that point, thirty kuown On September 24, 2007, Epstein did sign it. Instead in allowed him to plead Once again, none of the. victins had beea consulted or Jr salicitation of prostitution and roified. srostitation. The NPA established ins victims to sue him in civil rary step of ensuring that “any ipsteints would be immune from is agreement 10 plead guilty utd the manner described above, if 1 of the terms and conditions. of ates also agrees that il wall not against any potential co-canspiis © stared, mentioning Sarah Kell « 158 - | moment that Epsicin had finally did June 30, 2008. In the interim, accord; were only told, “This case i A lwsuit chat Bradley | Fort Luaderdale, filed in J Rights dct, or CVRA (ah CHAPTER 50 winch states that “victims ing the right 10 be heard i be precluded from cont pr farly! According to him, peost | woueary recovery of any «x result of the non-prasecution agreement, a fifty-three. SIE alsa knew thacif the gover: count indictment that federal prosecutaes had prepared entered ino 2 contract tha aginst Jeffrey Epstein—one that claimed hed ubused rights af Epstetns victims, dozens of underage women— never was fled. ave been impraper in ane But as far a laveyers represeuting Epstein's viclius were co0- remedy would hve: been te cerned, the fact that those victims were not consulted about the while itis difficult to now non proscetion agreernent was inexcusable. The “goverment pom Soudepinl % deliberately kept orinue victicas ‘a the dark’ so that it could enter By wn gun into a plea arrangement designed to prevent the. victims from static of imitations on tha raising any objections.” they would sigue, in documents fled ont : on Cr Susy February 10, 2016. For nine months, the laveyess claimed, fram kg ing bo the time thar the NPA was signed, on September 24, 2001 Ee nents Chit] Krischers office, “doing Fpsteins bidding, [hud] concealed he 0 massive and so comple PAS existence from victims” and continued to do so until the everyone involved into the i 19 Envy Rica moment that Epstein had 10 plead guilty in court, which he finally did June 30, 2008, In the interim, according to their lavyers, Epstein victims were only told, “This case is currently under investigation. A lavwsoit that Bradley Edwards, a victims’ rights attorney in Fort Laudentale, fled in July of 2008 cited the Crime Victims Rights Act, or CVRA (tide 18, section 3771, of the US Code), CHAPTER 50 which sates chat "victims of federal crimes have rigs, Includ- ing the right to be heard in court, and most particuiarly, not to be proctuded from court proceedings, and the right tobe treated fairly: J According to him. prosecutors had violated the CVRA rights y of the victims, Edwards, who said he was warking pro bona, cw that this suit against the government would not allow for monetary recovery of any sort (including lawyers’ fees). But he secution agreement, a fity-three- so knew that if the government, urged by Jeffrey Epstein, had deral prosecutors had prepared entered i110 a contract that improperly or legally violated the one Wat clatmed hed abused rights of Epstein victims, then that contract, by natuee, would ever was filed have been improper in and of itself—in which casc, the only ating Epsteiis victims were cot temedy would ave heen 10 have the contract invalidated. And {ms wert not consulted about the while it is difficult © kaow what, exacdly, would happen if the 15 inexcusable. The “government contract is overturned, ane possibility is that the government “iu the dark’ so thut it could enter could prosecute Epstein for crimes against his victims, if the ned 10 preven. the victims roa statute of imizations on those crimes has not expired ould args, ia documents fled on At the time of chis writing, that case Js winding 1ts way oaths, he lawyers claimed, from through the courts. It has all the eaemarks of a modern-day signed, on September 24, 2007) Bleak House — the Charles Dickens novel about » legal case that fis bidding, [lad] concealed the 850 messive and so complex that it drags on forever nd drags and continued to da so untill ryone involved into the mire. - I Jasses Parson . #2 underage girls. (Upon inf who brought Jane Doe to In the meantime, Epstein began to settle: out of court with his. of Epstein, and will ther victims. plaint) Under Epsicin's p In February of 2008, Virginia woman who eat by the lias ostensibly to give a weal Jane Doe #2 brought a ffty-million-dollar lavisuit agains! Epstein. compensation in his Pal At the time of their meeting, she. claimed, Epstein was fifty-two would be contacted when years old. She was a teenager, aud ber complaint, which was | Palm Beach residence or made public, gave the rest of the world an early glimpse of what Epstein or someone on hi Epstein, and the inner workings of bis secret world, looked like to bring one or mure unc from a victior's perspective. 1 recruiter, upon informatic “Epstein 34a Anancier and movie manager with a sectet cl economically disadvan cntele limited exclusively to billionaires.” the lawsuit alleged. Pam Beach County who “lle is himself s man of tremendous wealth, power and inffu. being offered — generally ence. He maintains his principal home in Nev York and also session and who were p owns residences in New Mexico, St. Thomas and Palm Beach, tw auiborities or have cre FIL The allegations herein concern Epstein's conduct while at his i conduct were made. Thi lavish estate in Palin Beach” The complaint continued: Epstein’ plan. Epstein's plan reflected Upon information and belief, Epstein has a sexual preference Upon arrival at Epstein’ and absessiom for underage minor girs. Fie engaged in aplan would be iuroducedto Sar and scheme in which he gained access to primarily economé- gathered the girls persona cally disadvantaged minor ginls bn his home, sexually and teiephome umber, Ms assaulted these girls, and then gave them money. In or about up a flight of stairs fo a bx 2004-2005, June Doe, then approximately 16 years old, fel able in addition io other Into Epstein's trap and hecame ame of is victims. gruphs of nude women lin Upon information and belie, Jeffrey Fpstein carried oul bedroum. The girt would d his schemes and assaulted girls in Florida, New York, and on with Epstein, who would b is private Island, known as Licle St. James, in St. Thomas. then remove his wed and Epstein’ scheme involved the use of young girls o reer and direct the girl to remon 0 i Fuusey Rion underage girls. (Upon information and belicf, the young girt ‘ who brought Jane Doe to Epstein was herself a minor victim to settle out of court with his of Epstetn, and will therefore not be named in this Com- plait) Under Epstein's plan, wderage girls were recrudted woman who went by the alias anstensibly to give a wealthy man @ massage jor menetary dollar lawsuit against Epstein | compensasion in bis Palm Beach mansion. The recruiter i [ would be contacted when Epstein was planning to be at his 1nd her complaint, which was Pulm Beach residence un soon after he had arrived there. world an early glimpse of what Epstein or someone on his behalf would direct the recrater of his secret world, looked like to bring one or more underage girls tw thr. vesidence. The recruiter, upon information and belief, generally sought out any manager with a secret cli- 3 economically disadvantaged underaged girls from western lionatres the lawsuit alleged Palm Beach County who would be enticed by the money adous wealth, power and influ- being offered—generally $200 to $300 per “massage” al home in New York and also session—and who were percetved as less likely to complain 6, St. Thomas and Palm Beach, to authorities or have credibility if allegattons of iniproper om Epsteinis conduct while at bis condict were made. This was an important element of complaiat continued: Fystin' plan Epstein’ plan reflected a particular pattern and methad Fptein has asexual preference Upon arrival at Epsteins mansion, the underaged viii nor girs, He engaged in apl would be introduced to Sarah Kellen, Fpstein's assistant, who d access to primarily economi- ‘gathered the girl persemal information, including her name ee oo har, sell? and telephone mumber: Ms. Kellen vould then bring the gil ac up a fight of stairs 10 a bedroom: that camsained a massage or ly 16 years old, Jel table in addition 10 other furnishings. There were photo- Dp 8raphs of nude women Timing the stairway hall and in the oe Sp carried out bedroom. ‘The girl would then find herself alone in the room o_o New York, andor With Epstein, who would be wearing only a towel. He would Little $1. James, In St. Thomas then remave his towel and lie naked on the massage table, Fieuarof young gil ocr and direct dhe girl to remove her clothes. Epstein wonid hen 192 = perform one or more lewd, lascivious and. seal acs, cluding masturbation and touchizg the girls vagina Consistent ih the foregoing pla and scheme, jane Doe was recruited to give Epstein a massage for monetary com pensation. Jane was brovght io Fstein's mansion in Pulm Beach. Once at the mansion, Jane was introduced to Sarah Kellen, who led her up the light of stat to the room with the massage table. In this room, Epstein 11d Jane to ke of her clothes snd give him a massage. Jane kept her panties and fra on and. complied with Epstein, instructions. Eystein wore only a towel around his waste [scl After a short period of tin, Epstein semaved the towel and rolled over exposing is pent. Fystein began tw masturbate and. he. sexually Jeffrey Epstein: June 30, 2 assaulted Jane. fer Epstein had compli the assault, Jane was then able 0 get dressed, leave the room and so back down. the AE airs. Jane was paid $200 by Esicin. The young girl who Qs Pagans investig: recruited Jane was paid $100 by Epsein for bringing fan ta age girls, Jeffrey Eps him Coumy jai is a result f tis encoun wih Epsicin, Jone expert re dyn ale, Bg enced confusion, shame, hilton am abarrassnent, and Ne York Tunes At the rime, fas suffered severe psychological and cenofinal infurtes. i the Tine having long siuce blu Sau Jos, “respect the legal process by this.” Can bt spent years fighung 1 then the federal government, in Woul ave seen him emerge | battle Lud aged him. Mellowed t all bur housed 10 2 journalist fr 1 ; lascivious and sexual acts, «ching the girl's vagina. og plan and scheme, Jane Dox © massage fur monetary com- 0 Epstein's mansion in Pal lane was introduced to Sarah tof stairs to the room with the SE pstein told Jane 1 take off her CHAPTER 51 ge. Jane kept her panties and teins instructions. Epstefn waste fsicl. After a short period wel and rolled over exposing. masturbate. and he sexually Jeffrey Epstein: June 30, 2008 ted the assault, jane was then room and go back down the n June 30, 2008, more than three years after the start of 7 Epsiein. The young girl who eee Pagans investigation inlo his dealings with under- by Epstein or bringing Jane: © age girs, Jellrey Epstein reported to the Palm Teach County jail. er with Epsce, Jane expert- few days earlier, Dpsteis hu taken a phone call from the ation and embarrassment, and New York Times. At the time, hed Leen working, or vacationing land emotional injaris. (the line having long since blurred), at bis compound on Litde Sain Jeffs. “lL xespect the legal process.” Epstein had said. *1 will abide by this Hed spent years fighting, the charges— fighting rhe state, hen the fedcral government, in an effort to avoid a sentence chat tld Luve seen him enserge from prison an old man. But the tle bad aged him. Mellowed him, even. Months eaclier, he had but hoasted to a journalist from New York magazine. 104 195 Janias Barronson ‘Its the Icarus story, someone who flies 100 close to the sun.” hat journalist said in reference to “the agony” of Epstein’ legal “ordeal” “Did Icarus like massuges?” Epstein responded. But after Fpscein's indictment, there were no more: boasts. For the most pare, he kept silent in public and retreated into his Eyes Wide Shut world. And when the New York Times did manage to get him wo speak on the record, he spoke like chastened man Siteing on his patio dow on Little St. James, Epstein likeaed ‘Tuimself to the shipwrecked Gulliver after he washes ashore on | Lilliput. “Gulliver's playfulness had unintended consequences,” he said. On tho eve of his departure, he had a few more things 10 say: That is what happens with wealth, There are unexpected hurdens as well as benefits. “Your body can be confined, but not your mind...” “1 am not blameless..." Outside of the agreement hed signed with the prosecutors 3 office, this was the closest Epstein had come 10 admitting his guilt, But strange details were. sprinkled throughout the story. §le had formed a “board of dizectors. of friends” who would coun cel ira on his behavior. Aud, seemingly for the first time, hed bired a full-time masseur —s man. Readers of the New York Times might have wondered: Epstein was going 10 jail for eighteen months. What need would be have for a full-time masseur? 1 The storys last line hinted at the answer: in preparation. for incarceration, Epstein had sit up an e-mail alert. From then on, bis auonnatic reply would read “On vecatiot® 196 renso who lies to close to the sun,” 0 “the egony” of Epstein’ legal pstein responded. 1, there were na more haasts in public and retreated iato his P he New York Times did manage A RT V he spoke like a chastened man. {le St. James, Epstein likened 1 p liver after he washes ashore on ncarceration intended consequences” he said +e had a few mare: things 0 say: wealth. Then: are unexpected 8 butnot your mind..." +d signed with the prosecutors tein had come to admitting bis sprinkled throughout the soy ars of friends” who would coun cemingly for the first time, hell an = might have wondered: Eaten nhs, What need would he haves 2 the answer: in preparation pan cual alert reply would read "On vacation 96 CHAPTER 52 Jeffrey Epstein: June 30, 2008 he Palm Beach County Main Detention Center is on the T= side of Lake Worth Lagoon, which separates West Palm Beach frown the island of Palm Beach. Epsteins ume on FI Brille Way is five miles to the east Mary's high school is several miles (0 the west. 1ts fitting, somehow, that this jail — whic is the juil Epstein ‘ends up in, after turing himself in to the local sheriff—lies in TT — The detention center's inmales, their families, and their law. call it the Gun Club, a reference not only 1a the juils uddress, Gun Club Road, but also to its population of husders, bur . drug dealers, rapists, and murderers. There's the occa ial hooker as well. And, from time to time, Haitian refugees lodged ihere. (There are threr thousand inmates in all. Juices Parrsnson Some wait a year before waking their way ta the courthouse, their date with the public defender, and an appearance before the judge. Somme get our nch sooner, if only they can make bail. But there's no bail without money —or at least collateral —and, of course, being without moncy is often what lands people n jail in the first place. Jeffrey Epstein could have posted bail for every single inmate in the Gun Club. 3 ‘But thars just one of the ways in which Epstein is alike bis A {ellow inmates, He's on admitted pedophile now. Even bunous onc. And, famously, pedophiles tend to fare poorly in jal Luckily for Epstein, Ric Bradshaw. the sheriff in charge of local jails, transfers Epstein to the infirmary, where he sperids si 3 cvucly on nigh before being transferred seven ies up the i ert Ric Bradshaw: fun road to a much smaller, ssfer location: chr: Palm Beach County Contra Detention Center or, ss its knanwa, the Stockade. ; SE sad Yon Bra “Its not somewhere wed put a serial killer,” Ric Bradshaw says. O Killed him." a Most of the residents here are addicts who take putt in drug, Sherill Bradshaw education prograus, prostitutes, petty criminals, and drunks. Western. Tmposingly tail, iv Its a far safer place for Epstein 1o be, and, unlike other inmates mustache, and slow, souther (except, of course, those being held in solitary), hel end up with Bod 1s ae oe a his own cel, even his own wing, which be has 10 himself Bartoli the streets of Tor ss Eptcints lloeed pay for a securcy and, who sits outside he Bis bec. hres oe orn cell and keeps watch. And he's allowed any pumiber of isiors: | beer: spent as the head of wi For u convicted felon, it's an extraordinary benefits packugs: talk 10 the media, aud day, as But according to Sheri Bradshavy, who also oversees the stodke. Ehe's clearly uncomfortable, id ade, Epstein is incredulous over the weatment he Is Teceiving. But here in his Ws "elle was astonished that he had 10 go to prison at all” Bi Remick, Sadstom onc aer: shaw vermembers. EE tre rss Let just say he dida't think hie belanged there.” 7 "When be arrived here, he 20 pe (img their way to the cousthonise, nde, snd an appearance hefore somes, if only they can make bail Ley—or at least collateral —and, +1 often what lands people in juil osted bail for every sige inmate ~ CHAPTER 53 ups in which Epstein is ualike is pedophile now. Fen a famous one. tend to fare poorly in jail iradshaw, the sherill in charge of o the infirmary, where he spends Sheriff Ric By radshaw: 1 nansfered seven miles up the June 2015 Tocation: the Palm Beach County 1, as its known, the Stockade. po Job says Ric bradshaw, “was se aserial Killer? Ric Bradshass s2y5. eta LE i ave addicts who take part in drag tele herl(f Bradshaw could hav nes, iminals, and drunks: Vester ave stepped off the set of . ety cxmiasls, nd droskg i —— i in tobe, and, unlike ober mite Br vis See ath re oe gheld tm solitary), hell edna oldschool law officer —the kind you once w ee He i 4 ae nh | patrolling the streets of Tombstone, Deadwood, or Dodge p " sgn die bec vm fo yon ys, even of which av ‘s alowed amy mumber of visit spent the head ofthe couny' jis, As a rue, he Ss an extraordinary benefits pack BS fe oe. an to, 1 bo ln ont rt ig adh who ls oversees the i 5 clearly wicomfortabl, dey, and es rey Epstein, rth treatment he is reco ing: Bu bere i hits opal office ; & a bere in his wood-paneled offic on the frst lo be had to go to privow cal’ Be one i fot or of the “We have a th housand sexual pred hink he belonged there” : ors in the county? he “When be: arrived here, he was one of them, tle definitely 0 . or Janie Partenson a it the category we have 10 ensure the general population is not met a suave short haired ge: gong to take their anges out on Feeuhi aceon Although he understands that Epstein is a sex offender That would be Jean-Luc E and has a sense of the scape of his alleged crimes, Bradshaw's For the duration of Jeffze alco aware thal the actual conviction was for a “low-level felony.” the Stockade, Bramels taken Ac the request of Fpstein's attorneys. -a request that is c= Brillo Way, 3 firmed by a court order— Epstein is quickly granted “work release” What it means in practice is that six duys a week, for up to Sixteen —sixteen! — hours each day, Fpsiein is allowed to leave the Stockade 10 be driven by a designated driver in a car ear ] marked especially for him to any one of three places: his lawyer 8 Jack Goldberger's office in dowatown West Palm Beach, the Palm Beach office of a science foundation that he's established, x and his house on El Brilla Way. Despite the ankle bracelet he wears, it could be argued that as u fabulously rich prisoner with two of his own jets parked nearby, at the Palin Beach International Airport, Epstein might have posed u flight risk. ‘Instead, every day of the week save one, he's allowed (0 goto J is lawyer's, Wo go to his office, or simply to go home: 3 Did the deputy in charge of Epstein go to the house on H ] Brillo Way? Ric Bradshaw considers the question “Yes, he says, “he did” Did the deputy go inside the house? 1 “Yes, he did 1 so, the deputy right have encountered Nadia Marcinkovdy who was staying on El Briflo Way at the time. He may alse 1a wn Ups Fw Ric ure the general population is Tot met & suave short uave short-haired gentlemen who - tn gentlem ho spoke with a distinct th Epsiein fs a sex offender That would be Jean-Luc Brunel. of Lis alleged extmes, Bradshave's For the dutul 4 d i : ion of Jeffrey Epsicinis stay —ar . ction was for a “low-level felony’ bth Stockade, Brunel taken, dn oy iy —or half stay-—in worneys—a request that is con- Brill Way. een te iotspon petein is quickly granced “wark 1s thac six days a week, for wp to ch day, Epstein is allowed to leave. 8 a designated driver in a cas ears any one of thre places: his lawyer lowntowa West Palm Beach, the foundation that he's established, 1 he wears, it could be argued that S with two of his own jets parked ccnational Airport, Epstein wight week save one, hes allowed to £010 e, or sitaply 10 go howe. ¢ of Epstein go to the house 08 he question. the house? ave encountered Nadia Marci > Way a the time. He: may also oe ns Ki fraudster named Arnold Pr had been commuted hy Bil left offic. Sheriff Bradshaw wants conjugal. But even US auorney car CHAPTER 54 agreement with the govern ment was highly irregular “Epstein appeacs to hve while in jail," Acosta would eral public. “Although the te Jeffrey Epstein: june 30, 2008-July 21, 2009 ex oa while in state custody nndermy i Aud, of course, Epsieins Am to Sheriff Ric Bradshaw, the treatment Jelfrey. a] by taxpayers. Epstein received in the Stockade was not preferential By some measures, he Ist wrong 1 2010, millionaire polo mogul John Goodman killed & young, man while driving drunk. He was convicted but wis owed to spend to years under house arrest while his appeal was being tried. Like Epsiein, Goodman was allowed visitors, Bue Goodmans sisitor ist was nothing fike Jeffrey Epstein. ‘Nadia Marcinkova s said to have visited Epstein in jail morc than seventy times. Epsteins assistant Sarah Kellen also visited Epstein 13 the Stockade. ‘A Russian mixed martial artist named 1gor “Houdia” 7 view was another visitor, as was a dishurted lawyer and fois Eo Carn Run fraudster named Arnold Prosper’, whose own prison sentence had been commuted hy Bill Clition on the day before Clinton eft office. Sheriff Bradshaw wants wo be clear: none of these visits was conjugal. Buteven US attorney Acasta, who negotiated Epstein’ nmusual r— with the government, would say tha Lpstei's arrunge- ‘R54 agreement wi CHAPTER | ment was highly irregular, “Epstein appears 1 have received highly unusual treatment wehile in jail.” Acosta would say in a letter addressed to the gen- eral public. “Although the terms of confinement in a saae prison sre matter appropriately left to the state of Florida and not fed- 1008-July 21, 2009 eral authorities, without doubi, the treatment that he received h while in state custody undermined the purpose of a juil sentence And, of course, Epsteins stay at the Stockade was subsidized ¢ Bradshaw, the treatment Jeffrey. by taxpayers. + Stockade was not preferential. By ‘wrong, © mogul John Goodmun killed a3 trunk, He was convicted but was ander house arrest while his agpe vas allowed visitors. But Good effey Epstein. 110 have visited Epstein in jail me 1 Kellen also visited Epstein i lL astist named Igor *Houdiol™ was a disbarred lawyer and fi 204 5 5B school females 10 provic massages. Palice sought resuled in a term of im reports, however, in 2001 | 0 concerns regrding th i © charge Epstein only. assault with no intent 1c RSS on CHAPTE would have resulied fn 1 register as a sexual affer 3 underage victims. Local police were di A ney’s conclusions, and re. R. Alexander Acosta’s letier to the general public, q Federal authorities recei / lor § engaged im additional ve | March 20, 201 the quality of the evidenci at trial. With a federal c: “To whom it may concert. considerations. First, a y requires tha the crime be Lserved as U1. §. Attorney for the Southern District of Florida an interstate nexus, Secor om 200% thzongh 2009, er the past weeks, hav: red charged by the state, the fe ey ate ae wwe oh ext, 10 backstop stale & me appears disci. | thaught it ppropeite to provide is no miscarriage of justice some background, with Lwo caveats: §) under Justice Depart erally that which has alre = cuss privileged internal com= level ment guidlines, 1 cannot discuss privileged in numications amos departnent attorneys and (i) 1 no longed Alter considering the y have access o the original documents, and as the mater s additions! considerations, vay 4 eae the prison af memory edd the state charge was insu oe I mater was origmally presented 10 the the prosccuars and age palm Beach County State Attorney. Palm Beach Police Mr. Epsteinis aniorney, Roy Aleged that Fpstem unlawfully hired underage bigh= best Known for bis suc 206 Fire Raw schol females 0 provide him sexually lew and erotic wassages. Police sought felony charges that would have resulted un 4 term of imprisonment, According in press repores, however, in 2006 the State Attorney, in pact due tw concerns regarding the: quality of the evidence, agreed to charge Epstein only with one eonnt of aggravated Y assault with 10 intent to commit a felony. That charge CHAPTER 55 would have resulted to no jail time, no requirement to register as a sexual offender and no restitution for the 3 underage victims 3 Local police were dissatisfied with the State Atcor- 3 ney's conclusions, and requested a federal investigation. er to the general public, i Federal authorities received the State's evidence and engaged in additional investigation. Prosecutors weighed the quality of the evidence and the likelihood for success at trial. With a federal case, there were two additional considerations. First, a federal criminal prosecution requires that the erie be more than local; it must have the Southern District of Florida an fulecstate nexis, Second, as the matter was initially Over the pust weeks, T have read charged by the state, the federal responsibility is, 10 some + Epstein. Some appears tue, extent. to backstop state authorities to ensure that there havght it appropriate t provide is ao miscarriage of justice, and not to also prosecute fed caveats: © vader Juste Dept exslly that which has already been charged at the sia discuss privileged internal com vel. mentarorneys aud 6) InoTongee After considering the quality of the evidence and the nme, aod a the mane additional considerations, prosecutars concluded that precision of memory is reduczdh the state charge was insuliicient. In early sue 2007, wn originally presented ta thel the prosecutors and agents i this case met with Le Attorney. Pal Beach fol Mr. Epsiein’s auorney, Roy Black. Me. Black is perhaps Oawlully hired underige Hi best know for his successful defense of William - wr Jans Parreason Eu Kenedy Smith. ‘The prosecuians presenied Epsiein a well-known legal expert choice: plead 10 mare serious state felony charges (that Pa would result in 2 years imprisonment, registration is good man to serve time sexual offender, and restitution for the victiuas) or else hou if we continued 1c prepa fora federal felony trial office systematically cow What followed was u year-long assault on the prose ment, and when we di cation and the prosecutors. L use the word assault laten- appealed to Washingion tionally, us the defense in this case was more aggressive 7 The defense strategy han any which 1, or the prosecutors in my office, bad Defense counsel investiga previously encountered. Mr. Epstein hired an sey of his fun, Joukigfin egal superstars: Harvard Professor Alan Dershowitz, for- provide a basis for disqua mer Judge and thet Pepperdine Laxe Dean Kenneth St, ecutor is an effective 4h former Deputy Assistant 10 the President and then Kirk 8 eliminating the individua {and & Ellis Partner ay Lefkowitz, and several athers, and thus most qualified to meluding prosecutors who had formecly worked in the 8 tihood for success, Delens. 115. Attorney's Office and in the Child Exploitation and least two prosecutors. | Obscenity Section of the Justice Department. Delense rejected, these arzuments, attomeys next requested u meting with me to challenge Despite the army of aut he prosecution aud the terms previously presenied by the terms first presented the prosecutors in their meeting with Mz. Black. The meeting On June 30, 2008 prosecution team and | wet with defense counsel in Fall appeal 10 Washingion DC 2007, and | reaffirmed the office's positian: twa years, guilty in state court, He wi registration and restitution, or trial. oument, register us a sexu Over the next several months, the defease team pre- restitution to the victims, sented argument after argument claiming that felony Some may feel that the | criminal proceedings against Fpstein were unsupported tougher. Tyidence that bas ty the evidence and lacked a basis in Jaw, and that the encourage that view. Mony offices insistence on jail-time vias motivated by a zeal 12 ou, ling detailed stacemen aveccharge a man merely berause he 1s wealthy. They ages. Physical evidence ha bolstered their arguments with legal opinions froct these additional statements 28 2 sressson Euwtwy Rica ecutors presented Epstein a wellknown legal experts. One member of the defense us state felony charges (that team warned me thai rhe offices excess zeal in forcing a prisonment, registration us a good aman 10 serve time in jail might be the subject of a ation for the victims) vr else book if we continmied to proceed with the matter, My ar office systematically considered and rejected each argu- carlong assault on the prose- ment, and when we did, my offices decisions were 1 se the word assault inten- appealed to Washington. As to the warning, T ignored it {his case as more aggeessive The defense strategy was tot limited to legal issues. prosecutors in my office, had. Defense counsel investigated individual prosecutors and 1. Epstein hired an army of their families, looking for persona! peccadilloes that may ‘rofessor Alan Dershowitz, for- : provide a basis for disqualification. Disqualifying a pros- dine 1a Dean Kenneth Start, ecutor is an effective (though rarely used) strategy, as + the President snd then Kirk: eliminacing the individuals most familiar with the facts fkowitz, and several others, snd thus most qualified (0 tale a case 1 rial harms like- o bad formerly worked in the lihood for success. Defense counsel tied to disqualify ac in the Child Exploitation and least ro prosecutors. | carefully reviewed, and then Justice Department. Defense rejected, these arguments mecttag with me © challenge Despice the army of attorneys, the office held frm to terms previously presented by the terms first presented to Mr. Black in the ariginal meeting with Me. Black. The meeting, On June 30, 2008, after yer another last inure (et with defense counsel in Fall appeal to Washington D.C. was rejected, Fpseein pled he office's position: to years guilty in state court. He was 10 serve 18 months impris- I onment, register as a sexual offender for life, and provide: ‘months, the defense feaun pro restinution 10 the victims rgument claiming that felosy Souic may feel that the prosecution should have been inst Epsicin were unsupported tougher. Evidence that has come to light since 2007 may ed a basis in Taw, and that (he ercoursge that view. Many victims have since spoken time was motivated by 4 zeal 10 our, filing derailed statements in civil cases secking dam- ly because he is wealthy. Ther ei. Physical evidence has since hoen discovered. lad we with legal optaious h these additional statements and evidence been known, pon 20 Jamas Parvenson r the puicome ay have been differeat. But they were net At times, some prosecut Tenown to us ac the time. trial, and at times fel 1 4 prosecution decision must be bused on admissible right in the first meetin facts known ut the time. In cases of this type, those are spective of defense tact unusually difficult because victims are frightened and tiomal vight 10 a defense often decline to testify or if they do speak, they give con- clght should not be pun Leadiciory statements. Our judgment in this case, based sels exercise of thelr ry on the evidence known ai the time, was that it was better Washington D.C. Prosecy 1a have a billionaire serve tire in jail, register as a sex frustration and anger wi offender, and pay his victims testitucion than risk # trial 1 their judgment with a reduced likelihood of success. T supported thu After the plea, | reca judgment then, und based on the sta law 3s i then stood Ome was from the FBI Spi and the evidence knows at the time, would support that 8 to offer congratulations judgment again being reguding chs ¢ Fpsicin's treatment, while in siate custody, likewise of the defense, and he cal may encourage the view that the office should have been holding fir against che | Loughe. Although thi terms of confinement in a sate 5 itz, Lefkowitz and Starr prison ate & matter appropriately lef to the Stae of Flor- 3 received calls or commun da, and nor federal authorities, without doubt, the reat itz, Lefkowitz and Starr. | ment that he received while in state custody undermined als previously, from my the purpase of a jai) sentence Kirkland & Ellis in the m Sows may also believe. that the prosecution should peace. [agreed io talk any have been tougher in retaliation far the defense’s tactics Fpsteta pled guilty, us 11} The defense, arguably, often failed to negotiate in good tors battle defense attorne; faith, They would obtain concessions as part of a negotis= have ted, vet 1 confess tk tion aud agree to proceed, only to change their winds fully inchs case and appeal the office's pusition to Washington. The tues “The bottom line i thix iigatians into the family lives of individual proseculors served time in jail and 5 were, in my opinion, uncalled for, us were the accustious He has been required to pay of bias and/or misconduct against individual prosecutors restitution clearly cannot ¢ 2 pe — Irv Rs different. But they were not At times, some prosecutors fe thar we should just go to terial, and at tes T felt that frustestion myself, Wat was must be based an admissible | ight in the first meeting, however, remuinrd right irte- 1 cases of this type, those ure spective of defense tactics. Individuals have constin & victims are frightened and tional right 10 a defense. The uygressive exercise of that they do speak, they give con right should not be punished, nor should 4 defense coun Judgment in this case, based sells exercise of their right to appeal a US Attorney to he time, was that it was better ‘Washington D.C. Prosecutors must be careful not 0 allow time in jail, register as 4 Sex frustration and anger with defense counsel 10 influence ms restation than risk atrial 8 their judgment 1 of success. 1 supparted that A After the plea, 1 recall receiving several phone calls, on the state Jaw as it then stood One was from the FBI Special Agent In Charge. He called the time, Lwould support fat 10 offer congrarmlations. He had been at many of the meerings regardig this case, He was aware of the tactics hile in state custody, likewise of the defense, and he called w praise our prosecutors for iat the office should have been holding fia aginst the lilkes of Messrs. Black, Dershow rms of confinement in & state itz, Lefkowitz and Starr. Tt was a proud moment. | also priately left to the State of Flo received calls or communications from Messrs. Dersliow- ities, without doub, the treat: J itz, Lefkowitz and Starr. 1 had known all three individ le in state custody undermined als previously, from my time in law school and at = Kirkland & Ells in the mid 90. They all sought to make se that the prosecution should peace. agreed to tall and meet with each of them after ation for the defenscs tactics, pstein pled guiky, as 1 think it important tha prosecu fren failed to negosiate in good J tors bactle defense attorneys in a case and then woven. | concssions as part of a negotis have tried, yet | confess that this has been difficult to do 4, ouly to change their minds, Filly tn this case ition to Washingion, The inves= “The bottom ine is this: Mr. Jellrey Epsicin, a billiosair, ives of individual prosecniofs Serv time in jail and is now a registered sexual offender atled for, as were the accusations Fle has been required to pay bis victims restitution, though «against individual prosecia jFestitution clearly cannot compensate for the crime. And By a re know sasch more today about his erimes because vie | tims have come forward 10 speak out. Some may disagree with prosecutorial judgmeats made in this case, bot those individuals are not the ones who at the time reviewed the evidence available for trial and assessed the likelihood of success, Respectiully, R. Alexander Acosta Former US. Atorney Souther District of Florida 202 rabout his crimes because vic- speak out. Some may disagree \eats made in this case, but the ones who aL the time {lable for trial and assessed the | PART VI Respectfully, R. Alexander Acosta farmer US. Anoruey Aftermath Southern District of Florida m CHAPTER §6 Jeffrey Epstein: July 2009 effrey Epstein walks oun of the Stackade on July 21, 2009, having served less than thirteen months of his eighteen month seutence. One of the concessions his lawyers have gotten while working out his plea deal guarantees is that che media uot be alerted to the time and day of his departure. But from now: on, Epstein, who is fifty-six, will cary the mack of a level 3 sex offsnder—level 1 being the lowest, and level 3 indicating the highest possible risk of a future criminal tof a sexual suture. Wherever he goes, he will be forced to reg- ister oc such, Every ninety days, Cpstcin will have to check in with the horitics. Every year, the New York City Police Department falc his mug shor. And for a full year, Epstein will be under St arrest in Palm Beach. | This last probibicion doesn't stop hi from fyiug, with court ars approval, on his own planes to New York and to Little Saint Jes where the locals have taken to referring to Epsteinis 727 us the Lolita Fxpress, There are other restrictions, of course, that Epstein is sup posed to abide by. He hus 10 provide the state of Florida with a list of all the motor vehicles, boats, and airplanes he owns. The full lst includes two Escalades, six Suburban, two Ford F-150s, two Harley-Davidsons, a Land Rover, a Hummer H2, 8 thirty fourfoo: TVC boat, and a thirty-five foot Duiei powerboat Three of his five planes tum out 10 be registered to a com. J pany called Air Ghisluise, Inc As a registered sex offender, Epstein is legally obliged in 8 undergo peyehiutric treatment, This 1s a restriction hel get Alfredo Rodriguez: Aug around hy having his own psychologist submit a report to law enforcement officers. Epstein is also prohibited from accessing pornography on 3 pstetns howseman, &1 ie Intecuiet and using social metworking for sexual purposes. Er SO For Jeffrey Epstein, there will be no Bangbros, ‘Tinder, oc PI Swingles com misid, Lupita, who had com ‘There wll be lawsuits up after Epsiein's “massage: Six weeks before probation cads, he setiles with seven women Jie, had cried as she. describe who sue him in civi) cours. But Epstein can easlly afford the set Rodriguez was fired by 1 Uement payments. He went be going back to jai, and in regard afer seeing a steunge car — to further prosecution for any criminal accions, bis troubles are Si rete, foes behind hire. massenses: Nat everyone whe's spent time in bis company will be 50 Ou his way out of the he lucky. of Epstein's pupers, which he By Chic Reiter's investigator For years, Rodriguez tries [Tanager No one wanted 1 28 New York and to Little Saint Jeff's, referring to Epsicin's 727 as the 5, of course, that Epstein is sup- rovide the state of Florida with a oats, and airplanes he owns. The six Suburbans, to Ford F-L50s, oo i Rover, 2 Hummer H2, a thirty- CHAPTER 57 fvesfoot Donzi powerboat en out to he registered 10 a come for, Epstein is legally obliged to This is # restriction hell get 8 Alfredo Rodriguez: August 2009 sehalopist submit a report 16 law From accessing, pornography on EF houseman, Alfredo Rodriguez, also ends up with a etworking for sexual purposes. risen sentence. will be no Banghros, Tinder, or ] na sworn statement, Rodriguez talks about Epstin's maid, Lupita, who had complained to him about having to ciean Up afer Epstein's “massages” Lupita, who was u devout Catho- ends, he settles with seven womens lic, had cried as she described the stained towel and sex toys, t Epstein can easily afford the se Rodriguez was fired by Epsicin, he says, when he called 911 e going back to jail, and in rg site seeing 2 suangs car —a "beater" —in Epstein driveway. criminal actions, his troubles 45 it turn out, th car had belonged 1 one of Epsterns masseuses, hme in his company will be On bis way out af the house on El Brill Way, he took some Epstciuts papers, which he failed to produce when questioned : Chief Reiter's investigators, For years, Rudiriguez tried and failed to find work as house No ene wanted to hire someone whod worked for 215 w Justus Parresox on Jefivey Epstein. Finally, desperately, he tried to sell the informa. a tion hed stole The. papers named underage girls and the places where BS es on Geto Fpstein bad taken them, The list included locations in Califor who imsistsh once moe on by wi, Paris, New Mexico, New York, and Michigan. The papers lawyer told him that an associ also included the names, addresses, and phone numbers of J What the Liver knew anc famous individuals — Henry Kissinger, Mick Jagger, Dustin Hof: 8 the associate in question was ‘man, Ralph Tiennes, David Koch, Ted Kennedy, Donald Trump, b the FBL A few days later, on 1 Bill Richardson, Bill Clinton, and former lsraclt prime minister J guez and sets wp a meeting, wl Ehud Barak among then ; using the meeting, Roc This was intriguing, if not at all damning, Epstein made a | book und several sheets of logs habit of collecting such information for future use. But informa: ten notes." Special Agent Pryn tion pertaining to the girls wanld have bolstered the state's case. continues: against Jeffrey Epstein, and by withholding it fom the Pali Beach PD and the FBI, Rodriguez had commiteed a crime Rodrigues explained tate Tn bis defense, Rodriguez would say thi the papers were an his former employer's resid “insurance policy” Without them, be believed, Epsicin would 200410 2005 and thet the bo huve made him “disappear” working for his former emg That now: Rodriguez needed the money. And so a few weeks detail the information within after Epsteinis release from the Stockade, he approached a lawyer | antinformation othe LCE. | who was representing, some of Epsteins masseuses. He had the he ad previously led ta he. holy grail," he insisted. A “golden nugget” The: names of hun: about the $50,000, took pusse dreds of girls, he said, who had been abused by Epstein. ening The lawyer told Rodriguez in no uncercain terms that he was LEER, obliged to turn whatever he had over to the authorities, BY Proceedings, Tile 16, U.S. Co demanding money for the information, Rodriguez was cominits tioned, Afier Mivunda warning ting another crite. Radrignez waived his rights a According to a sworn statement by Christina Pryor, a special those rights, Rodrigue admit agent with the TBI, Rodriguez "persisted that hi: would only and baok in his possession an aver the infociuation in his possession in xchange for $50,000 A — 21s n nrrcuson Fru Rica ately, he tried ta sell the informa I rage girls and the places where Two months lates, on October 28, the lawyer called Kodriguez, list included locations tn Califor- who insisted once more on being paid for he information. The York, wad Michigan. The papers | lassyer old him that an associate would be fn touch. dresses, and phone numbers of What the lawyer knew and Rodrigues did not kno was that ‘issiuger, Mick Jagger, Dustin Hoff the associate in question was an undercover employee (UCE) of ach, Ted Kennedy, Donald Trump, the FBI. A few days later, on November 2, the UCE calls Rodri- and former Israeli prime minister sez and sets up a meeting, which takes place the following day: During the meeting, Rodrigiez produced a stall hound J at all damuing. Epstein made a ‘book anid several sheets of legal pad paper containing handvril- ‘ation for future use. But informa: ten notes,” Special Agent Pryor would say in her statement. She ould have bolstered the states case continues: by withholding it from the Palm Juez bad committed a crime. Rodriguez explained that he had tahen the bound boak fram ould say that the papers were an. his former employer's residence while employed here in them, be helieved, Epstein sould 2004 (0.2005 and that the book had been created by persons working for his former employer. Rodriguez discussed in ed the money. And 50 a few weeks detail the infor ration within the book and identified import- 1e Stockade, he approached « Lawyss ant information to the UCE. In addition, Rodriguez admitted of Fmieis masscuses. He had he had previously ied to the FBI Rodrigues uskud the UCE golden mugger” The nawes off abou the $30,000, took pussession. of the money, and began ad been abused by Epstein counting it in no acertain terms thal he Rodrigue was then detained for Obstruction of Official le had over to the authorities Proceedings, Title 18, US. Code, Section 151200), and ques- Wormation, Rodriguez was cou lined. After Misunda warnings were administered by agers, 3 Rodrigue waived his rights and signed a written wabser of ement by Christina Pryor, 4 those rights. Rodriguez admitted that he had the docments 12 “persisted that he would aah @id book in his possession and had never turned them over ceseashonin exchange fof 5 local law enforcement or the FBI. In addition, Rodriguez 2a 210 Juices Bar zRson advised he ad witnessed nude girls whom he believed were underage af the pool area of his former empluyer’s ome, Jr chat his Jormer employer was engaging in sexual con- Lact with underage girls, and had viewed pornographic {mages of underage wirls on computers in kis employer's home. Rodriguez was then released from custody for further investigation The items that Rodrigues had attempted to sel to the CE for $30,000.00 were resie wed by an agent familiar with 1 the underlying criminal investigation. As Rodriguez had described, the Items contained information material to the underlying imestigation thal would have been extremely use- 3 Jul in investigating) and prosecuting (he case, including the Prince Andrew: 2011 ‘names and contact information of material wimessrs and additional victims. Had those. items been produced in respunse o the Uiquiries of the state law enforcement officers stne AIF di fits on the FDI Special Agents, their contents would hav been Pre preseated tothe federal grand jury. Thr melee Ghislaine Maxwell introduced Following his release, Alfredo Rodriguez was arrested ugsin: time in the 1990s. In 2000, Eps He appeared in court on Jane 18, 2010. facing charges of cor Castle 10 celebrace the queens t cuptly concealing records and documents. Dressed in a Ble flew to Sandringham, the qurer Jumpsuit and shackles, he apologized for his crimes and asked Betty Piri Ader theca the court to be merciful The prince had also visited He received a sentence of cighteen months. Palm Beach as well as in New It sas the same. punishment that Jeffrey Epstein bad goterd us aden ber ZS lis for bis crimes. But unlike Epstcin, alfredo Rodrigue served his asked her ta give the prince wi Gime: iu a federal prison and did not ask for. ar receive, peri back with the details. sion to go on work release. According to the Guardian, ied togecher at Windsor Castle, 20 % Lew fs ALLRED, MAROKO & GOLDBERG anes corpses 6300 WILSHIRE 30ULEVARD pistol sue “sou or comes. vid LOS ANGELES, CALIFORNIA 53045 EE pie vo I Jism viv ama aw. com Cans cach es pumas June 19,2019 YTA FEDERAL EXPRESS & EMAIL Mr. Scott Link Link & Rockenbach, PA 1555 Belm Beach Lakes Blvd, Suite 930 Went Palin Reach, T1. 33401 I we: [I Dear ir. Link, We represeat IN vith rcforcuce to bor claims against Joffrey Epstein for childhood sexual sbuse which occurred in New York City when she was vars old. New York recendy passed the Child Vietims Act which creates u 1 year sind for claims where the statute of limitacions had expirod. ‘Lhercfore, INN vill be able to suc Mr. Epstein for the sexual abuse which sho experienced while sh vas a minor. I = hc perect victim She vias born in MER 2 town on the JN const. hen NN os four vears old, I descended into civil war, Af the age of six, her entire village was cvacuated. She fled hr hometown travelling through war zones on fool with her family, in stream of refuges. Her Family seuled in the outskics of SEL As cefucees, with a0 money. hee family lived wgether ir: one room, sharing a bathroom with other families. Her pasents evenmally found low paying, unskilled jobs. Their only clothing was what was provided to them by the Red Cross. When she wus ten years old, INN cnt arrived io IER By the sixth grade, IN was 5°10, beautiful and naturally slim. She desperately NL YORK GHFCES 305 BROATMAY. SUTC 07 . NW YORK, NCW YORK 19007 Ta 202 20601 FAX 212) 202 2967 Soott Link ume 19,2019 Page wanted 10 leave [JI Soe learned about a taker scarch for models and persuaded hor mathe Lo take her. She was a huge sucsess and begun modeling at age fourteen. Though her parents disparaged hor for marketing her uppenrance. they allowed her to wrk because she eamod more thu their combined incoroe: ‘Atage sixtcon, ISS moved to Ne York City to model. She lived in an apartment for models, with on or two rouramates and no adult on the premises. ler father was deeply ashamed of her because he disappraved of her profession and her patents distanced chemscles I ics voi hectic wilh profissionl weignments. She worked with op tier clients and for DNA Modeling Agency, a well-knawn gency representing supermodels such as Linda Evengelista and Natalia Vodianova. I vss very nisosnt and incaperioncid prior to meting Mr. Bpstein. ALoge sivtees, I cxpericnocd her first hiss, The director af perfume campaign, Fabian: Barron, wantsd 8 kiss af the end of the commercial a a ale 1 a peefome 3d. She dreaded her patents’ reaction fo seeing the cammercial. She was raised in the Orthodox Chistian Church where abstinence was encouraged. NY io Joffe pois shen wis sistas yess old. ‘She was intro through a fellow model n ew yeurs her senior Mir. Fipstein seemed bigger than life. Lie did not drink or do drugs, which pur her at case. He was friend with former Presiden Bill Clinton, the President who mae is possible for HEN I rc cr fil 10 romigeste to America. When she told biz. Epstein how her family cams to America, Mr. Fpsiein said he would personally thank “Bill” for hee. Mr. Lpstein touted other impressive connections. He mide it knoe that he had A list celebrities on speed-dial. She felt very fortunate to bavi mide the connection vith Mr. Fpnigie. As I: stron zeman from he family increased, Mr. Fpslein's role in hor lle hevame more and more important. Hs encouraged ber and built ber confidemse. She trusted him completely. Mr. Fpiein told [NEE zt ic was on the board of dirctors at Harvard University. He promised that once she took her S13 and obtained the scores she needed, he would write letter of recomunendation for her, which he said would carry significant weight with regard her sdmissian. Her dean was (0 establish hecself as 2 successful model and to onc day graduate from Harvard. Mr. Tpsiein made her feel that everything she wanted was possible. Soult Tink June 19,2019 Page IN ic vo bin that she hi never even bud a buy rind. Te told hee everything would [all into place, “just keep doing whl you are doing, work hard und stay focused™ She told Me. Epstein that she preferred to abstain from sex until she was married. The first tire IES sod her for masse sas 1 help wich an che in is shoulder. [IEE ought it was an innocent request. Tle said his masseuse had failed to eet kink ou of is shoulder. He gnve her a large pusple massager for hee to use to take the knot «aut of his back. Vir. Epstein told her she wus un excellent masseuse and she was pleased to be able to ease his pai. ‘When tho massage ended, Mi. Tpstein pulled two buadred dollars from his wallet avd handed it to her. He vaid, “Twas going to give ic 10 the masseuse anysway. 50 you take cand pay Sor your ear service ur something.” Vir. pein began calling hor every dav, no matter where she vas in the world. He told her be Joved her. Tle hecame a vital part of Hi us her parents remained distant, He invited ber 1 stay at one of his apariments close to him on the Upper Fust Side. er ardiuovs work schedule, startiog. with 6:00 2.m. call times and shows running Jae into the night were exhausting, Fstein’s daily check-up calls and pep talks gave her strength Io survive her grinding schedule. ‘When in Paris, Mr. Epstein allowed her lo stay ut hix home with her sister and arranged for u night out at a concert with Naomi Campbell. 1 uppearcd to [thar Mr. Epstein’s thoughts were focused on her career, future und good fortune. “The fis! time the purple massage tool found its way betwen her logs, I'd hin fo stop, but Mr. Tipstein pushed the head of tho massager firmly against her xd forces! her Togs apart. She felc ashamed and embarrassed. The mssages became a ritual an were always wecompanied with sexual abuse and a two-hundred dallur payment ul the end. Mr. Epstein approached her as i he was Jer mentor and teacher, teaching her about Sexuality, opening her eyes. She experienced immense orgasts, and then shame and far. She Slt claustrophobia es she stared up into Mr. Epstein’s church-like ceiling of the massage perlor while he fondled her. She fit she couldn't escape her position, und thal this was the way it had 10 be bevuie this powerful man orchestrated it. Al the end of cach massuge he would muke ‘himael ejaculate by demanding she pay vigorous aitentian tw his nipples with her fingers and he wauld tell her what a good girl she was, that he loved her and would call her later, which made everything seem batter. Thon he sould open his wallet filled with hundred dolla bills and give her a couple, which she acocpted as pockel maney, never thinking twice about it. Scott Link June 19,2019 Page 4 I vt this is what it must fc] like Lo become a woman. She was both thriiled and ashamed, She followed the path that Mr, Epstein set out for her because be said if she trusted him and did what he told her to do, everything would go cording to his plan and her career would soar. Without him the world was a scary and unpredictable place. When she was ‘with him, she felt like everylhing was right because of how much love and care she received fram him. She started to think und believe Urat they would be together und thal he would marry her. Fle used the purple massage vibrulor on her tine and time again. She closed her eyes focling Jost, overwhelmed and out of contral. When be stuck his penis in her mouth, she did whar she was told. She choked and gaggod and when she tried to move her head away he forced it back into place. Mr. Epstein was extremely aggressive. When it was ovr he fold her how amazing she was. She continued to belive in My. Fpsiein’s (tiendship and guidance. Mr. Epsiuin tak hee virginity. This was lhe trjectory for which he groomed ber. Ill IN firs sca! expecieace was devoid of tenderness or ullection. She was stripped dova ‘and made to shower. Mr. Epstein told her, “IF you're Jying about heing a virgin, or 1 gat a disease from you, I'l Kill you.” She felt hor mind scpurale fram her hady during interconrse. She begin to feel like a shell of her former SCIf, She sus mortified and in agony. She felt she had bocome everything her parents feared she would hesome. She was appearing in beauty magazines and making hundreds of thousands of dollars, but Jell dirty and worthless, Mr. Epstein made her feel like nothing more than a teenage prostitute. Tiverything came crashing down once she realived tht this wes not love. I iv. Epsteics residence for fhe Jest time feeling less than human. On bier way out, she passed a young gitl who appeared to be another young model. As IN turned around W glance back, she saw the young woman entering Me. Epstein’s residence. She vias disgusted with the realization that she was one of many called t “massage” Epstein. J + a nervous breakdown while alane in New York. She found herself crying incomsolubly., shaking, hyperventilating and unable wn go lo her castings and mierings. She was suicidal. She feared confiding i her agents and reaching out for belp from them because sho was so ashamed. She booked a ticket to go home. She flew back lo Kanwas where her parents wero living. She never returned to New York. I costed with the realization of wht she was Ture into and how she Seat Link June 19,2019 Pages ad bos victimized, 1 sbatered hor to her core. At the vulnecable age of 16. Mr, Fpsicin made himself the center ol her existence and the master of her world. She realized she was» disposable pawn in bis game. She could pot Ink uhout her years with Mr. Epstein because she was consumed with shame. AC 16 years old. he isolated fe and made himself her only emotional support system. |ler mental torment and pein turaed into depression. She vas prescribed medication. She nunbed herself and tried not deal with what had happen. She tried to block the pun. I -brvassed that slic hid been used and abused. She withdrew and had 0 desire Io medel ar interact with anyone in the modeling world anymore, IESE Slupped taking calls from modeling agencies. and eventually they stopped walling for good. She was afraid to 20 fo News York where her cmotians and memories would be triggered. The final contact between IN and Mr. Epstein was shen he tracked hee parent's house phone number in Kansas and tried ta speak 10 her. |S othe grabbed the phone and tld Ms. Epstein sh was calling te police before hanglag up on kim. ler career dwindled to nofhing, Taking a break from the modeling industry when clients ike lalian Voguc and Victarin’s Secret were requesting bookings comiluted career suicide. in Kansas she hecame chronically depressed. She was suicidal before hor 18" birthday. She called the suicide hosline many times from her hae. While in Kunwas, a friend repro ee wilh news that Mr, Epstein had boon arrested. for trafficking underaged girls. feluas if she had gone from cisig a supermode) ia hearing an unsuspscting prostiute. Her purents’ warnings of what svould boom of her in New York had come to fruition. She fel prey to a child predacor, Vi. Epstein, and it took her 3 devade to understand the gravity of what Tpstein had done to her as a vulnerable young girl. Me. Upstel masgucraded ws a loving mentor, a parental substitute snd friend wha had ting nS bc. test m ind. Tbe repercussions of te ses und menial ‘os SRI ured rata with her Te ist sovual encounters aro forever seared by ‘memotica of Mr. | pstein forciug his purple massage device betvvean her logs amidst her cris for him to stop. Dehililating nausea and stomach pain followed her separation from him. She hued 10 framework with which to refecence what a “normal” sexual experience was. She remains plagued with scl doubt nd insecurity and finds it nearly impassible to separate memories of Mi. Epstcin's mumipalation and abuse from ney: relaunships she cies to develop. Scott Link June 19, 2019 Page6 Ihe sexual abuse Mr. Fpstei inflicted upon ISN <5 rrcparabl psvchologicsl scars, Sho hes struggled and canines to siigale with ht ability to maintain healthy relationships with men and in general. Her carccr is permanently compromised und the Iikelihaad of recovering severed professional fics is non-existent. Please contact us within ten duys of this letrer 10 advise whether Mr. Epstein is amenable ro attempting to resolv + civit claims without litigation. Very tmily yous, ALLRED, MAROKO & COLDRERG ORIA ALLRFD TN THT CIRCUIT COURT OF TIT 15711 JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No... 2009 CA 40BIOXXXXMBAG JEFFREY EPSTEIN, Plain, ws SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants . STATEMENT OF UNDISPUTED FACTS Defendant Bradley J. Edwards, Esq. offers the following specific frets us the undisputed nti fils in (his case. Fach of the following facts is numbered separately and individually to facilitate bpstein’s required compliance with Fla. R. Civ. P. L510(c) (“The adverse purly shali ently... any summary julgoens evidence on which the adverse party relies”). All referenced exbibits and ascents heve previously been fil with the Court and provided lo Fpstoin. ‘Sexval Abuse of Cildren By Evstein 1. Defeméemt Epsicin hus & sexual preference for young children, Deposilion of Jelliey Lpsiein, Mac. 17, 2010, oc 110 (hereizafier "Edscein Depo.”) (Deposition Attachment #0 ! Whew cuestioued about this subject at bis deposition, Epstoin invoked Lis Fifth Amada right i cewain ileal cote Di: wake a. incriiuaring admission, Accoutingly, Edwards is entied 3 the averse inference agaizst Epstein 1a, hod Epstein answered, Se answer would have bon vatvordle fa Ein, “Tis well setled tat the F-fllk Amendment ¢oz3 not frkid advs: ieferences agalust partes to 2. Epstein repemedly sexually assaulied mone than forcy (40) vourg girls on Dumeroes uecausions bessveen 2002 sad 200 in kis azssion in West Balm Boch, Florids, Those sexual zssunls included vag pereinton, Fpsicin abused tang of ie girls davers if not Fundreds of times. Fysein Depo. ac 109 (0: Hows many tines bave you cogaged in oral sex with females under the ge of 187" A: [Tnvocaion of the Fit Amendment; Deposition of ne Doe, Seatember 24, 2009 and continued March 11, 2070), at 527 (minor girl sexually abused at Tens 17 ines by Fpsteie) hersinafir “Jan Dac Depo”) (Deposition Attachment #2); id, S64-67 (vagus ponctaation by Epstein with his finger), 56% (vaginal penetcation hy lipstsin with a sssager); Depositian af LM, Scpromber 24, 2009, at 73 (ercinafior “LM. Depo”) (Deposition Artzchimens #3) Georg the minnie in which pein absed her beginning when LM wa 13 years ale, souching her vai with is fingers od vibrocor) st 74, line 1213 (she was personally molested by Epstein more tham 50 times), ul 164, line 19-22 und 341, line 12-13 and 605, Tine 3-5 (deseribing thet in addicion to being personaly molested by Epstein sho was Jad $200 pes underage il sho brousht Bpsicia und she brought him more th severly (70) nderse irl - she told him that she di sot want w bring him any more gicls aod he insisted hat she continue to bring him underage iss), Deposition uf EX, May 6, 2010 (hereinafter “EW. Depo") (Doposition Attachment £4) al 115-116, 131 and 255 (descriving Epstein's abuse oF her ginning at age 14 when he gaid her for touching ber vagina, inseing bis fingers 20d iil serio wher they ose 1 esti in rons ts probative evidence offered again fa” Baier v. Paimigianc, 425 1.5. 308, 318 (19765 accard Vasque: v. State, #7 $0.24 1200, 1203 (Fla. App. 2001). Th reson for ai ule i bos lagi nd lian. A marty may ron tame uo he ghia oF Sllees acd thes: escape the consequences by invoking x comiuilional priviege — at leu nal in i civil “aim” Fraser . Securily sd or, Carp 6:5 S034 $11, S92 Fla. App. 1993), 2 using a vibrator and be also paid her $200 for each other undenige female EW. brought him lo molest. She brought him between 20 and 31 underage females); Deposition of lane Doe #2, date (hereinafter “lane Doz #4 Depo”) (Deposition Attachment #5) at 32-34, end 136 (she describes first being teken fo Epstein at 15 years old, "Ding Fugered by Win, having Lin use: a vibrator an [me], grabbing my nipples, sinelling ty butt jerking off in oat of me, licking my clit, sevesal ings"). 3. Alu relevant times Edwacds bas hod a good faith 5asls to conclude and did conclude” tirat Epstein was abl: to ceess 4 large number of undernge girls through a pyramid abuse scheme in which he paid underage victims $200-5300 cash for each atber underage victim that she bruught 1 him. See Palm Beach Police Incident Report at £7 herciuaficr “Incident Report”) (Exhibit “A”), The Palm Reach Police Incident Report details Epstein’s scheme for molestivg widerage feanzles. Among other things, the Tecident Report outlines some of the ‘experiences of other Epstein victims, When $.G,a 14 year ali minar 6: the time, was brought ta Tpsiei’s Wm, she was ralen upstairs by 2 woman she belicved to be Epstein’s assistant. The woitaa started to Sx up the oom, putting covers an the masssge luhle unl bringing lotions out The “wssisiant” then ef the caom and told 5.G. that Epstein would be up in a second. Epstein walked over to .G. and tok) fer to take Ler clothes of in & stem vaise, SG. shales in the repo. she ¢id not know what lo do, 3s she was the anly one there. 5.0. mak off her shirt, leaving ber fra or. Fipsizin, then in a towel cold ker to cake off everyting, S.G. ramoved hur pants leaving = bn support of all aszerions cancwming he acrions Fdware took, what wards loamed. in fe sours of is sezmseaalion of Is slats, Fiwandve pont Bift Delle end io foendstion far tips Bales, sec Birards Anvit ar dspecifcaly purrs 25 id 25 of hat AFEdavit, Fou ary, deposi stashed 0 is mermorarcun will 5 identified momsricely us sachets 1, 52, 4, cic. Ie ci aaeod this emorandan ll bo ido lpaceiselly es exabits A. B,C. on ber fliong panies, Fpsisin ten instructed $03 30 give him a massage. As $.G gave Epstein 2 massage, Kpstein tuned around ang masturbared. S.G. was so disgusted, she did not say anything; Epstein (uid her she "hed o rely ol body.” Zt al 14. Tu the report, $.G. admiliad seeing Jeffrey Epstein’s pens and stated she though Epstein was on stores because he was a “really built guy and bis wee sez was very finy.” Jd. at 15. 4. The enact nuiher of misor girls sho Epstein assauhed is knows only to Kpatein. loivever, Edwards had a good faith basis to beliove and did in fio: beliove that Epstcin's victims iors substantially wore than forty (40) in number. fn addizion to the deposition excerpts fram vq of his meny victims above about the number of undergo girls brought to Epstein and the Pali Bench incident. report, there is overwhelming proof that the number of underage girls molested by Epstein. trough his scheme was in the hundreds. See Complaint, Jane Dog 102 v. Epstein, (hereinafter Jane Dov 102 compiuiei} (Tishibit “B°); see also Deposition of Jelliey Epstein, April 14, 2010, at 442, 443, and 444 (pstein invoking the Sth on questions about his daily sibuse und molestation of vhildren) (Deposition Allacinnen! #6), 5. Ad all relevaat times Edwards has had a good faith basis to believe and did in fact believe that Epstein and bis sttomeys knew of (he seriousness of tho criminal invesiigation: aginst hira und corresponded constantly with the United States Atormey’s Office in an atemyt to avoid the filing of sunerous federal felony offuscs, which offort was successful. See Comesponvence (run US, Allorney’s Office to Fpstein (hereinafier “ILS. Aomey’s Caitespondence" (Composite Exhibit “C) (provided in discovery during, he Jan Doc v, Epstein cused 4 6. Al all relevant limes Tichwards bis had 2 goud fuilh basis lo believe end did in fact believe thar, more specifically, Epstein's attorneys kaew of Epsteic's scheme to cecruit minars for sox and als kien hat these mimors hud civil setions hs they vould bring against him, In fact, there was ach camnnmnication between Fpstein's atiorneys and the United States Prossuulors in 2 joint atcmpt to minimize: Epstein’ civil exposure. For example, on October 3, 2007, Assistant U8, Mdtorney Marie Villain sent an enn] (iihed hereto us Txbibi: “D) lo Joy Lefkowitz, ‘counsel for Epstein, with attached proposed loter to special master regarding handling numerous expected civil chins aging! Cpstein, The leticr reads in porlinent pari, “The wdersigned, as counsel for the Cnied Siates af America and Seley Tpstein, joinlly wile (0 you to provide information relessl 1a your service és # Special Master in the sclection of en ationcy to represent sevoral voung women who may have civil damages claims against Me. kpsein. 1a (18. Attorney's Office and the Federal Bureau of Investigation (jointly referred to ai The "Uiniled States”) have conducted an investigation of Teilrey Cpslein zogarding his solistation of minor females in Palm Beach Caunty' to cagags in prostitution. Mr. Epstein, through bis assistants, would recruit uaderage females t travel i his ome In Palm each tn engage in lewd canrluct in exchange for mancy. Bused upon the investigation, the Unilzd States has identified forty (40) young women who can be characterized as victims pursuant to 18 USC 2255. Some of those women went io Mr, Gpsiein's home © only mes, sone wienl there ut ranch ws 100 limes or moms, Some of the women's conduct was limiied to performing u topless or nude message while Mr. Esstoin masturhated himself. For ather women, the conduct escalated to Tul) sexual intercourse. As part of the resolution af the case, Tpei las greed that he would nal antes! jurisdiction in the Souibern District of Floridy for any victim who chose to sue hin for damages pursuant to 18 USC 2255. Ms Lpstein agreed to provide an adorcey for visti: wha elected ta proceed exclusively pursuant 1 hal section, and agreed lo waive any challenge lo Jibilicy under that scction up lo en mount agreed to by tho partis. The partics bave agreed to submit the sclection of an amoruey 10 a Special Master..." 2 Aull redevynt times Fubwards hog had a gon Gith basis 1p Selives and did in Gal believe that LM. was, in act, 2 victim of Epstcin’s criminal ausc because LM. was onc of the sairor Females (at he Lied Seles Aliomey’s Oflice recognized as a victim. LM.’s sworn deposition tescionony and the adverse inference drawn from Epstcin's refusal t testify confirm that Epstuin began sexually assaulting TM. when she was 13 years ald and continued 1 molest her on more than fifty (50) aceasions over thre (3) years. Epstein Depo., Atachment #1, ac 17 (“Q: Did you . .. over cogage in any sexual conduct with LM.#* A: [Tovocation of the Fifi Amendment]; see also Fostein Depo., April 14, 2010, Attachment #6, at 456 ("(): LM was an ‘underage female ther you first abused when she was 13 years old; is that comet?” A: Tnvosation of Fifth Amendment] 5 Kpstein was also given ample opporuity to explain why ho engaged in scxusl activity with LM. beginning when LM. wis 13 years oll and why be has molested minor: on an everyday basis for years, and he invoked his Sth amendment right rather than provide explmation. See Epstein Deposition. Tebruamy 17. 2010, at 11-12, 3031 (Deposition Attachment #7). 9. Epstein also sexually essed EW, begicning when she vas 14 years old and dil sus or muneTius prcasions, See LW. Depo., Atachient #4 at 215.216, 10. Another of the minor girls Epstein sexuelly assaulled vars June Doe: the abuse. bogan when Jin Dos was 14 years old. Rather dian inciionioate himself, Epstein favoked the Sil amendment i questions about hie digitally penetrating Doe's vagina, using vibrators on ber vagion and masturbuting and cisulating in her presence, Tpsiein Depo, April 14, 2010, Attachment #6, at 420, 464, 468. 11 When Edwards's clients 1.M., FLW, ard Jane Dae were 13 or 14 years old, each was hraught to Fpstein’s hame maltipic times hy enotber widorage victim. Epstein engaged in 6 one ar more of th following acts with sach of tho then-minor girls ul bis mension: receiving a topless or completely mudo massage; using & vibtaior wn her vagina, mesturbariog in hee prescis; cjaculsting in her presence; touching her breast or bettoeks or vagina ur lhe clothes covering her sexual organs; end demanding that she bring hin other underage girls. Fpstein acd is co-conspirators used the telephone to contact these girl to entice or induce them into going 10 is mansion for sexual abuse. Epstein also made EW, perform oral sex on him and was 1 perform sex acts on Nadia Mercinkove (Tpstein's live-in sex slave) in Epsteins presence. Sac Plaiofif Tums Doe's Notice Regarding Evidence of Similar Acts of Soxval Assault, fled in Jano Toe v. Epstein, No. U8-cv-80893 (3.D. Fla. 2010), as DIE 197, {hereinatter “Rule 413 Notice™) (Balubit "E"); Time Pos Depo, Atiachment #2, at 379-330; LM. Depo, Attachment #3, ac 416; 1L.W. Depa, Atachment 74, at 20, 12. Aull relesant tines Ditwacds has had a good faith basis to believe and did in feet helieve that vet another of the minor girls Epsicin sexually assaulted was C.L. When she was approximately 15 years old, C.I.. was brought 10 Kstein’s home by another underage victim. While 4 minor, she was at Epstein's homo on multiple oconsions, Fawisin engaged in ane or more of the following wets with her while she ws a minor at bis house - topless or completely ude mussige on Tpstein; Epstein used a vibretor on her vaging; Tpstein msturbuied in her presence; Bpstein cjocularod in her presence; Epstein also demanded that ste bring him other underage girls, Sev Rule 413 Natice, Exhibit “k"; Incident Report, Exhibit “A." 13. At all relevant times Fedwarils has hil u good faith basis 10 believe and did ia fact belicve that you amoiher gil Mpstein sexually assault ws AH. When she was spproximeicly 16 years. old, she was brought to Epstein's home by suofhir underage victim. While a minor, she 7 was at Epstein’s home on multiple vocasians. Tpstein engaged in one of wore of the foliowing acts with hor while she was @ minar at his house - topless or completely muds msgs on Epsieis Iipslein used a vibrator ou her vagivu: Fpstein masturhzced in her presence; Epsicin ejaculered in her prescove; Fpsiein luched ker breast or buttock or aging or the clatties covering her sexual organs: was made to perform sux wots vr; Tsing made to perform sex aces an Nadia Marcinkova in Epstein’s prosence. Rpstein also forcibly raped this uncerege victim, us ho hid her bead down ugains. her wil and pumped bis penis inside her whi she was sceeaming "Na. See Rale 413 Notics, Exhibit “Fs Tneident Report, Exkizit “A”, at 41 (specifically discussing the rape): “{AJL) remembered that she olimexed and was removing herself from tho masse table. [4.11] asked for a sheet of paper ind ire the rassage table in the master bathroom and where |'pstein, Marcinkova and she viore, Fpsiein tuned JAH] on to her stomuch on fhe massage bed and inscrted kis penis ino her yagina. |A.H.] sured Epstein bogim lo pump his penis in her vagine. [AH] ocarne upset over this. She sald her head was being held again the hed forcibly, as be contd fo pump inside hee She screamed no, 20d Epstein stopped ...” “[AH.] advised there were times that she was so sore when she left Kpstein's house. [AH] wivised se was rigped, tom, in hor veging area. [ATL] advised she ad difficulty walking to the var uler leaving the ouse because she was s sore.” 14, Witham detailing each fet known shoul Fpatein’s abuse of the many underigs girls, Edwards has had a good [ith basis to believe and did in fect boliove at all slovant limes that Epstein also abused ofher viet in ways closely similar to those dessribed in the preceding pacugruphs. Epstein’s acditional victims includ the following (among many otier) young gis: S453 AD; VA: NR; 184 VZ3 LA; FE; ML; MD; PID; und DN. These gis were between the ages of 13 and 17 when Fpsiein hused them. See Rule 413 Notice, Exhibit Tiz Deposition of B.W., Deposision Azachment #4. H 15. One of Mr. Epstein’s household employees, Mr. Alliedo Rodrigher, saw numerous endersge gisls vowing ino Epseein’s mansion for purported “messages” See Rodrigue Depo. at 242-44 (Deposition Attachment #5). Rodrigues was aware lai “sex fogs” ad vibrators were found in Tipsien’s bedraom ater the purported massages. 4. ar 223-28, Rodger thought what Epstein was doing was wrong, given the extreme yaulh of fhe girls he saw. fd. at 230-31. 16. Allred Rudvigner. sak a journal fiom Epstein’s computer that reflected many of the rames af underage females Epstein dbused across ihe country and the world, including locations sich as Michigan, California, West Palm Beach, Rew York, New Mexico, and Paris, France. Soe Journal (hereinafter “Tao Journal” or “Holy Grail’) {Exhibit “17 (idenciying, among other Epsiein wequainiances, females that Rodriguez believes were underage under the ‘healing Inbeled "Massages™). 17. Rodriguez wns later charged in a crineinal complaint with obstruction of fustios in conmaetion with tying to abtain $30,000 from civil attomeys pursuing <ivil sexual assaull cases agains: Epstein as payment for producing the baak 10 the attorneys. See Criminal Complaint ut 2. US. v. Rodriguez, No. 9:10-CR-80015-KAN (S.D. Fla. 2010) (Fxhibil “G7). Rodrigues Stated he needed moncy because the journal was his “property” and that be was aftaid that Joffrey Epstein would make hi: “discppear” unless be had au “insurance policy” (i fhe journal). ef at 3. Becausc of the importince of the information in the joumal to the civil cases, Mr. Rodviguez eller i “The (oly Grail" 15. In the “Holy Greil” or “The Tours,” aicong he many nares liseed (along with tho abused girls) ure soume of the people that Kpstein aileges i: his Complaint bad “no canrection 9 wshatsaever” wich the litigation in this cee. See, e.g, Taumal, fixhibit I, 8S (Donald Trump); 09 (Bill Clinton phone nmibers listed under “Doug Bands). Federal Investigation and Pica Agreeovent Wits Epiein 19. In sporosimately 2005, the FBI and the U.S. Attorney's Office in the Southern Distr of Florida learned of Bpsoin's repeated sexual abuse of minor girls, They began @ criminal investigation info fedorel ollenses related to his crimes. See US. Atomey's Comespondenye, Tahibiz °C. 20. Avall relevant times Favours has uc a good faith basis to believe and did in fact blisve thal (4b avail he Government learning about his abuse of minor girls, Tpstein Mreatened Sis employes and demanded thet hey not cooperate with the goverrinen:, Fpstein's aggressive withess tampering was so severe thal lhe United States Attorney's Office proparcd nogotinted plea agreements containing these charges, For example, in a September 15, 2007, email from AUSA Villafiia to Telkowil (atiached hereto as Exhibit “H), she attached the propose plea agreement desciihing Bpstein's witness tamporing as follows: UNITED STATES vs, JEFFREY PSTTIN PLUA PROFFER" On August 21, 200%, FRI Speciat Agents K. Nesbitt Kirkendall aud Jason Richards traveled 10 the home ul Leslie Graff to serve her wich a federal rnd jury subgoena with an investigation pending in the Souler District of Florida. Ms. GrolT works as the persona! assistant of the defendant. Ms. Goll” began speaking will the ayents and then excused herself to po upstairs to check on hor Sleeping child. While upstaizs, Ms. Grofl Ieleghaned che defenda, Joffrey Fipsiein, aad informed him that the FBL agents were ul her home, Mr. Fpstein instructed Ms. GrolT not to speak with the agents and ropcimumded ber for allowing thera into ior home, Mr. Cpsiein applied pressure to keop Ms. GrofT Tron complying with he grand Fury sebpocmis that the agents had served pon her. Tn particulay, Me. Epstein wamed Ms, Groff wgairs srming aver documents amd electronic evidence responsive w the subpaci end pressured her 10 delay her 0 appearace before the grand Jury in the Southem District of Florida, This canvensation occurred when Mr. Fpstein wis shied his privaiely owned civilian airerafi in: Miami in the Souther District of Florida. His pilot bad filed a flight pian showing the parties were about to rerum fo ‘Teterboro, NI. ARer the canversation with Vis. Gro, Mr, Epstein became cancerned that the FBI would ry to serve bis tnsveling vomprnion, Nadia Murcinkovs, with « similar rend fury subpoena. In fac, the ageats were preparing to serve Ms. Marcinkova with a target letter when the flight landed In Teterhoco. Mr. Epstein then redirected his airplme, taking ie pilot lk & new Might plan to travel lo (he US Virgin Ishunds instead of the New York City area, thereby keeping the Special pens from serving the carget letter on Nadia Marcinkova. During the flight, the defendant verbally harassed Mis. Marcinkava, icussing and pressuring her roi lo caoperats with the grand jury's investigation, thereby hiadering and dissuadivg her from reporting the commission of 4 violation of foderal low to a law enforcement officer, nameiy, Special Agents of the FBI. Kpsisin also thveatened and narassed Sarah Kellen against cooperating ngwinst ir us well, 21. kdwards leamed that the Fab Beach police department investigation ultimately Ted @ the exvostion of « search warmunl at Epsiein’s mansion in October 2005. See Police Incident Report, Exhibit “A”. 22. Fidvards leaned that ol scoand fhe sim ime, the Paha Beach Pelive Deparment alsa hegan investigating Epstein’s sexual ahuse of minor girls. They also callected evidence of Epstein’ involvement with minor girls and bis obsession with training sox slaves, including pulling information fram Tipstein's trash. Their investigation shower thal Tpsiein vrdereal fran Amazon.com on about September 4, 2005, such books as; SM101: A Realist Introduction, by Jay Wiseman; SlavaCran: Roadmaps for Leotic Servinude - Principles, Skil, and Tools, by Guy Bakdwirs; aud ‘(raining with Miss Ahemathy: A Workbook for Erotic Slaves and ‘Their Owners, hy Christin Abernathy, See Roceipl for Sex Shwe: Puke (Exhibit “T"), 23. The Palm Beach incident reports provided Edvards with tie names of aumcrous witiesses (nl parivipated in Cpstein’s chiki molestation eritninal ensecprise end also provided n Taiveards with some insight into bow far-reaching Eostoin's power wass ind hoe addicted Epstein was 10 sex with chillren. See Tnciders. Report, Fhibit “A” 24. The Palin leach Police Deparment also collected Epstein’s message pads, which provided other nares of peopl: thal also knew Fpstein's scheme ta malest children. See Mossage Pads (Exhibit “I") (note: the aames of underage females have been redacted to protoct the ananyaity of the underage sex abuse victims). Those message pads show clear indication that Epscsin's stall was froquenty working ta schedule multiple young airls between the ages of 12m 16 years old literally every day, ofton two or threo times per day. Jd. 25. In light of ali of the information af numerous crimes committed by Epstein, Fidvaris learned that the U.S. Attorney's Offico began proparing the fling of foders! criminal chacges against Epstein, For example, in addition (0 Lhe wilcess tampering and money Tuumdering charges the LS. Atcamey's Office propared an 32-pege prosceution memo amd & S3- page Indleument of Epstein related 10 fix wennal whuse of chldien. On Sepreciber 19, 2007, at 12:14 PM, AUSA Villzafaha wrote ta Epstein's counscl, Jay Lelkowilz, "Jay - Tate to have lo be firm: about this, but we nced to wrap this up by Monday. 1 will nol miss ty indictment dace hon this has dragged on for several weeks ulready end thea, if things fall apart, be left in 2 loss advaviageous position than befor the negotiations. have had an 82-page pros meno and 53- page indicmicnt sitting vn the shell since Mey to engage in these negotiations. “There has fo be an ending date, 2nd that date is Monday." These end othr communications are witkin the comespandense etushod we Composite Fahiit “C." 26. Gttwards learned that rather than facs he filing of fedeml felony eriminal charges, Epstets (through His ullomeys) engaged in plea hargaln discassions. As a resaht of those 12 discussions, on September 24, 2007, Epstein signed an agreement with the US. Atmey’s Office For tho Snuthern Disisiel of Ford. Linder th ugreement, Tpsluin wgroed bo plead guilty 10 an indicunent pending agaisst hi in the 15° Judicia] Circuit in and for Pali Beach County charging him with solivitation of prostitution anc procurement of minors for prostitution. Fisiein als agreed thal he would receive a thirty month sentence, inchuting 18 months of jail time 2nd 12 months of community control. In exchange, the U.S. Attomey's Office agreed not to pursue any eden] charges ugeinst Fpstein, See Non-Prosecution Agreement (Txhibii “Kh 27. Part of the Nou-Prosceution Agreement that Epstein negociated was a provision in which the fedenil government agreed ool & proscculs Bpetsin's co-conspirators. The co- conapirutoes procuced minor females to be molested by Lipstein. One of the co-conspirators - Nadia Murcinkov -even pariipsled it the sex sts will minors Cineluding FW.) and Tsien. Se Tncideat Report, Exlibit “A”, at 40-42, 49-51; Deposition of Nadia Marcinkova, April 13, 2010, (hereinafter “Marcinkovs Depo.”) ai 11 (Deposition allachmen £9), 28 Under the Noa-Prosecusion Agresment, Jpstein was ta use his “hes: efforts” to entec into his guilty pleas by October 26, 2007. However, Edwards leamed thac Epstein violated is agreement with the U.S. Attorneys Office 10 do 50 and delayed entry of his plea. See Lefer om US, Atwouncy R. Akander Acosta to Lilly Ann Sanchez, Doc. 19, 2007 (Exhibit “17 20. On Jaruury 10, 2008 snd again or May 20, 2008 LW. and LM. recived letiers from the FBI advising them thar “[tlhis case is curently under investigation. This can be a Tongthy process and wo equi. your continued patience while we conduzt a thorugh investigarion ® Letiers artached at Composite Exhibit “M". “This document is evidence that the FEI did not noiily EW. und TM. that u plea ugreement had eirendy been reached hat would JE] lock fxleral prosecution of Epstein, Nox did the FBI notify FW. and L.M. ol any of the parls of the. plea agreement. Nor did the TBI or other federal authorities confer with kW. and LM. about the ples. See id. 30. In 2008, Edwards belicved in good fit that sriminal prosecution of Epstein was extremely important 10 biy ¢lients LW. and LM. and chat they desired to be consulled by the FRI uniiar other representatives of the foderal goverment about the prosecution af Lpstein. The fotters that thoy had received around January 10, 2008, suggosred that # criminal investigation of Tpsiein was an-going and thet they would be contacied before the fede] government cezched any final rosolction of hat investigation. See id Edwards Agrees tu Serve ov Leoa! Counsel for Three Victims of Tpsiein’s Sectal Assauliy 30 In shoul April 2008, Bradley J. Edwards, Esq., was u licensed altorney i Farida, prailicing 05 a sole practitioner. As a former prosecutor, he was well versed in civil casos tht involved ceiminal els, ineluling sexual assaults, Three of the many girls Epstein had ahused — LM. TW, and Jane Doc — all requested thal Tiwards represent them civilly and socurc apgropriare monetary dsmuges against Iipstein for cepeated acts of soxual abuse while they were minor girls, Twa of the girls (LM. and EW.) sls reucsted that Iwas represent them in connection with a concem bul le Federal Rureau of Investigation (FBI) and U.S. Adomey’s Office might be nrmanging a plea Sargain for the criminal offenses committed by lipsozin without providing them the legal rights to which fley were entitled (including the sigh to be notified of plea discussions wd the right to confer with proscutors waaul any pln armgenienss, See 1" Alfidavit of Bradley J. Edwards, Esa. at 1 - 2, 4 (hereinailer “Cdswards Affidavit’) (Exhibit 32. On June 13, 2008, stromoy Edwards ngreed to represent 13.; on July 2, 2008, attorney Edwards agree] 0 represent fane Doe; and. on July 7, 2008, attorney Edwands ugred Io sopruscau LM, in connection with the scxusl assuls committed by Fpsiein and to iasure that thelr sighs as victims of crimes were protested in lhe criminal process on-going agaist Epstcin Mr. Edwards end hs three clients executed written retention agreements, Sec id, al 2. 3. In mid Junc of 2008, Bdwards contucied AUSA Villafaha to infor hor that he seproscuted Jane Dios #1 and, later, lane Doe #2. AUSA Villafifia did nol advise that plea agreement had already been nogotistod with Fpstein’s avoreys thar would block fedoraf prosecution. To the contr, AUSA Villafata mendoned + possible indictment, AUSA Villafafia did indicate that federal favestigators had concrete evidence and information that Epstein bad sexuully molesied many underage minor females, including FW, LM, and Jane Poe, See id aL 44. 34. Edwards ulso requested frum the 11S. Attorney's Office the informetion thal thes had colleuted regarding Epstein’s sexual abuse of bis alienis, Hawever, tie LS. Attoraey's Office, declined to provide uny such information to kdvards. It similarly declined lo provide umy sch inurmmation 10 fhe other attameys who represented victims of Fpsiein’s sexual assaults. Authe very leas: this includes the items that were confiscated in the search warrant of Epstein’s hore, including Gilivs. vias, massage table, oils, wd addiiom] messige pads. See Property Receipn (Exhibit 0"), 15 35. Om Friday, lane 27, 2008, at approximsiely 4:15 p.m. AUSA Villalada received a apy of Epstein’ proposed state ples agreement and learned that th plea was scheduled for 8:30 sm, Monday, June 30, 2008, AUSA Villafasia called Edvards 1 provi novice fa his cliescs rogurding the hearing. AUSA Villafata 6id not 1611 Aomey Iidwards that the silty pleas in state cow would bring wn wd wo the passibilicy of federal prosceution pursunnl 1 the plein green. See Cdwards Affiavir, Exhibit “N', ul $6. 36. Under fhe Criowe Vietins’ Righss Act (CVA), 18 US.C. § 3771, viciims of fodersl crimes — including 1W. and LM. — wo entitled 10 basic rights during any plea hargaining process; including the right 0 he treated with faimess, the digtt (0 confer will prosecutors regeding my plea, and the right to be heard regarding any plea. The process that was Tollowed leadisg to the non-prosecution of Lpsiein violated shese rights of EW, and T.M. See Fuacrgeney Petn, for Victim's Enforcement of Crifue Victien’s Rights, Na. 9:08-CV-80736- KAM (8.0. Fla. 2008) (ochibit “B"). 37. Bocuse of the vialatian of the CRA, on July 7, 2008. Fiwards filed an action in he US. District Cow for the Southern District of Florida, Case No. $:08-CV 8UT36, seeking to enforce the rights of EW, al LM. “hat action alleged fat the U.S. Addomey’s Office had ited 0 provide 11. and LM. the rights lo which they were entitled uncer the Act, including the right to be notified wboul u ples agreenent and to confer with prosecutors regarding 1. See id. 35 Oa July 11, 2008, Fdwards lak EW. 2ad LM. with him to the beacing v1 the CVRA action. I was only a this hearing thet both victims lzurced foc Use fst tine that he plo deal was slrcary done with Fipstein and that the criminal case against Tipsiein had been 16 effectively terminated by the 1.5. Atiamey’s office. Swe Hemming Trenseript, July 11, 2008 (Exhibit “Q"). 39, Fiwads leamed au Jae Doe ell so stoongly tit (Be ples bargain was inzppropizre thet she made her own determination to appear an a telexision program and exercise ler Fist Auenduenl. rights Io orificize (5 unduly lenient ploa bargain Epstein received ina criminal case. 40. The CVRA action that Bdvarcs filed was recently administratively closed and Edwards filed a Motion i reapen that procesding. See No. 9:08-CV-80736 (S.D. Fla). Epson's Entry of Gul Pleas ro Sex Offenses 41. Uttimately, an June 30, 2008, in the Fifteenth Jusicial Gireuil in Palen Basel Comaty, Hlorids, dofendant Epstein, entered plozs of “guilty” to various Florida state crimes invalving the salicitaiion of’ minors Tor prostitution and the procurement of minors for the ‘purposes of prostitution. See Plea Colloquy (Exhibit “X"). 42. As u vondiion of thal ples, and in excimge for the Fedora] Govermacnt not proscouting the Defendant, Epscein additionally entered into an agreement with the Federal ‘Government avknvwledging thet approximately thirty-four (34) other young girls could receive i pagments Gor him under the federal statute providing for campensatior. lo victims of child sexu abusc, 18 USC. § 2255. As bid bon agroed months before, the U.S. Adtommey's Office did not prosecute Eptela federally for bis sexual abuse of flies minor girls. See Addendum lo Nop-Prosceution Agreement (Exhibit “S”) (in redacted fom: to protect toc identities of the minars invailyedt), 1” 43. Because Epstein became a convicted scx offender, hi was not lo have contact with any of bis vietims. During the course of his guilty pleas an lune 3ih, 2008, Palm Beach Ciruil Court Jutige Deborah Dale Pucillo erdersd Epstein “nor to have any conta, direct or indirec:" with any victims, She also expr stetod that her ra-cosisel ander applied tn “al! of tho victims.” Similar prers were entered hy the federal court handing some of she civil cases against Lpstein. Ihe foderal court stecod that i “finds it necessary ta state early that Defendant is und this courts order nat 10 have dec or fudicecs contact with any plains." Order, Cisse No. 9:08-cv-R0119 (S.D. Fla. 2008), [DE 238] at 4-5 (smphasis added); see iso Onler, Case No. 9:03-cv-30893, IDF 193] 412 (emphasis ackled). Edwards Kites Civil Suits Against Epsicin 44. Edwards had good faith befiel tu his clients Tell angry and betrayed by the criminal system and wished to prosceutc and punish Epstein for bis crimes ugeinsl thers in whatever avenue remained open to them. On August 12, 2008, a¢ the request of bis client Jaze Doc, Bred Fawards filed a civil suit agains Jeffrey Epstein to recover dumeages for his sexusl ass af Jane Doc. Soc Edwards Affidavit, “Ne 7. Tnciudsd ir is Gomplains was & RICE count that expluined hos Iipetein ran a criminal conspiracy to procure young girls for im to seualy abwe. See Complain, Jane Doc v. Epstein (Exhibit “T7). 45. On Sepicanbsr 11, 2008, ul the request of his client EW. Brad Edwards filed a civil suit against leftiey Iipsiein 20 recover damages for bis sexual assacil of EW. See Complaint, KW. v. Epmein (Exhibit “U7). 18 46. On September 11, 2008, at the request of bis clicat LM.., Brul Fdwards filed a civil suil against Jeffrey Epstein w recover damages for his sexual assault of LM. See Complain, LM. v. Epstcin, (Exhibit “V*). 47. Jn Doe's federal complaint indicated thet she sougit damages of more hen $50,000,000. Listing the amount of damages sought in the compiaint wes in accord will alher civil sits hat were. led against Epstein (before any Lawsuit Filed by Twurds). See Couplaiut Jame Doe #4 v. Lpstein (Exhibit “W™) (ied by Terman and Mermelstein, PA). 48. At shout the swe time as Edwards fod bis three lawsuils against Tpstein, otber civil attorneys were Gling similar Tawsuits aguingt Fpstein. Vor example, os or aboul April 14, 2008 another lw firm, Terran and Mermelstoin, filed the Srv. vivil uction agaios: Fpsen or batmll of one of is seven elicnts who vere molested hy Fpatein. The camplaius that atomey Herman filed on behalf of his seven clients vere similar in tenor 2nd fen 1 the complaint that Edwards filed on behalf of his three chicuts. See id. 49. Over tho nest year uni a hal, more than 20 other similar civil actions were filed by various sllomeys against Epstein alleging sexual ass of minor girls. These complains were also similar in teuor snd tone 1o fhe compleint that kdswards filed on belalf of bis clients. These compluints ure 1 public recard asd have not besa attachid, bul are availzble in dis Court's files und the les 0 the 41.5, District Cot for fhe Swaliem District af Florida. 50. In wddition to the complaiats filed aginst Epstein in Florids, a female in New York. Av Cordera, filed a lawsuit against Epstein in New York making similar alicgations = tht Epsteia ped ber for u massage en forced her to give bi oral sex and molested her in ofacr ways when she wes only 16 years olé, Cordero was bam 2 male, and In he complaint she 19 alleges that Epstein told her during the “massage”, “1 love bow young you are. You have a tight butt like 0 buby”. See Jet” Epsteis Sued for "Repeated Sexual Assan'ss” an Teen, New York Pos, October 17, 200%, by Dush Grgoram lnk an beige epost com'pinassicegionalitem_ A4zIWWLUTTI7R FOUIKY (Nb: jsessionid=6CAS ERT IRTTSATSDEISBEBACAASCITED. See Arlicie attached hereto as Exhibit “X". SL Edward's ibree complaints against Epstein cuntingd Joss detail about sexual abuse Caan {as ane example) 2 complaizt fled by eltomey Roherl Iasephsbers from cic law finn of Yodhurst Orseck, See Camplaind, Jane Doe 102 «. Epstein (Fabibit “R"). As recounted in detail in this Camplaint, Jane Doz 102 was 15 years old when Ghisiaime Maxwell discovered ber and lured her to Epstoin’s house. Muswell and Fpsteic forced hr to have sex wilh both af ther and within wesks Maxwell and Epstein were flying her all aver the world. According to tho Complaint, Janc Doc 102 was forced fo live as ane of Epstein's underage son shives for years and was loresd Go have sex with not only Maxwell and Epstein but also other politicians, businescmen, royalty, scademniviuns, cic. She was even mad to watch Epstein have sex with three 12-year-old French girls that were sent to him for bis birthday by a Trench citizen that is a friend of Ipstei’s. Luckily, Jane Dos 102 escaped to Australia 0 get sway from Epstein and Maxwell's sexual abuse. 52. Edwards loamed that in addition to civil suics that ers filed in court aginst Epstein, at around the seme time other atameys engaged in pre- fling sedflement discussions wilh Epstein. Ries than fac filed civi) suits in these cues, Epstein paid money scttlements la ore than 1 other women wha hud sexually abused while they were minare, See articles regarding setlements attached bomelo us Composite Exhibit Y." 2 Fpsteip 's Obstruction of Normal Discovery and Argacks on His Viciims 53. Onoe Edwards fled bis civil vormpluinis for his three clients, he began the aarmal process of discavery for cases such as these. Ho sou standand discovery requests fo Fpsiein sbcint his sexual abuse of the minor girs, including requests for admissions, request for production, and intervoguiories. See Tilwards Affidavit, Exbibie “N", et f11-19 sad 25. Rater than answer any substantive questions sboul his sexual abuse aud his conspiracy far procuring minor girls fur him fv abuse, Epstein invoked his Sth amendment right against self ncriminacion. An example of Epstein’ refusal fo answer in wilachied us Campaaite ixhible "2" (original discovery propounded tn Tpstein and his responses invaking Sth amendment). 54. During the discovery phase of the civil casss Bled aginst Iipstein, Iipsicin's deposicion was taken ot losst five times, Dring all of those depositions, Epstein refused to anmsvicr amy substumtive questions about his sexual abuse of minor wits, Stee, et, Deposition Autachemeots 1, 6 and 7. 55. During these deposicions, Epstein further sttempled fo obstruct legitimate, questioning by inserting a vericty of imelevant information about his case. As ons of innumerable Sxamples, on March 8, 2030, Mr. Ilerowitz, representing soven victims, Tans Dass 2-8, asked, "Q: In 20404, did you rub Fate Doe ¥'s vagina? A: Tiacuse me. I'd like t answer that question, es [would Tike Io answer mostly every question you've asked me here today; however, upon advice of enunsel, 1 cannot answer thal question. They've advised me | must assert my Sixth Amendment, Fifth Amendment aud Fourteenth Amerdment Rights against sol [excuse me, ngainst-unde: the Constitution. And thovgh your partner, Jefieey |lerman, was disbured after fling this lawsuit [a semen that wos unmeel, Mr. Edwarcs' paner ss in fail for 21 fabricating cases of 4 sexual nature Neecing uosuspesiing Florida investors and ofliers ou of amillions of dlls for cases of a sexual nature with--Yd like to answer your questions; however if I--Lim toid that if I do so, 1 risk losing Tay counsel's represealation; therefore Tried secpl their advice." Epstein feposisinn, March §, 2010, at 106 (Deposition adachmant #10). 56. Wilien kdwards had the opportmiry to take Epstcin’s doposition, hc only asked onfonable questions, all of which related 10 the weris of the cases against Kpstein. All depositianss al Epstein in which Mr. Edwards participated on behalf of his clicnrs are ateached to his motion. See Edwands AF, Exhibit “N” a1 {31 and Deposition axtachments #1, 6,7. 10, 11, 12, and 13. CF. with Depositian of Epstein taken by an swore represeating BE (omc in which Edwards was not participating), hup:tfwww. youtube somivateh?v=N-dquliyY Xa: and pir youtube contvathty YONIYIEW-10 57. Edwards's cffors lo obusin information wbout Tpsiein's organization for procuring young girls was also hiocked because Epstein's co-conspirators took the Fide Deposition of Saxzh Kellen, Maxch 24, 2010 (hercinafler “Kellen Pepo.”) (Deposition tnchment #14); Depusition of Nadia Marsinkova, Apsil 13, 2010, (Deposition attachment #9); Deposition of Adriana Muciask Ross, March 13, 2010 (uersinsfier “Ross Depo.”) (Deposition atichment #15). Tack of Mhese co-conspirasors invoked their respective rights against sclf- inerimisiation us 10 all relevant questions, and the depositions bave been attacked. $8. Alall relevant Ges Tebwards has had a goo faith hasis to believe and did in face heliave Sarch Kellen was 2a employee of Epstoin’s aud had been idenfificd az a defendant in an least one of tie complials guinst Epstein for her rale in bringing ils to Epstein’s mansioc: ta Te bussed. A the deposition, she was represented by Bruce Reinhart. She invoked the Tilth on 2 all substantive questivrs regarding ker role i arranging. for minor girls @ come 0 Epstein's mansion 10 be sexaaily abused. Reinhart had proviously boon an Assistent United Stetes Atocaey in the T.5. Attomey's Office for the Saulhern District. of Farida when lipstein was being invesligated crimioaily by Reinbarts office. Reine loft the United States Adomey's Office and vas imumediarcly hired by Epstein lo reprosent Fpefein's pilots aml certain co- conspirators during dh: civil cases gains! Fpeiein. See Felwards Affidavit, Exhibit "N" ae yi 1 $9. Falwars also had other lines of iegidmans discovery blocked through the elforts of Epstein and oflcrs. For exmple, Talwar learned trough deposition that Ghisiaioe Maxwell wat involved in ninaging Epstein’ ateirs and comanics. See deposition of Epstcin's louse manager Janusz Beoziak, February 16, 2010 uf page 14, lines 20-25 (Deposition. Attachment #16); See deposition af Epstein's housekeeper Louella Rabuyo, October 20, 2009, page: 9, Tinos 17-25 (Depasition Attachment #17); See deposisivn of Tpstein's ilu Tary Fagene Marison, Ociober 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo Rodriguez, August 7, 2009, page 302-106 £d 148 (Deposiion Auachment #8); See also Mined Androws Friend, Ghiskine Maxwell, Some Underage Gids aad A Very Disaurbing Story, Sepiemher z, 2007 by Wendy Taigh, Tink at tp forme. cediovarvativns.coméarticle. php? JE9SOHANNA SIOBERG Exhibit "AA" 60. Allreco Rodriguez testifiod thet Maxwell took photos of girls without the girls! knowlodge, kept the imuges on Ler computer, knew the names af the undersge girls ard their respective phone nuinbers and ather underage victims wore molested by Fpatein and Maxwell together. See Deposition of Rodrigusz, Deposition artachment # § at 64, 169-170 and 236. n 61 Tn reasonchile reliance on [bis and vier inlbaonation, Edvards served Maxwel? for deposition in 2009. See Deposition Notice attached as Exhibit “BE.” Maswel: was represented by Direll Jaffe of the New York firm of Cohen an Gresser, and Edwards understood. chat ber attomey was paid for (dicectly oc indirectly) by Epstein. She was reluctant to give her deposition, und Edwads tried Lo work wilh her attomey to take her deposition on terns that would he acceptable to hath sides. The result was the attached con idenlislily ireemerd. under which Maxwell agreed to drop any obicetions to the deposition, attached hereto as Exhibit "CC." Maxwell, however, conirived 10 avoid the Geposition. On June 29, 2000. one day before Edwards was to fly to NY to ake Maxwell's deposition, her attamey informed Ldwasds that Was wll’s wher was Gesdily 31 asd Maxwell wa omssquently fying Go England with no intention of reruming to the United States. Despite that assertion, Gslaine Maxwell was in fact in the country on July 31, 2010, as she #tended the wedding of Chelssa Clincon (former President Cliaton’s daughter) znd vias caprure in a phatogeaph taken far OK magazine. Phoios from Lisuo 809 uf the publication See US Weekly dated August 16, 2010 are attached becto us Lixkibit “DD” and Ucwands ARidaviz, lchibit 'N” a5 12 62. Maxwell is not the only importunt wimess Lo lic to avoid deposition by Edwards. Lpin review of the messege pads that were ken Fram Epstein’ home in the police Insh pulls, see Exhibit “J spre, many vere from Jen Luc Bran, a French citizen and oce of Epstein’s closest pals, Tle Teli messuges for Tipsieiz. One duled 4/1/05 suic, “Tle has « teacher for you iv ‘euch you bow to speak Russian. She is 248 years old, not blonde. Lessons are free ard you can save your 1% today IF youu call” Sex: Messages taken (rors fear Lug rune ire alteehed berelo as Exhibit “EE” In light of chose ciroumstances of the ease, this message reasonably saggcsted to 24 Latwards hat Brunel tight have been procuring hwo eight-year-old girs for Kpsizin to sexually abuse. According (0 widely cireulised press reports reviewed by Edwards, Brunel is in bis inties and has a reputation throughout the world (and especially in the modeling industry) as a cocaine addict thal hus for years malested chitdres, through modeling agencics while acting as Heir agent conduct that has been th subject of artical reports, bucks, several news wrliciss and a 60 Minus dovemeniacy on Brunel’s sexual exploitation of underage models. Se hteutradmillershero, blogspot eomi201 10% women -arc-objecs html, 2itached herelo ns Exhibil wy 6. Tiwards leased that Bruncl is also someone (wt visikd Tpstcin on approximately 67 oscasions while Tpstein was in jail. See Epstein’ jail visitor fog atiached as Exhibit “GG. 64. Falvards leaned that Brunel currently runs the modeling agency MIC2, a campany for which Epstein provides finial support. See Message Pads attached as Exbibit “I” sigpra and Swann Statement of MC2 cuployee Marites Vasquez, Tune 15, 2010, “Maritza Vaseuer Swom Statoment” atthe ul Tabibil “U7 at 1-16. 65. Implayees of MC? told Edwards dat Epstcin’s numeri condos at SOF Fast 66 Steet in New York wero used Lo house young models, Fdwards was wld that MC2 modcling geacy, affliated with Lipsiein aad Brucel brought andorage girls from wll over the world, aramising them modeling conracts, Tpsioin and Brunel wild then obtain a visa for these girs, then would shure the widerage gids reat, presumably to five ay underage prostitutes in the condos. See Maritza Vascuez Som Statement, Fxhibit “111” at 7-10, 12-15, 29-30, 39.41, 59- 60 end 62-67. 25 G5. Iu view of this information suggesting Brune! vould provide significant svidence of Fpstein’s tafticking in young girls for sexual abuse, lidviards had Brunel served in New York for deposition. Sez Notice of Deposition of Joan Luc Brunel attached hereto as Exhibit "11" Relore The deposition tok place, Brunel's attorney (Tuma Kudman of” Wes! Palm Bench) contacted Edwaids to delay the deposition date. Eventually Kuda informed Edwards in Janyary 2009 that Brunel bud lef) the country und wes back in France will 20 plans to retum. “This infaraation was unre; Brunel as accually saying with Epscin in West Fal Beach. See ‘Banasink deposition, deposition tachment #16 ul 154-160 and 172-175; sec also pages from Eputeints probation file evidencie lean Luc Brunel (JLB) staying at his house during that relevant period of time utisched Exhibil “IF”, As 4 resull, Edwards Fed & Motion for Contenpl, altached hereto as Tishibil “KK” (ecause Fpstein settled this case, the mation was ever nied upon) 67. Talwadls was also informed hat Epstein paid for riot any BrensT's regneseniation during the sivil proccss but also paid for logal reproscatation for Sareh Kellen (Epstein’s exceutive assistant and prozaree of girls tor him 10 abuse), Larry Visoski (Fpsiein's personal pile), Dave Rages {tpscein’s personal pilot), Lany Harrisan (psteio’s personal pitot), Louclla Rabuyo (Epsicin’s housekeeper), Nadin Marcinkova (Fpstein's live-in sox shave), Ghidlaine Viaxwell (marager of Epstein’s afiairs and businesses), Mark Epstoin (Epstein’s brother), and Jaansz Banesizk (Fpsioin’s house manages) 11 was nearly impossible to take u deposition of somepne that world have helpfol iaformation tha was nat represented hy an attames; paid for by patein. Sec Edwards A%davit, Exbibit N" ac 11. 26 65, While Epstein and ofbers were preventing any legitimate discovery into his sexu] abuse of minor gids, al (he sume Gime he was engeging {trough his uliammeys) in beadal questioning of the girls who hud filed civil suis wgainst him, questioning so savage cht it made Toc! headtines. See Jane Musgrave, Viciines Seating Sex offender's Millions See Fainfid Pasts Used Agains! Them, Pim Beach Post Nows, Jan 23, 200, available at Tuten paimbeachpost coms nowsieriuiefvietims-saekinp-sex-offonders-millions-see-puinful- pasts: 192988, um luck iereto 25 Fxhibit “LL Edwards Pursues Other Lines of Discovery 69. Because of Tpsiein’s thwarting of discovery and attacks on Tidwaads’s clicnts, Fawards was forced to pursuc ofher avenues af discovery. Edwacds ony pursuod logitmate discovery designed to fuler the cases filed against Epsicia. See Tdwards Affidavit, Exhibic Nagi 0. Edwards nofified Fpscein’s atomays of his intent to lake Rill Clinan's deposition. Edwards possessed 2 legidoawe basis for doing so: (4) Climon was fricnds with Ghisluine Maxwell who was Epstein's lomgime companion and helped to nw Fpsisin's sompanies, kept images of naked underage children or. her computer, helped ta recut ndorage children fur Epstein, engaged in icsbimn sox with underage females thet she procured for Fpsiein, and photographed underage females in sexually explicit poscs and kep! child pornography on har corputer; (b) it was nasional news when Clinian traveled with Epstein aboard Epstein’s private plan to Afrion ami lhe news articles classified Clinton ws Tipsiein's friend. (c) the complaint fitéd on behalf of Jane Doc No. 102 stated generalty that she was required by Tipsicin 1a be sexually expioiied by nol uly Kpsichn but also Bpsiein's “udell mele peers, including royalty, : 7 politicians, acadernicians, businessmen, andar other profession] and personal acgalntances” estegories Clinton and avquainiances of Cliaton fall into. The fight logs showed Clinton truveiing on Lpstein's plane on numerous occasions between 2002 and 2005. See Flight logs attached hereto us Tixhibit “MM” Clinton traveled on many of those flights with Ghistatne Maxwell, Sarah Kelfen, end Adriana Mucinsks, - all cmployors andor wa-corspinions of Epstsin's that were losely onnooted lo Fpstein’s child exploitation and sexual sbuse. Lhe documents clearly shaw that Clinton frequently flew with Epstein aboard his plans, then suddenly stopoed - raising the suspicion that the [Fendship ubruptly ended, perhaps becouse of vents related to Tpsisin’s sexual abuse of children. Kpscein's personal phon dircctery from his computer contains ¢-uail addresses for Clinton slong with 21 phane marshes for hie, including oso for big ussiatint (Doug end), his schedulers, and what appear to be Clinton's persons nuanhers. “Fhis irformation ecrieinly loads one to believer lal Clinton might well he 4 soarce of relevant information and ellorts Wo alitain discovery from him were reasonably calculated to lead 10 admissible evidence. See Exhibits “B”, “T” “AA”, “DD”, and “MM” and Tdwards Afidavit, Exhibic“N" at 15. 7. Bradley J. Edwards, Esq., provided notice th hie infended ia teke the deposicion of Donald Irursp. Edwinds pussessed a iegitimase hasis for doing so: () The message pecs confiscsied from Epstein's bome indiestod that Trump called Epstcin's West Palm Reach mansion on several oceusions during Ihe lime period most relevant to my Bcwards's chicos” corpus: (b} Tru was quoted in a Vauiny Fair vile about Epstein us suing "Tve known Jeff for fifteen years. Tomiie guy.” "Ho's a lol. of fan to be wit, Jt is even said that be likes ‘beaut: women as rch as 1 do, and many of them arc on the younger side. No doubt about it — ® Jelliey cnjoys his social Tif." Jollrey psn: Tnternz ion] Monesmnen of Mystery; Ho's pals with 2 passe! af Nobel Prize-winning scientists, CHOS like Leslie Wenner of the Limited, socilite Ghishyine Mua], even Denald Trump. But it wasn't uatil be flow Bill Clinton, Kevin Spacey, and Chris Tacker m Africa on his privaie Dosing 727 that ihe world began to wonder who 2c is. By Lendon Thomas Jr. (See article acached heroto as Exhibit “NN") (c) Tramp llegsdly banned Fpsicin from his Marago Cid in West Pabm Beach beoauso Epstein sexually assaulted an underage girl at the club; (dy Jane Doe No. 12's complaint alleged that lane Doc 102 was initially upprouched at Trump's Manilagy by Ghislaine Maxwell and rosruited to be Mawel] and Kpscein's underage sex slave; (6) Mark Epstein (Jeffrey Epstein’s brother) testified that Tromp Hew on Jeffrey Epstein’s plan with him (the sams plaue that Jane Dos 102 alloged was used to have sex with underage girls); () Trump had been to I:pstein’s home in Palm Beach; {g) Epsicin’s phone directory from his computer vontsins 14 pons numbers for Donald Trump, including emergency aumbers, car numbers, and numbers 1 Trump's security guard and ‘houscouan. Based on this information, Edwards reasonebly belicved that Trump might have melevant information to provide in the cases against Jeflrey Fpsiein end accordingly provided motice of # possible deposition, Sve deposition of Murk Epstein, September 21, 2009, at 48-50 {Deposition Atiachment #19); See Jae Dos 102 v. Tpstein, Tahibit “B7 Tahibic “TF Exhibit’), “N” and See Edswerds Affidavit, Exhibit “N” acy13. 72. Thwards provided notice ll fo intended Io depose Alm Dershowitz, Edwards possessed a legitnate basis for doing so: (a) Dershawitz is believed to have been friends with Tpsteir. for many years; (b) in one news ariel Dershowitz comments hes, “T'm an my 20h ook... 1b ouly person ouside of my immediate funily that 1 send drafts to is Jeffrey” Lhe 9 Talented Mr. Epstein, By Vicky Ward on Feawary, 2005 in Published Work, Vanity Fair (See asicle attached us Tahibit “00%; () Bpstein's Touseheoper Alfredo Rodrigues testified Gua Dershowitz stayed at Epstein's house during the years when Epstein wes assaiting minor females on u daily basis: (0) Rodrigues lesiifed hal Dershowilz was st Tipsiein’s house al fimes when uederage females where there being molested by Epstein (sce Alficdo Rodiigucz deposition ai 278-280, 385. 426-027); (¢) Dershowitz reportedly assisted in allempling 10 persue the Peli each Stare Atomey’s Ollice thar hecasse the underage females alleged 1 ‘have boca victions of Epsicin's abuse lacked credibility and could not be belioved thet they wore al Tipstsin’s house, when Dershowitz limself was on eyewitness ta Uieir presence a the hase; {61 Jano Doc No. 102 stated gocerally that Epstein forced her to be sexually exploited by not anly Tipauein but ala Ppiein's “adult male peers, including royaley, policicians, academicians, businessmen, andor ather professional and personal acquaintances” — catcgorics that Dershowitz and ncquainéences of Dershowitz fall infor (2) during the years 2002-2005 Alan Dershovsitz, was an Epswin's plans on several occasions according to the Aight logs produced by Epstoin's pilot and information (deseribed hove) suggested that sexual wuulis may hove token place on the ‘plane; (h) Epstein donated $30 Million one year to the uuiversity at vihich Dershowitz teaches. Based on this information, Tdwards hid a reasonable Susis (0 believe thal Dershowitz might have velevint information tn provide in the cases against Jefliey bpstein and accordingly provided notice of a possible deposition. See Dershowit lets 1o the Stace Atomey's office attached as Exhibil “PP; Deposition of Alfiedo Rodriguez at 276-280; Flight Logs Exhibit “MA; Eachibits “B” und “00”; end Edwards AMdavit, Exhibic N" at 14. 30 3, Tipméin's camalaint elleges that Licwards provided rotice that he wished to take the deposition of Tommy Mattols. Thet ssscrtion i untrue. Me. Mattolss deposition was set by fhe fae firm af Searcy Denny Scaral Barnhart und Siripiey. See Hdvwards Aiavis, Exhibit "N” ate. 74. Edwards gave nolice th he intended w (ake David Copperlields deposition. Tidiarde possessed a legidimaue basis for doing sa. Epstein's housekeeper and one of the only witnesses who did not appest for deposison with an Epslein bought uilomey, Allredo Rodrigues, eile thu: David Copperfield was 8 guest at Epstei’s house on several oscasions. His name aiso appears frecudurly in the messige pods confined om Fpstein’s base, Thus been ‘publicly reported that Copperfield himself as had allegations of sexual misconduct made against Jin by women chaining he sexually sbused thew, and one of Epsicin’s soxual assault victims also alleged thal Copperfield Tut touched her in an improper sexual way while she was at Epsceia’s house. Mr. Copperickd likely has relevant information und deposition was rousomibly calealated to 1:46 fo fhe diseavery of adinissible evidence. See Edwards Affidavit, Exhibit “N" at nr. 75. Epson also takes issue with Randy identifying Bill Richardson as a poscible witless, Richandson was properly identified as a passible witoss because Epstoin’s pessomil pilot testified to Richzrdson joiming Epstein al Epsivin's New Mexizo Ranch, There was information ilicating diac Epscain had young girls at his ranch which, given the circumstances af the cass, raised the reasonable inference ho ws sexually abusing lbese ils he bud soused girls in West Pulm Bech ural elsewhere. [ichasdsan had also retumed cempaign donations that were given to ira by Epstein, indicativy that he believed (ha¢ there sas something shout Epstein a with svhich He did pol want fo be associated, Ricliardson wis not galled to testify nor was be ever subpoenaed to testify. See Edwards Affidavit, Exhibit "Nat 18. 6. Fauwards leamed of ullogations (bat Epstein engaged in soxu abtise of minors on Nis grivate aircraft, See Jane Doe 2 Complaint, Exhibit “RB.” Accordingly, Tdwards pursued discovery to confirm these allegations 77. Discwery of the pilot and Hight logs wis proger in he Gases brought by Edwards against Epstein. Jane Doc filed a federal KICO claim against Epstein that wes an acive claim ivaugh much of the iigation. The RICO claim alleged ‘hat Fpsicin ran #n expansive criminal encerprise that involved ard depended upon his plane rzvel. Although Judge Marra dismissed fhe RICO claim at some point in the federal Wfigation, the legal foam representing Edwards’ clients intended to pursue an appeal of that diswnissal. Moteaver, all of the subjects ‘meitionsd in dhe RICO chim remsinzd relevant to other aspests of Jane Do's claims sygainst Eptein, inchuding 1n particular fer claim for punitive damages. See lidveards Affidavit, Lhibit NT ut 19. 4. Discovery of the pilot and Might logs was alo nroper in the cases brought by Tdwards agrins Tpstein because uf the need (0 ubtain evidence of u ders] nexus. Edwards's client Jane Doe was proceeding to tial an a federz! chain under 18 US.C. § 2255. Section 2255 is 2 federal starute which (unlike relevant state statutes) established a mina fevel of recovery for vistinss of ie violulion of its provisions. Prosesdinyg under he shilute, however, tegiited a “federal nexus” to the sexual assaults, Jang Dos had two grounds on whist to argue that such a nexus existed to her abuse by Fsteins first, is use of telephone io armsnge for girls to be abused; ad, socom, bis travel en plancs in interstate commerce. During the course of che firigation, 32 Bdwards smticipeicd that Epstein would argue at Jane Dog's proaf af the lederal nexus was imaitequate. These Fears were realized when kpstcia filed a summary judgment motion raistng this argument, In response, th othr attomeys and Edwards representing Tene Doe used the Dight log evidence 0 respond ta Fpsteins summary judgment motion, explaining that the flight togs demonstuated that Epstein had waveled in interstate commerce for the purpost of fucilituing is send wssaults, Because Fpstein chose 10 settle the case before trial, Judge Marra ti rio rule an the summary judgment motion. 9. Rdwrds hail further remion tr believe and did in fic believe Ut We pilot and Hight logs might contain relevant evidence for the cases ageinst Bpsicin. Jane Doc No. 102° complaint outlined Epstein’s daily sexu] exploitation and abuse ol underage minum as young as 12 years oid and alleged that Lpsteit's plane was used to mamsport underage females to be sexually abused by him end his friends. The fight logs accordingly were a potential source of information about either additional giels who were victims of Epstin’s abuse or friends of Epstein who may hove witmessed or even parficipaled in the abuse. ised on Mis information, Tdwards reasonably pursued the flight logs in discovery. 80. In the full of 2009, Epstein gave a record interview Io George Rusk, a reparier willl the New York Duily News abot pendicg legal proceedings. In that intorvic, kpsisin demonstrated an utr Jack of remorse for his crimes (but indiretly admitted fi crimes) hy Stating: «People do nor ke it when people make good snd that was one reason be (Tpstein) was being tacgeted by civil suits filed 3 yourg girls in Floric; «He (Epstein) bud dane nothing wrong: 3 » He (Epstein) bad gone to il in Florida for soliciting srostitution for no reason: «fie sare thing (i.e., sexua: abuse of minor girs) had happened ii: New York, hie (Tpslein) vid have reseivesd ceil a S200 lie; «Bradley J. Edwards was thc onc causing all of Epstoin’s probioms Gic., the civil suits brought by Jane Doe and otber girls); © LM. vane W bis as o prostitale 2nd & drug user (i.e., cane to Cpstein for sex, rather than Epstein pursuing bor, + AT fhe girls suing hin re ony Irying to get 2 meal fickes; +The ouly thing ic might have done wrong was to maybe cross fhe lin a litle too closely; + He (Bpstein) was very upset thal Fdwars had subpoenaed Ghisline Miaviell, tht she was good person that did nothing wrons (i.c., had dans nothing wrong oven though she helped procure young girls to satisfy Epstein’s sexual desires); + With regard fo Jane Doe 102 v, Epstein, which involved an allegation that tpsiein ud repeatedly sexually ebiised u L5-yeur-uid girl, forced her to have sex with Dis frionds, and ow her ou bis private ple nationally and intemstionally for the purpases of sexually maiesting and abusing hes, he (Epstein) Hippaatly said that the tase was dismissed, indicating that the allegations were ridiculous and untrue. See Affidavit of Michael J. Kisten attached hereto es Exhibit “QQ.” 1. Tho Rush interview nlso demonstrated perjury {a federal crime) an the part of Kpstein. Hpstein fied about not knowing George Rush. See Epstein Deposition, February 17, 2010, taken in LM. v. Joffrey Bpstein, case S0-2008-CA-028051, page 154, ine 4 through 155 line 9, (Deposition auactnest #7), wherein Jeffrey Epstein clearly impresses that he docs not recognize George Rush from fic New York Daily News, This improssion was given despite the Fact that he uve a lengthy personal interview 2bout denails of che case thet was tape cceorded with George Rush, 4 Eppstain's Havessingss of Witnesses Against Him 82. ACAI releyam times Tiwards has a good fnith basis 1a believe snd did in fact “etieve Mat Epsizin engaged in threatening witnesses. See Incident Report, Exhibit “A” at. K2, TS. Attomey’s Cozrespondancs, Exhibit “C" - Indictments drafted by Fedoral Government gain) Fpsisin: and Flwards AMdavir, Exhiiu “Nai 11. 83. Despite thio no contact orders entered ageinst Epstein (see Exhibit C, supra), Talwards Terma fal Fpsiin continued 1 harass hi victims. For example, Jane Doe hid a tind set for her civil case against him on July 19, 2010. As that trial date approached, defendant ‘Epstein intimidated her in violation of fhe judicial no-contwst anders. On Tuly 1, 2016, he but x “private investigator” tail Jane Doe . following ber every move, stopping when she stopped, diving wien she drove, refusing 10 puss when she pullad over, When Tune Doe ullimulely drove 20 ber bore, the “private luvestigator™ then paced in bis car approximately 25 feet from Jane Doc house 2nd deshed bis biga bom lights inlermilicaly into the home. yen more hireateningly, at about 1:30 pont, shea Jace Doe fled ber bame in the company of a reticed police officer cnployed by Jane Doe's counsel. the “private investigator” atempicd tw follow Jane Dos despite a request rat 10 do <9. The retired oflicer sucessfully tank evasive action and placed Jone Doe in a secure, undisclosce location the night, Ocher harassing actions against Jive Toe asa fallawed. See Motion for Content fled by Twands in Jane Doe v. Fpstein cetalling the event, including Fisten Affidavit atrachod to Motion, Composite Exhibit “RR Epstein Settlement of Civil Clans Againsi Wien fir Sesvol Ales of Children 81. Ihe civil cases Edwards filed against Epstein on bebalf of LM, EW, and Jane Te were ewsucably perueived by Tunis be very song cases. Because Gostein bad 3 sexually assole these ils, he had comrmitied several serious tons agaiost team and would be Jiwble to then for appropriate damages. See Preceding Undisputed Faces. Because of the outrageousnass of Epstein's scxvul ubuss of minor girls, Edwards reusoribly expected that Epstein wauld also be liable for punitive duiages io the girls. Because Pdwards could show thal Epstein had molested children for years and designod a complax premeditated scheme to procure differeu minors everyday lo safisly his eddistinn 10 sex wilh minors, fhe punitive damages woul have to he sufficient to deter him fram this illegal conduct chat he had engaged ia daily for years. Epsein was nd is w billionwive, See Complainl, 49 (referring 10 “Palm Beach Dillion’); see oso Epsein Deposition, February 17, 2010, at 172-176 (Deposition Attachunsat #7) (taking the Fifth whe asked whether le fs # billionaire). Accordingly, Fawards reasonably believad the punitive damages tha would have to be awarded agaiust Epstein would have bon subscantial cough to punisk hin severely enough for bis past conduct ss well us deter him fram repeating his offenses in the fiture. See lidwacds Affidavir, kxhibit “N° at 419. 85. On Joly 6, 2010, rather thon face tried for the civil suits that had bren filed ugeinst him hy 1M, 15%. andl June Doe, defendant Epstein setled the cases agaiost him. “The terns of the settlement are confidential. The sctuloment mounts sm bighly probative ia the instant action as Tpstein buses his claims (hal Tidvaards was involved in the Ponzi scheme on Epstein inability so sewde dhe LM, K.W., and Jane Doe cases for “minimal value". His continod inability to settle the claims for “mini value” aller the Poni scheme was uncavered would be highly probative in discrediting any causal relationship between the Ponzi scheme and Edwarés's scitloment neguistions. See Edwards ANidavil, Exhibic“N" au 21, Fd ards Sion Invotvenent in Frovd by Scott Rothsteir 36 86. From in or ubuut 2005, rough in or sboet Novennber 2009, Scot: Rotlsteir appears In lave run agian Poni scheme at his law fires of Rothstein, RosenZzldt and Adler P.A. (“RRA”). This Ponzi scheme involved Rothstein flscly informing investors that settlement agreements bud been reached wilh putative defendants hased upon claians of sexual hacassment andor whistle-blower actions. Rorbstein falsely informed the iavestors that the potentiel settlement agrecments wore wvailible for purchase. Plea Agreement at 2, United Sates v. Senit ¥. Ruibsivin, No. 9-60331-CR-CONN (8.0. Fla. Jan. 27, 2010) attached bereto as Exhibit “SS.” 87. It has bem alloged that son ofher ses that Rolbistein used 1 lure investors Sula his Ponzi scheme were he cases against Epstein that were being handied by Bradley J. Edwards, sq. Edwards had no knowledge of the fiwud or any such use of the Fpslein cases. Sex Edwards Affidavit, Fxhibil “N” a 49. 8% Bradky J. Edwards, Esq., joined RRA in ubout April 2009 and Ted RRA in November 2009 - a period of less than one year. Edwards would not have joined RRA od he heen aware that Scott Rothstein was running a giant Bond scheme al the Grn, Tihwards left RRA shortly efter Leeming of Rothstein's [rauduleant scheme. fd. 2:48. 9. Auno time prior to the public disclosure of Rothstcin’s Pond sche did Fwands Know or Live Tessun 10 beieve bul Rotlictein was using legitinaee claims that Edwards was rsecuting sgainst Epstein for any frandult or othorwiso illegitimate purpose. Jd. ut 0. 90. Edwards never substantively discussed the merits of any of his three cases againse Tpstein with Roflistein. See Deposition of Bradley 1. Edwards token March 23, 2010, at 110-16. {horcinafior “Edwards Dopo) (Deposition Atiachment #22), 3 91. On July 20, 2010, Bradley Edwards recived a letier from fie LS. Atamey’s Office for the Southern District of Florida the office responsible for prosecuting Rotbscin's Por scherne. “The lettec indicated that law coforsement agencis hil determined that I1ewards was “a victim (or polentisl violin” off Scott Rothstein's federal crimes. The ltr irformed Edwards of his rights as a vier of Rothstein's fraud and promised to keep Rewards informed about subsequent developments in Rofisiein’s prosecution. Ske Letter attached hereto as Exbibic wr 92. lefiey Epstein filed # complaint wilh he Florida Dar against Bradley Edwards, Est., teising wlegations (hat Bdwards and others were involved in the wrongdoing of Scout Rothsiein, After investigating the claim, dh Florida Bar dismissed this complaint. See Edwards Affidavit, Exhibit “N” nt §23. Fpsiein Toke de £431 When Asked Substantive Onesticns About Tis Cluims Against awards 93. On March 17, 2010, defendant Lpstein was deposed about his lawsuit gaint Edwards, Rather than answer substantive questions about his Tawsuit, Fpsiein repeatedly invoked his Fifth Amendment privilege, Sve Lpsieia Depo. taken 317/10, Deposition Attpchment #1 94. In his deposition, Epsicin took the Fifth rather than aaswer the question: “Specifically what sre the allegations against you which you contend Mr, Edwards inne up?” 1d aaa, 95. I bis deposition, Lpsteia took to Fifi rathor them name people in California tat Lidwauds had ried to depose to incon the settiement vee af tha civil suit he was bandling, al 2% Ey 96. nis deposition, Tpsteir: Iook he Fiflh rather than answer the question: “Do yau now fore President Clinton personally.” J. © 97. Inkis deposition, Fpstcin took the Filth rather then answer the azstion: “Are you ‘nav selling us that there were claims against you that were fabricated by Mr. Edwards? /d. at 39. 98. Tu lis deposition, Iipsiein 10ak the Fifts rather than answer the question, “Well, which of br. Edwards’ cases do you contend were Sibricated.” Id. 99. In his deposition, Gpszzin walk the Fifth rather thon answer the question: “What is the accual value that you contend tho claim of EW. aginst you has?” Jd. at 45. 100. Tn his deposition, Epstein Wok the Filth rather ran answer a question about the ‘acoua value of the cla of LM. and Jae Doe against him. fd. 101. Inhis depositiun, taken prior to the settlement of Edwards's clients claiuns against Epstein, Epstein took the Fifth rather than wnswer the question: “Ts here any pending cliim aginst you which you contend is ibriceted?” 14. 2.71. 102. to his deposition, Epstein took the Fifth rather thar, answer tle question: “Did you ever have demaging evidence in your gerbage?” J. al 74. 103. Tn his deposition, Epseln took the Fifth rachoe thon suswer the question: “Did sexual assaults evar take place on a private airplane on whith yors were a passenger” 4d. at RX. 104. In his deposition, Epsteia took the Fifth ratber than auswer the question: “Docs a flight log kept for a private jor used by you contain he murs of welebrifies, dignitaries ar internation? figures?” it an 89. EU) 105. Tn bis éepusition, Tpsicin tok the Tifth cuther them smswwet the question: “Have you ever socialized with Donald Truap is the presence of females wnder the age of 182” 1d, ul 59. 106. Tn his deposition, Tseein tack he Til raiber fan answer he question: “Iie ‘you ever socialized with Alan Dershowitz in the presence of fomsles under the age of 18." £4. at 90. 07. In his deposition, Epstein took the Fifth rather than answer she question: “lave you ever socialized witl Mr, Mottola in the presence af femsles umer the age of 187° 7d, st 91- 2. £08. Bn bis deposition, Fpstein took the Fith rather than ams the question: “Did you ever socialize with David Copperfield in che presence of females under the sge of 167° /d. at 109. In his deposilion. Epstein look the Fifth rather than smswer the question: “Have you ever socialized with Mr. Richardson [Govemor of New Mexico and formerly U.S. ‘Representative znd Ambassador to the United Nutions] in the presence of females under the age af 18 Jd 93. 110. In his deposition, Epstein look the Fifth rethor than answer (he question: “Hive you ever sexually abused children?” 1d. at 95. 111. Inhis deposition, Epstein took the Fifth rachor then answer the question: “Did you uve stall members that assisted you in scheduling appainunenls with endeniye fernales; a is, fearatas weder the age of 18. 1d. at 7-95, 112. Tn his deposition. Fpstein taok the Fifth iaher thar answer the questian; “On how many occasions did yon solicit prosditution.” d. at 102. : 40 M2. In his deposition, Epstein took the Fiflh rather than answer lhe question: “Few many minors have you procured for prosiiution?” Jd. at 104. 114. In his deposition, pstein took the Fifa rater then snswer che question: “Have you ever cosrexd, induced or enticed any minor to emgage in wy sexual acl with you?” Td a 107. 115. In bis deposition, Epstein took the Fifth wafer hum answer the question: “How ‘mumy times Bave you engaged ir londling underage lemales?” 7d at 105. 116. 1a bis deposition, Epstein took the Fifth rather than answer the question; “Few many times have you engaged i: oral sex wih females under the age of 182° 44, at 110. 7. 1a bis depositioe, Epstein took the Fifth rather than auswor the question: “Do you haven personal sexual preferences fur illest?” 1 a 111-12 118. Tn his deposition, Epstein wok the Fifth rather than answer the question: “Your Complaint st page 27, puragrah 49, says that "RRA ard tae litigation team wok an emotionally driven set ol fects involving alleged innacent, unsuspecting, underage Somales and a Palm Beach Dillicasice, 26d sought to tum it info a paldmine, end of quote. Wha is the Palm Beach illionsire refined 10 in that seatence?” 14. at 112-13 119. In his deposicion, Epstein ook the Fifth rues than answer he question: “Who ace ihe people who are authorizel la make paysest [10 your lawyers] ou your bebalf?” 44. at 120. 120. 1n bis deposition, Epstein took the Fifth rather than answer the question: “Ts flere inylling; in 1.M.’s Complaint. that was. filed against you In September of 2008 which you contend to be false?” id at 128 4 HOUSE_OVERSIGHT_0106068 * CERTITICATE OF SERVICE i | HEREBY CERTIFY thet an Naseer 4. 2010 a copy of the foregoing hes ben served via Fux und U.S. Mail to all those on the attached servies list. Juck Suurois Searcy, Denacy, Scarola, Barehart & Shipley 2134 Palm Beach Lakes Blvd Want Pulm Beach, IL 33409 (561) bie (Ex) JACK AROLA 2 ar Nn: 165440 Pl SERVICE LIST Christopher E. Knight, Bs. Joscph L. Ackonnzn, Eso. FOWLIR WIL BURNETT A. 901 Phillips Point West 777 South Flagler Tirive West Palm Beach, KL 33401 Jack Alan Goldberg, Fg. Adterbury Goldberger ctl. 250 Australian Avenue South Suite 1400 West Palin Beach, FT, 33401 Mare 8. Nik, lisq Law Offices of Mare S. Nuri Ons E. Broward Blvd, Suite 700 Font Lauderdale, FL 33301 Gary M. Feuer, Ir. Famer, Jaffe, Weissing, Filyiards, Fistos & Lehman, PL 425. Andrews Ave.. Suile 2 Fort Lauderdak, FL. 33301 a Liquid Insight Bankof America “%% Trump’s effect on MXN Mereill Lynch Key takeaways Pte + bi ric sn can aris of Dor Ts utenti ssc nt Mein = © Our nls sus xg ke i ch £5156 nro ww + Wie reamair neatrol for re given LS electior risks ee likely renin higr in the rear prc tpg By Claudio irigoyen and Ezequiel Aguirre SEL rtf the doy, MEN may be uch 15% ders pre a 4 Rect Lu ght ublcatons 13 Aen “ ber rei 2, - 2 Wot Bega Sa 014 Fo ze iret mi ee Mote 8 TE) mM (0 Tr) MXN ns Ee neon . BE en Trump's effect on MXN Po er © eon en ic aaa o* Drmad Trans siects uy Mian sz Our RE aici 3 analysis suggests the exchange “a i perhiaus a mac as 15% undersdued. nour § he big he Mena pen ley wie ro aprile se eves Hel Caton 5 i Home, we rene naar for nos gt S Becton “ks are ely 1 rennin Hig in theca tn. © A model of MH weekly rears incluting Trump £ i sctimote.d model of RAN ms wie Sto rants “andes a § inches Bend Taume's Beak kansas pollo verge nfo 15 posit clin i 15 goncrly accepted no hat Trump's chances he US = cto ae been 3 malo de of he oon ps Ct 15 3 iver cena irvesewent ecg ens bee pyc th Salis ls rd te ot § SR ry oes evs 5 ek ses ok os over in rss fs 8 EE et ee BS oa a tam ane Su a Freep es ocd coi To en a coy Sng oc noe ta. Re pe srs npg 8 7. hl: Ceci nope Js A is the SPSCO index returr, a) is th | 0-yes® US band ye © crange, A ig oe “ - 5 8 ®, ‘ 3 1 1 Strategy: meutral MXN for now J —— Gan ak fod pede s » 0 N greet Ltd EY , ES 2 ol we we ws ome wa ws ma ms me ata Rate na x seen a Can he ing one. Foes ely, 16562015 Ky rade ess To ates nd PX ries for 2016 fen Su 530 TIS, sr. 125 rg stp or“ Comet Clot 2010 Ss UE 45 E.R By ry. 15 bp pc 190 5 Specs £0 bos Sep 2012 Cg $m Gy TG 510750 es sa, ret $25 re 350 so S256 Corea 1. ang 2m Tee 5.0, ar. 1, 530k Co, 5:70 x craze my ut Comet 0% Buy EUS 310th 10s 050 KO co [ER 1 EURUSD-160, SOTA 200. cst 70% 50g 0556 12261 err Lyne a: nme VE Seen 2063 Closed a2 902 {10h 207 5 Su ALCON, ery: 932. target: 9205500: E59 revised “om 50; Closed a: 38.26 115 or 20° Ex 581 TRVATY, erin: 42.40, target 36.15, scp £525 (Cos 518.27: Sel SANA spt £655. pe £27 sw £0 reise Fram 001 New trades. Rates: a7 FRA US wire: wt, 625bn, sarge in tom oss 6 21 Sep 20168 * Beit recent igh tein, rcness buns vs DIS. waning TLTAO & worge-ece Issuance poi renee: widening sting open trades For a comple Ff 03° pon ad rcommenzacions, a5 ull 5 our ade recon: rian dosed wor the 351 17 mons. pase soc £1 Basan rx heck Loos banks 50 he cs Fae ie Lom” 5 ton 20 Races: ESky fon Ss hash ene: 11 Sho, 570k 15.5, top E13 110 AAT “Rank vadging flows a 11 tack of Sram pickuu i con sue <c spt the AAS of 355 Eas Seat. I 2150-03 2 RRS LC oosing In Sop ty 1 sbi pe des Fr. co” premum of £580K on 300m notions. for 3.3 bay 40) F006) “iy rares 2 ar sk fom the L115 tomaitiw, ascectl 1 aol capil boy re “aged oresdy un Jy 58%. 20 B21 In” 0 £005, 0075: ZB Qe $75 01 OLAS) “pling erabitty fuse JK Bug urn cena efit makes hoz long OMG Hy SUITS. PII 0 rade th 3 ong: Stans ing “c<ommendstion 16 0S DIETkeVES 5. Arh WT Amn i, Closnd ar 1 Jl 18 i 5 0g U6 all nb 16 5 €0% “18 consiT6 Jn Closed 3.5309 12 Ja 20161 QT 0152027 “tines ones arg 400 siop ess: 1000p £11 bar 2016) x Sot CURUSD fan 6740411500 ris “cevrsol cos Gate 1.1077 sunt Jl 26761 EUR ezanside isk are underpni ed. ie tink re pos rere rs rally is care and ould be ct ish, Potential shutks inde reat cea, rb sree in ys eri sec ans police pals in Spain, Closed 103461 Jol 2016: Bu: uy EURCHE * 0871 03 at su tur CFSE 7.757805 0g 10.45 vl uf] 1.0930 set) pr 2616) 4 ue vgn 5 Saphe e Daaketamarcs BP ie wipe Fr termi firey “EUR 15 underpncing bes and ir sha tin Eur ss» cheaper say 2 express such » ie hz opin. CHF tens to ps-Form strongly siren ks becom mare loca ec Closer cn 28 fg 2016: Buy EUHUSD 6m 1001.20 strc gs or 155 2 ps off 11020 spot, OF tows v's 121412.3 (20 Fe 2015; “Going 1, £010 FURS sue gs may be anti and eau daub edge in the scan ra che Je QO 3 12025500 Dr hE Funda dL cis nlc Options Risk Statement Potential Risk at Expiry & Options Limited Duration isk Urlike suming a sherting 2 stack. enplcying ary ced ootices strategy i by defircion ie by 3 fi dion. The mas: Save Fike associate ath general tins “ding ate total loss of capi invested and c2 aryzsigrment rik, all of hich ean ccc. ina sron oetiod Investor sulabilty Tre use o* starcandzad tices anc oie elated de aties nstiume are cansideres unuteh € Fc” many Indes =. Invests consciring such Strategies are encourmged o became femiiar vith the “Characze ics anc sks of Sandi aed otces ian OCC autnored whic paos- cn opticrs risks, U.S, rvestars sud carsut ith a FI 4 Regired psons Finca. For detaod infomation egading: 1 isk inv vod ith mcs ng in is options: et avi hee cami ahout publ tens ch 2cter-Tks 5. Analyst Certification ais inh. hereby Cerf +1 devs pressed in This research ear abr: acini an sss aware 2a he ososrzh mid) pple in sh asi. | An fey ea in 0 ch my ccmensatcr was 15, |e, zictl or nc, elated 0 the Scifi tomers. vids apvesszd in fis 2seaves repr an on 7 Sent 0 Disclosures Important Disclosures Other Important Disclosures in EE SS CR RS ES RE SR Fie Bee i Cob eh as SE cl tA SE pam An Ie cy Pre Soop SY vt, sh cd fA Ho | rons Vir yn Gos Wath reo Her rv ek Song rt aE FY 08 Va Th 5 fs HO Vi i aot hd ose ng on US th We ch aac of Yi sn Bs pri sri Bebe Car TR re i en ir eS Tee sl ener pt sta ue ge : ofr Eh RAE A EA Ra rR Er rer li SE ah Sr EAS ip POA esr eA RY Li PAA HO AA AAA JLB AA Ape ARRAN Sah BAA 4 A A sh Mo Bo PA ddl fo A a Ti Re Arb rk ao A Pt i pasap ia BN A SABRE A re agg a bs A A I A al fl eo opera FE i va ah Yo FATES ve Meet FR ER ms. TEE, A EE Sb RL A SAA Ee rr at prob Sl at A Ri ee Mp AA hb bd re as evr aren Cri eT tS TE re Re JRA LAN a RR Re rE A 3 rm Re En Me AF Tl ELF FE i YAR He mtn BP- ne pn 7 rk 0 7 Research Analysts = HE nm pny Sd lie Comic: CO 3601 Fs Apes No. 030601) unireo stares oreice or EE eme——— CovRumEnT crsics Excive Brunch Prsonoel Public Finsual Disclosure Report (OGE Forms 2786) Ra TS ———— Se — E——————— IT I re Mia XT (AOA ee = Za Las 2 June 14, 2017 I [mente Z| otty iam Eee aE Er — Ee —— mr ———s aL 0 ER Bo— eae SE eee ee Lm Pa Ee = Fr | Bm Te EE i — BE Sma Ta —| = OE i = ==x= = E= EE— =F +5 gone mr | Smo o_o EE — i i EE === =—=L Ta CE = i 11 EE — fay eo ooeome [oan = Ea Ear Tam pseene Emsam A EE Ea Lae fame mE = Em I hme ie] ee RE Be a = = Ei a PEE oo TE RE ap. = = ET i —a | | | EAPO | mm ) Eme——— [= ET —— F [ TT — Be PR ry a," Er CE WE wd we eo A SCS | TITER Bh A Tt | [BE I rT 1 [= rrr i EE, A ov overs omen ee uss a) Se ———————————— Ee Er | Tr RE m— CS RE HR A : == a —_m_ i — —-— a fret ome | EE _ | I = | el BE ery A A ose ners oe ———————————— {ai FE aaa =T = ee I 1 [Ee] | | 'HOUSE_OVERSIGHT_010635 ————— tL A 1. ; — Er r————— - ETE Se a ia en Ls THR ACEOMEANTING SCHAAR (PART. OMA AS ANINTIGRA PARTS Mf ARIE AND SHOULD BE EAD HCONILIKCTION TEREWIH. Sap marie | ers OSE OVEREIST. D068 I __ EET | ~~ TEE a a— EE Te oT EIT = CL ————— mmm a i louie Ad mm pad ste ei a | 'HOUSE_OVERSIGHT_010638 nd Co A a = A pl in cy | a pe ee TT 1 | C—O ET — PR ee ; = eee a EE n | | | = —— a tn ore oe aay cr. Loe Ey Bt == TTT [I um JET i] ean a, ro REN, i = a CT] B= 1 | =—T TT I ACCOMPANY SCHED PART. OM BT 2)S AN WTRGRAL AKT OF 8 ARC? AP SHOULD BE EAD I CONNCTION THGHROWIT. Gapain momar hn — = =e [oe Tors pent ad = La == [1 [| _— Et. y eRe remot np eA OS. OARS AA 0 = EEE i 1 ACOA ANI SOUL SAT 2 ETA) AN TEAL ART OFT ADH ANH OULD 5 SAD IN CORLIC HON THERSWYTH. Gap crc mmm —— IR RTaR 0 A = —— PE 0 TRI] RL ll sa Li te nl ems ec men a | ee | i — HEE TT rT | TE A EL EE ——— a me te ea ara ET m————— [| =a | Ee Ap S—— i ™ i ro oS A, PLEA CAINS | LE 1 CC TR ACCORANYING SCHSDULE [PART 2 ASR A113 ANINTSORAL ART CF TH ABA DUD WE REAL 9 OICTION TR Cogn mova | a LE ve ovens ors fy == ma prs ri [pe Fors perm er FETE | ry r— ere a emi Sonor Fr or ES (2. SO Donia J Trump _ Door ———1 a Cn i EE i | rr rT1 Ee ———— —— SE SEE fr fr 1 BS. oe _] ss I I EE eee eee] |, ——— I VS SSR oF 1; IS NS A S— . rr Per rr EE — — El EE a i esc or ot 5 ioe Th ue om, 0 nt che scout mbes see acres ofl meme mes Se ction or equied ermtion SI Sass] |... fpoiirome —————— ee [Parts Spomes Employment Ametondimeome 1] C—O — [ison ou larg mnt [ees 1: SeGER 3 COPAY LC Prem EA = se cory ELAM ARS ACCESSORIES i) ie ey esse TS ms cmp 21 331016) ese erin bl ert a pe 35,207, mss assis pm SS RCE, ~~ J I — I rr) I TT TTR £—— 0 TT Hr I eT —— DE REY I EN id RET EC a 2 NET NE NT — TE RET S— Se — TT EC IT TR rep BET I RC CS — TT I rr — I Fo NE TY I TTR ICT CT E— rr — EE I EE EE — ever I I — — I rer er a — Pe rr a a — SS [Te er ET SR [Tr Ce IT N— —— icin to PS EEE EY TT ET —————r RE errs] LL J SITS —— Ie [1 Err Py eet TT RR Pe — A CTT EE — TT — —. 0) TT Boi BET PS [LT Coe I N— CS —© EEE — ro — ©) Ee pr — Pe TT eee oP Fo) Lr Tet re A = NTT I LT Eee BT TS rr — ET TC TS I er NS I er BT 1 HE A A Ce EE RE PS. [= CoE Tr Cer RT TT I — 7 IEE Cre I | Imtons tor art Be sunimminssmnm i aN | ma mee me" I CE 7 (7 I Ie Ty eter MTT — I Ey cee RUE — — — oS I EE Ce ET — Sev — 0 TN i RC [Hlrcromouescosas a] wm mmm] mm me] tg Coe ET CP [2 ET eTY TET S— pS. 0 ITN BC ITE [Fenroscommerroe | em mann | Se ——— LL. CE TTY Ie ITE [Fecsermanacones or mmr mmm] som ween] C—O ET I BCE rE I I I ES [Em CY IC I ET —_ "mm a J ee eecmmm————————————........ ] SIE. | WO, I ion isielicd I I I EE [lesen Jw] owas] cme [lemme | owamcmmons| vmmn-vams | [losses || owimowsion Jovammcumonr] soo somen | Floseone — [onl wwiommomsrion Jovamcumoon] _vaoorsow | [lta om onacey [Wa] wwissm | [onan | [locomowcom [ua] wmiimmmsran Jovemncoocon] ssomsom [losssswcos [on] wemiemmmmsron Jovmomicon] iva | 1 ) j— | Dia) af ————— [mommies TT 7 [7 EE RE Ce 1 EE HE EE [ene | | | 1 [homesrornncons [Wa] wwemmtmmon foes coon] mova | [lsesconmoremonoumene |v | wwemrwsan [| were | Plusssermccnan [wel vmemmmenmn | como | oom [lussscrnccmae [wa vomemomuion | cmwiion | oosorsoe | [lucene [wef vmicmmmnon | como | vowrsmon 1] Dat a st FE EEN ——————————————————— —————— et... | es a alli | [pee Tew Jvc TecowcType [mcomcAmosnt | ee [5 [= TN Crete ITT TS PS [0 ETT ee TC — LL — 1 mw EET [rrr ETE — I — 0) Er TT Cte BS rere [2 ET =P Ce ETE SE Se (2) Er = Coen I I — — Pe — 0) Kr TET Er I CY FT re ee — Ee Cer pe — ——— pe pr — See — pr ee arr — I — CT a — I —————— LE CT I R— Sp [0 [TT Ce Ce ITE SE 0) [TTT Ce NCTE TN F—— I EE Sr CT — TTT NSE EE A ————— i ——————————————————f verre] LT A 7 NY — I —. 2 IE ee TE [ rT Er IT — I EN I BT — ee — ET CT TT — SS [ITT [ete ITE CP — 0 IE ee CE Cp IST ET Ee I eS 0 ery er rr — I ry Io IT PS 0 ITT te BT ———— ey er pe — I 2 Ie ee IT CE 0 Er rer rr — I [ IT Be NE S— CS re Tg Ce TN I — IT ee I I i ee TE LC [or Po et BT _—_"_|m nitions or Pat EE Ea ED pote Pema] oe ———— a Ee— reer eee J: cme] (FS (TS IEE Ere BT CP —— Tr Ce TET eS 0 ITTY I BCS [oY [Try Cet ICT ET Cr CEN CS — Ty B — Ce Er To I TS ee [Y= Ce ES eT [Yr Tr eC CN Co . LY TT TT CE CP YT EE I re [7 [rTP Et IT pe 2) Lr oT [te To TT Co r= Ct TE TS some] mm Jo cv] wm | Hamm I Ey errr pr — 5 mem, I Er rrr pr — eS UT LT Ce I a— I ——— | —_—" IIIT IIE | 7 ST E— ee — CE I EE — oe — IT YT — ES — Le CE CE BE — Pe — TE CE TT S— ve — TE TT — I — Ce TT Ce I — LC ee I — CC EL] EE Ee MT — CP — TC TT — Pe — TC RT — C—O — [rrsssenes —— am I [2 CE ee I — BT — PP — ET — I — CY ET EE NT S— am——— we, TR REAR iii, | [lomorsomaons [1a | sonwortowmnsiomy | nar] Mn [rey Ete IE — I E=Tr~TTy [te TT S I OS [oY eer eet) I TT SE I [= KT ee) I I [= [ToT [ey BT SN Se — [oY [Ty rere rr — [LT Cer ce — C—O) Ky ce pr a— Se — oy [erry fer er — C—O [Tree Ce I — C—O [TE re pe — C—O [ry err rr — CP — [oer Cry r — C—O) Tr rey ae — see — oy [erry py ar — SS [oY [Terry [eet IT I — [= [fry a — NN 'HOUSE_OVERSIGHT_010658 a es a ER |. J ee ——— a 0 er me} LS —— CS 2) = To [tr I SR re IT Cr) IC FP 2 EET Ce I CI 0 ETE [Tet IT — I Er Eg FT I TN I [ ETT Te IT PS 0 E=Trsry Ter I TR I 0 I= Ee BT I. 0 TET ET Cy pT per pe a— ET Ee rr a— [erry Ce TT TT Ce Yr Tl Eee BT I Yr To ene) BT pe I) [=r Tl [Cer ITT N— Trg FT I TN Ce 2 = Ee IE cons bo ots. ec rn ala Emer mm ame mm —— TY. i — EE ATE LL aw— LL LJ | ——— Tr Tl Ct TRC SR 7 p— Tron | em mmr | mcm | wor wim immm— I) EE eer — SS [Ere er I — I ES ER E— I TOR I EN fiers] BCU SE [Pere A ETE I ES mere — ETE TE E— PoP I TX — I NTE ES [ean | ee CE I RR SS i NT I EO Ce I TE EE mr I NT I A I NTT I I I — LY TY E— CP I I SE ti Fa ——————— 1 fee pee SS. —— TT ec) pee Tow Tvahe _ TecmcTpe [woomeAmowet | Cm — I NET A E— ee I CT I EE Lee — CE ————— ve I BE ee I TT I A ee CTT I wm JO NN PS 2 NCTE I EE ee 2 CTE A ree I ETE EE PS BE I Se TY EE EE ee I ITT — — I — I ER — CTS I a; eR A NT I E— mr I IC A ——— ee A I I EE CE RR cra tor ts ee pt, che on mr, et so ls a Shr ee Tw EY. (S— ET LL CS 1 P—————— I IT ER 1 —— CT A I ——————— I EE EE Flossmmeme ~~ Tv] wowwowe TT 1 Ep El NT EE A Te ON LW , NS []S— C2 EN NO CP 1 NCTE A — PE A ETN A C—O ET EE [hocomeoermmenooons Jv] wesw TT 0] [Flascocrmonmoriase |v] ems [A I. hrsaoomupren Jv] wows TT 0 [ewwosrueroiomone [Vv] wows TT 1) Iloosmosnmmmer Jv] www TT 00000 [lowoosonimee |v] wesw | T ] 1. Tem, ont Tg eo ct Fh Td a ers i ET rman er repaid Ak 5,207 'HOUSE_OVERSIGHT_010662 frosty | EIT EE eremmerrer emer eeee ee EE m—— ENF ....... EE. | — By = FE Pocrpton "TF TWh JieomeTypr TinoomeAmos | Cp ki EN ER EE Dr — ES — — meme——— i I nom [memo |] ul mm 717 Tr I I cl BES I ki LEN I E— ee I CE I E— IS Cl TE EE EE Ff ee ppre LTT E E— ie LA ET I E— i — I TC A EE PE I TE A I [Flenumsermegnn Tv www re TX EN EE NT I TE I tidal 0 NT I EN Ee pt 538 wom mer RE frosviosrerioly RR [ere — Pew pon Y~ ———— Tes pes Tew [vase Tecomelyee eomerwonn epee I SCX EA E— Se NET EE EE Se I CE I EE [Sp EET EE EE em — A EE — per — ETE — ee I CE ye i IT I E— em TE EO Ee — TT — — a I CT I E— I Lr EE A TN EE A 15% EE RE esr Er — iim) Me © 1 1 SEES W— i" EE Pe ee I FE I I A EY E— SS i fe yr 1 of I A A ee rrr 1 ISS Save, SE |S rf ——F—— : Hl rT 1 Bs = 1 = fs = eee ee a 1; NOUN WANN SO WS ——— === [] er} SAA BARS, SAR Sn er rr 1 ul ES ES I frame ly Th he LE ———————— ee ee ——————— I AY} ii ICT EN EE | ET NE ICT ET MT Ey Ty IT ET El I BEE RE ET ET Es ir Nad r= I I MRT NT ETT ve FT ETN EET TY eT NT FT PTR EEC Ky TTS Ce CN) NE CCT IP mmm Greate ee | meson | |r | mn | ET ge EY ET eT re i ET TT Ee ET IC a ee I ET TT sd rm CTT Rr er Er ee EE Me PTT RET sk en i | En an | prs | [oF Le | 1 1 1 p71] I ee ee eT I RE EE RR RRR SL ———————— A — i — a — — rf —————————————— rr] 2 SN 1] 2 A rT] ATR AS Fal id 1] 1 LS fe EE 1 —— 1 1 YN EE —— —— H—————————— A, SU SO nil Wi FN —— — _ a — vp ——— _—___hhw iia Bre pm —— Bow SE mrs ———— pan oo Ylometi frre. Lid [A Ha. m Sse nd Barri -, a. a — wwe pe tio ae | E— Fone sera vein pr ria mre ”; Cryo aks = Wane Sie rg fo Freese Wessreatis main: Fr aaa” me sss Bey out | S—— |. ht J — fap oe pas. ad r———— jcom— ron ad jr j- i priors ie i Tm, PO... Be ses = Wie e ——— mn = Ing i Premem———— © 7 OSESADONS CULLEN “ Rr a fE— sE—--—- IY ; all Eerie =. Sn = S— He PP — Trae ee A PATIL EE A LG a SEE a EE —— BR had ER wees —- ro — —" } i iE i ome messes » i wi on « vesensue en, - - 2 Ta i —— hhh”, ——— EE —— _” » Sen a gua piv Bunion oie Pe — Eo am —— — J a a re. o a wi Soom } : oo oe pe BC Been Ha S— = orion AEE | ha PE 2 Wa LEN o— I hii rd | — | - TR fa - mem, om Fr— Fr— ) ” —— — PE - ASTANA or ha Tpctate fC R— A. po F3 joa— — a Sey sd Lo A— |. —— ss 0 a Bs Aaa LE = [RPO N— oe no os a = a [ — a, —— rppr——t Se, To Fer ou yr Fo — E. [Er —— I... J ar etene fo. ; Ls. . S—p—r I 1 ’ TIT _—— he s—_ : [Ry née wl hind to gr as L eli MuHa; in od re— a ———— Seti nd 22 es. =. rp p— . vr ty re — = Puna i a Ea | H—— jo ont a eases sane vs. He —— En Ware he 4 Shane re Api i. “ Fane a i statism isa i pr = rE n———— i Li pt sa Sy - a [Er ——— ia i 1 CL EBSSUATIDNE LAE ramm—— pon pron - = I _mn a re = CA SEONG el po Er — Roane Pr—— Sees: pu Formers Be kiiiiad Pur Esenrytesei ee rennet Err RR Bare BTiS sneer ea mu ese ee ————_—_o pe spin ™ - ® | S—— ee fc R— jc o— = ncsounarsc . o — — sa EG ed jn Lo — ost . a fer i — Fait | S— fo — 2 Fhamac we DST Mo » » Fu wie 0 Dv seo = AGING coe Lo — I— —E sit Pere Er jrm— . re : Sstinr Ft re meres az Free a] Lcd ad | ——— ie i ares Sut ad fs ee i ann: a ee Sangh: Hutt | SRE |. y”” . Aman Waren mS EE me rome RR , DPIC a. bm rem = ® Wisin He eee Ee. fi — [re—— wis. i fn for — [— EET —— wie . - — —-— i “ — — muessan om “! + - — [E——— Bester Pats rE Hares —— L— So— besa dd jy en 5 JAP CAROUREL 1G » a - - Fame ements 2 mee BEAD Uo ane Hawn Tooke ro A er rriotesc | — | me cacao WEEE Cx p— Shut 2 cruc i » marcsiesern Si keg mat Bonu = BI a JO " sowie wee mime cocaa0 man 12 ens te sts as rn ten LC cet = po cxcaco mea Kate 5 oe * CHD A MET COE ; " es Cas CARS LL VBA 11138 mae coh cos 7 i CORI CGAL vt an ty sted ti 1 Ph oi bs Soma pd Lomp— pes Rp [———— a. » Lo E fo vera a ad ronan fr I = mweonenconcy Ses ad avers Bhs . 2 pre fo nm a ac mnie [- mses aun oi “ 5 [ane sae ha Ea hie mnie Beane E—— JE Te Teac cost — a Er sae esc . ” a sin ET — py = E——— I. oe Somes = = » T— ove— PT E——————————— == re 5 mewn avery iia ster Hussey $e wean f— " sear — fo Flu fo ore = Ee ei ne N . LC A—— — rears oes. oes his Fonte ncn arse I - J —" en Lv ar Ens Ss ensues = - og Foute ire sew jo hci eher : cial rus = 5 Dut oe a ey isi a HOUSE_OVERSIGHT_0106¢4 RT me st te tr Sn . - Ee are " Ba L— te p— free, a a = Teens cosncose i id osu fo 0 men ves cmon, N » memesens p- — sats a ou b hae namonm Beri # sian Famcrzs tare +» Ime scone f— Pree. - ES El ecins = = messes on a vero ses oor TH Pm quan a | —— fo — cesta — Co i Hh np bi ll er aan [w— . > Ea hie a py ed — Fe . — ol —— rnd ar ce 8 ss PE BER gets, in nie Se 5 ranean stam vue. i: go Ev von iow iene = mein merc — ne L— RS AREY rr rm pe r— KAGAN LLC QS pe pose P Py con: Gna pea ma eS ns esremeon ro Rt — = eae w BC jo ter ute —— ja cad al Ecos He —— awe TR Mornin oe Josie fr —— f— HOUSE_OVERSIGHT_0106¢8 ——— Bal amd fR— Bei fc — f— Fey To karen we — rm Bo Sn | S— Bit ami geet fr. Baan == an a messin - sa gag NE me rn ye. fe Se F- . A oe bo ee Tiny ee - atl Proteesriy rd Bee pd | T— |- 15 THY ARS TOROTE LLC a) ? LL ” i TAGES oid —— Buia Jats — | o— Ey Si: Hoorn, fe Se NSA ET AAR SR CO bias fn — f— —_— Snes pan | —— on a Prey wan ~ = Sew ninonn sors 08 arRESES o Jute sad LL — fo bid A cass. fren HW iuiin . cna & 6 FL SCAN MANE ING TOS A & i mus ansmemens : as meses An ind mar css » HB Eas = J ” rm — mesa om ssa Samet ci Hh mira Ehsan pn y sonarus = Bn [FT——— [Epm—— il pa LA. Tbe » apm te Gy, Re tre nid Ws 2 0 IE MRSRRITLLS i i Ee EA RIE ca TP TEE AL TOE LL iain Er—— te Frame a Ea Bone Hern oT BALES ALCAN ot ces seo Esa Onsen cone si Ho or soma " & ies pe fr ua - Bons aan: [— J— 5 Hn a. [Erp pa. — ws - sm rear scons vi gg pEe——— a mse: 158 " Weve TR +o SPE Seve ST e pares: ane N . = p- map usansiarave or ——— —————— [ep—— [EEereT————— ry Ba “ Ll fo fm— JT Li ly | fo — [E———— « sm = meer seon sss rors oy += Devs oasis con a oe Hi FE fe— memsesie —— oy Fre a * 5 ACA COSA ONS ECC ha ou yoo Simin Bo rms. Tn os a —— fora. pretpon Srv: Ste rec jo oF SEAL 518762 Yn Com As 1 me Flee = S— j= . Re ad jo - Sen a -— = Se pe YH tN RU iid Tam TO—— o— rp— oe Guu | T— Bw Senave: fan | —— Bosiiun gpa fa | S—— =. —. Bonet Eprantts E— |. si ha omer Hom amazon fo. 4 1 NAL SEES GAG iid Huy Hien e Burren ari ssc Jo or BE cose F— PPP —— + arn uses com — So” Ee. te SE ——— on ca J | 2— LTT TT ham—— aera Saute wr Se aa ere wd amcor [— hA.. JO RS en pe Fo b To— Pn A ER. S—— = Bie I i" ter lu ee gs . * —————— egatet : Fd A 5 by f - 1) ak =) of = of x - No : Mh q FE i fl | "5 Ek [4 + ! All “ eA ri - EN ¥ & ¥ Ls ’ rH pan &F JE ra A 2 : wo Sa Yk y AeA ‘ o SC = HOUSE_OVERSIGHT_010715 os a j 4 | z Rd {J ] ” af ’ J \ 4; "+4 / Bh al \ te ir tg a Peggy Siegal’s Oscar Diary ? 8) . a HOUSE_OVERSIGHT_010716 EE — = I = p— a Tw pans 1] |] | $ » iS A se 2 4, , ¥ al wll =, Sl eae | +o Pay mer fy on r BA g oi . his was the year absolutely no one could predict Best sniead taut bilo gabills these Picture for the 86th Academy Awards: nat even me, the [1% Tviieerrs mone Siw one od Oscar witch. This made directors Steve MCQUEEN, rian of buderd profs sake aio ber Alfonso Cuaron and David O. Russell very crazy. After ice mormes The slot re jnded months of screenings, press conferences, IUnches, aNd (owin. who som br wre peon nce parties, publicists and bloggers had to look these three wise Hi masse, soe son vos ordre men in the eye and say, “We don't have a clue” ON Thru he dag, Tt? Th ss Samng wb: the ser dh mi Sn ste David Terman ci mo be pr is ir Li A A PP SR fre eset rvs Toe Ft Tadthun ack ahaciest by Sootng WORE pratt, Cate Tanchets move be rte } Taw. Firs. frag a Prgland, eave the provatior: fas fini wie ~deswad. in Join, Thin § nd cont exact cnn he seer tn Seve Merrie Michael ohender, “Coll th Danie Day Levis des § 3 Cuca mht, vt Plc Deine ted Chimet Toto 41 nbc Sppeanes 1 Puis Pur Ch ls br Sencha § rir von Vous al BC arouse pins tn enbeis eey Amercr. Mathew MeConasghers vesrrerasince § amweinced. DeGeretes then fled sporwor Werrar Broa! sidly sopaler awity wad Cli, Woy cf Wel Sever, and lly 170% & - J. HH = (-4 - oa on To ty re se | - i, X 30 your 200 0 a Fob tn up the regal. Be 1 9 Wye. Tancser ind Opesh Winfrey sre the hat al | I ANY Pru i J. AEE A gd head rst Vie Pa Soil Cle, [oe AE J pop le Vay Tr “utke Td & The toum was crawhrg wh san Se Wed is Casar nig chience, not omy did own porte: aiken 20 yews sgn vs Dorian Erimaet. are Cindy Crawtord wid Rande oF Chor. VMiwwaw whee Vaoup Tar, Willams fin b3 Vivienne Wostwaod # Gober meray I bad ot ors. Grapdon. Conte, snd Tanada Taschen eae” ha md Andie Togn cond Fad = 3 = HRY bn Cusmaes pnéarcr Reber Tran. Tose \ ‘IR Thats where Cheryl Bane Troaca. the Frat b ack \ A. wih a Her re A President Ball Chinon, n tower for the 1 rit, Fi oh 5 Tare ogni , A » tor Tank bey. 7570 he env Ii od Hr — — — —— Fi) =i his 5 how you win an 3a > SCe Jinpoint § FR and connect arn ph 2 7 N screen to an exac = RE. ¢ | esanrt tor hic evens Ve made it ive rarties. 3 i FRE of Sates Woe oo $90.4 ad iy po hormage Dd Ravel, aie mine, © ' {1} incuding hatshat omducer Megan Fllisan, ¥ ly Amy Adams, Sary C70 Michael Tyntan ard fo | WE ap JN | \ y \ (Che Tohn Durham Sows men For, ’ HOUSE_OVERSIGHT_010719 | Al Racine wd Thivid Mamet sca: wédod oc whic is abioms 0 hes “diet far the och aad A 2 Warner Tres’ Fincy priows diver for ds cer the semma sonsimy by amthelognt u A Tullock ord CFO Kevin Tosithara Apu, rain. Tren MG cauler’s rear this up. + iy Sicterat” Gorey tos vvan woah evens r complels wth Tova an Michael Cha. Smarts ry Sik Jone ed 1d is perdi her Tithe Danner and i fr ume, wares tel zw nmin es Wondy Alken he witpdircrs Thea aid Sacha Spielberg, fasd “ate came pac 1 with Suan Stroman an Toaduiy thezrors wih Tere Renrdor, Aden Trody. Tle Yue ANON Sg Se \ An exhaaeé Anse Coankn wis he sn sed Maria Bell pit chopsticks. - LV ee “pest. wich Aten Sheherarade Goldsmith. Aer diner, ve race Gasgins | I ) Tle 38 Fgh a en c snd cor G's wart a get ome, I wt rave, was indy, and | | © hesth wilh Trad. macietin maver Megan hoker nde ores. Srohisreards | Hy Ls Tiel Ai iw rere Masy was star, to have dik “1 with Sconces nd Guarda mhebar FRIDAY, FRRRUARY 28 rR | ‘ brs ler Truce Dern, WIll ok ns thie roaming ar tha oye pueblo seo 1 \ ermpagn, which hoi hegur at Wikhive Thal Jerry Tewis waa receives Robaell Er [6 ts Rom Meyer, vice Dumew. Tanita © omy teecsd ome exe ~~ \ J J TE tates Second Tim lenin, Toc Vito i Smt wer dec or mb 2 dime she, ¥ wit Ronms Clee, Rebert DeNirm, and Samaet 1. Jacko. . LY Magus sttied home xin he Wanda MeDanicl He marceting gry ‘or f Lame Gagan pre hi (7h tae red cape. Tadie Toster was ter rane and. rR pie A | — ll TET = —_— — - vk i NS — . y > ThA - { = / | I never tr Cor overwhelimir L* Zaddy Tom Sturridge’, Lily Coline, Greta dr al ’ vi bee ol ae Rathschild ard rer dractor hushand Sacha and screaming fans. Everything boi Gervari were ir abendirce ss vel a Aber bo ¥/ tals: LYSE WI Le L Tims, Prat. Rese Ofver Stone, Danny down to this moment of mass hysteria. Mum. lan Fig, fen sitserman, Peter ETA They mere hosted by Ari Pmanuel, industry cons Tom Benard, ad Michasl Waltz. crd Tavlar Swift ove Nozio © Kevin Tiorane. sed Nm erkos sn were Darker took pity 1 rae sed imvted re tn stare. Jasan Alexander ind Gary Rar 3 § with Jennifer Aniston. Pew ied Green Ooh Dalahan nd 1 headed to Sie oth My Ca dan hie year me CAEN F Charlize Theron. Sean Penn, fradiey Girk donmirg $20k Chanel Grates wre uded toslant raat antherotaer fal “ed carpets. © Cooper, onoh THI Mexander Payne. reve Anne Mathawsy, Sienna Miler juich baby: Onis his pear, 1 as menzrits wish she dk. © a ~ — - sti hey were conymg tomy house dimer, a” 5 Prag. of exer ree, end sresiming Fons a _- Srweng the antertat ret grin, wb them. - & a campaigning ie over nd you think yo sent % E, 4 — 4 see them. urz | their nev: nave WS like the A A last day 3 carp ’ -y Toni now ave evs aid alone a5 1am Speer Cd y Tiida Queally, te acasle skint Sait [I ep chin and of cree Graton 1h sored kia awd Miley Cyrus. nd spinning secure car ura up is se race as ons Tera Kenneth W. Star. Joe D. Whitley Kirkland & Ellis LLP Alston & Bird LLP 777 South Figuerna Street “The Atlantic Buikfing Ls Angeles, C3. goaa7-3500 050 F Sirset, NW. May 19, 2008 sua pacsivir CONFIDENTIAL Honorable Mark Filip Office of he Deputy Attomey General United States Department oi Justice 950 Pennsylvania Avene, NW Washington, D.C. 20530 Dear Tudge Filip: In His confirmation hearings last fll, Judge Mukasey admirably lifted up the finest traditions of the Department of Justice in assuring the United States Senate, and the American peopl, of bis solemn inten to ensure fairness wd ntegeity in the dministration of justics. Your awn confirmation hearings cchoed that bedrock determination to ase that the Deparment wanduet sell with honor and integrity, cspcially in the enforcement of federal criminal lav We come 10 you in that spirit und respeetfully ask for a review of the federal involvement in a quintessentially stare matter involviag our client, TelTeey Tatein. While we are well avare of the arc instances in which a review of this sort is justified, we are confident thal lhe wireumstances al issue warmaut such an examination. Bascd on our collective experiences, ax well a those of viber former savior Justies Department. officials whese advice we Lave sought, we hae never before seen 1 case more upproprini for oversight and review, Thus, while neither of us has previously made such a request, we Go Sa now in the recognition that both thc Department’ reputation, as well as the due process Hghts af aur efieat, are ul issue. Recently, the Criminal Division concluded a very limited sexiew of tix maller 1 the roquest of US. Atlomcy Alex Acosta. Critically, however, this review deliberately excluded many important aspects of this case. Just his past Friday, on May 16, 2008, we received 2 letrer rom the head af COS informing us thul CEOS had conducted a review of this case. By ifs own admission, the CEOS review was “limited, hath Fecuuslly and legally.” Pert of the self-imposed Limitacion was CHOS’s abstention from addressing our “allegations of professianal misconduct by foderal prosocutors™—cven though such misconduct was, as we contend it is, inextricably intertwined with the eredibiliy of the accusations being made against Mr. Epstein by the United States Attamey’s Office in Miami (“USA”), Morenver, CEOS did nol assess fhe femss of the Defecced Prosecution Agreement aow in effect, nar did CEOS ceview the federal prosecutors’ inappropriate efforts to implement those ters. We detail this point below Honorable Mark Filip May 19, 2008 Puge2 By way of hackgraund, we were informed hy Mr. Aosta thal, ul bis request, CFOS would be conducting a review to determine whether federal prosecution was hoth appropriate aud, in his words. “xr That is not whet oscurred. stead, CEOS has now acknosslodgsd that we had raised “many compelling arguments” agaist the USAQ's suggested “novel application” af Federal Tu in (hin mater. Fen so. CROS concluded, ifs minimalist. shion, that “swe do nod see anything that says to us categorically that a federal case shauld nat he brought” and that the U.S. Atomey “would uot be abusing his prosecutorial discretion should be authorize federal ‘prosscurion of Mr. Epstein” thus delogating back to Mr. Acosta the decision of whather federal ‘prosceution was warranted (emphasis added). Rather (hen assessing whothar proseution would he appropriate, CEOS, using a low haseline for i evaluation, determined ondy thal “il would rot be impossible 10 prove . . * certain allegations made agaiod Mr. Epstsin. The CEOS review failed to address the significant problems involing the appescance of impermissible selectivity that vould necessauily result fom a federal prosceution of Mr. Epstein Wo rospoet CEOS's conclusion that is authority fo seview “misconduel issucs wes precluded by Criminal Division practice. We furlber respect CFOS's view thal i understood its missian us signiticantly limited. Specifically, the contemplated objective was to determine whether the USAQ would be abusiag its discretion by bringing a federal prosecution rather than making ifs own de novo recommendations on the appropriate reach of federal law. However, we respectfully submit thal a full review af all (he Jucts is urgenily needed ul serior levels of the Juste Depuriment, Tn an effort to inform you of the nature of he fedecal investigation apainst Mi. Tpstein, we sucimarize the facts and circumstances of this matter below. he two base-level concerns we hold are that (1 federal prosecution of his mavir is not waared based on the purcly-local conduct and the upreesdenicd ‘spplication of faders] Starutcs to Fels such os these und (2) the sisioms of federal uulhorilies are hoth highly questionable and give rise Lo an unpearunce of substantial impropriety. “The issues that we bave mised, but which have not vet been addressed or sesolved by the Department, ae more than isolated allegations of professional mistakes or misconduct. These issucs, instead, affect the appearance ond administracion of criminal justico with profound consequences beyond the resolution in the matter at hand, « . . Tn n precedent shattering investigation of Jeffrey Epstein that raises important policy ‘questions. and serious issues as to the fair and honorable enforcement of foderal law—tic USAQ in Miami is considering extending federal Jaw beyond the bounds of precedent and season. Feder proseenors sivekhed (he underlying facts in says that raise fundamental questions of busic pro lessionalivm. Perhaps most roubling, the USAQ in Miami, as & condition of deferring prosecation, required a commingling, of substantive federal criminal law with a praposed eivil remedy engiueered in a way that appears intended to profit partsular lawyers in Honorable Merk Filip May 19, 2008 Page private practice in South Flocida with personal relasianships 10 sure of the proseculims imvalved. Federal prosecutors then leaked highly sensitive information about the case ta a New York Times reporter. The immediste result of this confluence of cxtmaordinary circumstances is an omdaught of civil lawsuits, all save anc brought by the First Assistant's former boutique baw fim in Miami. the facts In this case all revolve arownd tie classic site crime of” salicilaion of prostitution? The State Atomey’s Office in Palm Beach County had conducted a diligent insesligation. convened « Grand Jury that returned an indictment, and made a final determination ahaut how Un procesd. That is where, in our fidleral republic, this master should rest, Mr. Epstein faces a felony conviction in state court by via of his conduet and the only resan the State has not resolved this matter is that the federal prosecutors in Miami have condmed to insist that wo, Mr. Epstoin's counscl, approach and demand from the Stato Attomes’s Office ‘unher charge and a more severe punishment thn that Office believes wre appropriate under the circumstances. Yet despite the USAO'S refusal 1 ullow lhe State fo resolve this matter on lhe terns the Sute has deteried are appropriate, the USAQ has not made ang aempt to coordinate its cfforis with the State. In fact, the USAC mandated that any federal agreement would be conditionsd on Mr, Epsicin persuading the Stats 10 seck a criminal punishuncat unlike tha imposed on ober defendants within the jurisdiction of the Ste Allomey for similar conduct Fron the inception of the USA involveanent in this case, which at the end af the day is a case about solicitation of prostitution within the confines of alm Beach County, Florida, we have asked ourselves why the Department of Justice s involved. Regrettably, we arc unable to suggest any appropriate basis for the Deparhnent's involvement, Mr. Epstoin has no crimind history whutsocver, Also, Me. Bpsicin has never been (he subject of general media interest until afew years ago, alien if was widely perceived by the public that he was a clase friend of formes President Bill Clinton. “Ihe conduct at issue is simply nor within the purvicw of foderal jurisdiction aud Lis outside the heartland of the thros federal statutes tha bave been identified by prosccurs—I3 US.C. §§ 1591, 2422(b), und 2423(b). I One ofthe otser membres of Mr, Es defuse ea, Jay Danie, ns perl evinced th reurees’s Sontamporancous acs. 2 Akbongh some of tbe women lisged to be volved sere 16 und 17 years of age, several of ese omer enly mbt bs ying Uo Me, Epstein abot the’ sg. inter roca: wom statcmerts Tonuruble Mark Filip May 19,2008 Paged These stanutes ae intend Lo turgel crimes of n uly national and Internationa? scope. Specifically, § 151 was enacted 10 combat human Gallicking, § 2422 is aimed at sexual ‘predation of minors through the Internet, and § 2423 deals with sex tourist. The malure of these erie resus in multi-jurisdictional problerns that state and local authorities caunct effectively coativn on dreir own. However, Mr. Fpsiein's conduct was purely local in nature and, thus, docs not implicze federal involvement. After researchiog every reporked case brought under 18 USC, §§ 1591, 2422(b), and 2425(b), we found that not a single case involves facts or @ seerio similar to the situacion at hand. Our review of each precedent reflects that there hve been na reported prosecutions under § 1591 of a ‘ohn’ whose conduct with 2 minor lacked force, coercion, or fraud and who seas not profiting from commercial sexual trafficking. ‘There have likewise been no cases undec § 2423(b)—a ime vf communication—whers there was 50 use of the Internet, and where the corrent of phone communications did not contain amy inducing or enting of a minor 10 have legal sexust scrivity as cxpressly required by the language of the State. Furthermore, the Government's conlention thet “routine and habit” can fill the factual and legal void created hy the lack of evidence thal wh a comemunicalion ever occurred sets this ‘case apart thom every reported case brought under § 2422{b). Lastly. there are no reported cases of violations of § 2423(b) of a person whose dominant purpose in traveling was merely 1 80 tu his awn home.” Although ese madters were within the scope of Gre CEOS review, miber than considering whether fedeal prosecution is appropeiate, CEOS only determined that U.S, Atomic Acosta “would not be abusing his prosecutorial discretion should he authorize federal prosceulion” in this case. The “abuse of discretion” standard constitutes an extremely low bar of valuation amd while iL may be appropriate when the consideration of issucs are exclusively factual in nature, thi standund fails 1 address cuncems particular lo this situetion, namely the “navel application” of Tederul statutes, The “abuse of discretion” sundard in such pure legal mateers of stawsory application risks causing a lack of wiformity. The same federal states that would be stretched beyond their bounds in Miami have been limited to their hearcand in each of the other federal disteicts. Also, because this case implicates broader issucs of the admiuistiation of eyusl justice, federal prosecution in (his mutter risks the appearance of selectivity in its Siceiching of Tederal law ta i these facts, 3 Fodural prosoemion of 8 ean who sngeged im coserssal cent i his homs that amontcd a, ct most he limon uf prov:tulion, is unprocalented. Sino prtiion is fdocnually s sole concer, (sc Cried State. vas, 476 F.3d 1176.11 (11 Cie. 2007) feral Ls “docs not crminizs a acs of eosin tc. vie rally gover by sre egulion) , 4 her i 1 evidencs Fi Val: lath Cours avr 3nd Floi<a prosecutors canon SHScivly proces 13d pich the onde, Coes 5 10 reason why dis maz naa be enacted funn ue Funds of sae prosecutors in Flrida, Honorable Mark Filip May 19.2008 Page 5 Tn fact, recsat testimony of several alleged “victimy™ coniradiots claims made by “ederal prosecutors during the negotiations of a deferred prosecution agreement. The consisicar representations of key Gavernment witnesses (such as INN p— EN EE od EE) firm the following critical points: First, thece was na ‘communication, tclophonic or otherwise, thal meets the requiretnents of § 2422(b). For instance, Ma Gonzalez confirmed that Mr, Epstein never emailed, text-messaged, or used any facility of interstate commerce whatsoever, before or after her one (and only) visit to his home, IEEE “Iv. deposition) at 30. Second, the vimen who tostificd admitted! that they ied to Mr. Fpsicin about their age in orcler to gain admittance into his home. Indeed, the women who brought their underage fiends to Mr. Epstein testified that they would counsel their friends to lie abou their ages wr vel, IN stated the following: “1 would tell my girlfriends just like INN approached me. Make sure you elf him you're 18. Well, these girls that T brought, T know that they were 18 07 19 ar 20. And the girls that T didn't know and { don’t know if they were lying, or not, | would say make sure that you tell him you'ro 15.” INS 1rd, there was uo touting or habit of improper communication expressing an lent to transform a massage into an jllezal sexual act, In fact, there vias often no sextal activity al ail during the massege. I rr fied that “[sJometimes [Mr Epsteing just wanted his feel massaged. Somclimes he. Just waited a hack mas.” I I ::o siaicd Gi Mr. Fysicin “never touched [her] physically” und that all she did was “massags[ | his back, his chest and his thighs and thar was ir” protektel Finally, then: was 10 force, coctcion, fraud, violence, drugs, or even alcohol present in connection with Mr. Fpsécin’s crequntars with these ssormen. INN stated that “Mr, Epstein] never tied t force me 10 do anything.” IES Wc 12. These acuounls are fur from the usual testimony in scx slavery, Itesmet stings and sex tourism cases previously brought. The wae in neluslily were not younger than 16, which is the age of consent in most of the 50 states, ard the sex activily wus imeguler and in largo pert, consisied of solo sclf-ploasuring, The recent erop of civil suits brought against Mr. Epstein confirm that the plainills did nol. discuss wy sexlly-reluted activities with anyone prior to arriving at Me. Epstein’s residence. This reinfucces aur cantention That no telephonic or Entcmot persuasion, inducement, enticement or coercion of a minor, or of any atber individual, veeurrsd. Tn addition. Mr, Jeffrey ‘Herman, the former law partner of one of the federal prosecutors invulved in this muller end the aftomey for most of the civil complainaits (as described in decal below), wiss yuote in the Palm euch Post us saying that *it docsn’l matter” that bis clicuts licd about their ages and told Mr. Epstein that they were 18 or 19. Not only is u federal prosecution of this maker umwarreored. but the irregularity of conduct by prosecutors and the unorthodox terms of the deferred prosecution agreement arc beyond any reasonable interpretation of the scope of a prosecutor's respamsibilities. The list af’ impropriclics includes, but is not limited to, the Following fits: Honoris Mak Filip May 19,2008 Page 6 + Mederal prosecutors made the unprecedented demand thaw Mr. Epstcin pay a minizun of $150,000 per person to an unnamed List of women: they referral 10 1 minors and whom they insisted required representation by a guardian ad litem. Mr, Tpuicin's counsol later establistied that ull bul one of these individuals were actually adlis, nal minors. Even then, though demanding payment to the women, the USAQ eventually wssertcd that it could not vouch for the verusity of any of the chairs that these tore might make. * Federal prosecutors made the highly unusual dernind that Mr. Epstein pay the fees of a civil atlomey chosen by the prosecutors w represent. these ulloged “victims” should they chowse lo bring any civil litigarion against hien. They also proposed sending a Retice to the wllegod “victims,” stating, in an underlined sentence, that should they choose their own attomey, Ms. Fpsivin would not be zequired 10 pay Orci fees. The prosceutors further demanded thal Mr. Fpsicin waive his sight to challenge any o the aflogations made by these “victims.” «the Assistant US. Attomey involved in this matter recommended for the civil aitvmey, a highly lucrative position, un individual that we lamer discovered was : clasely wd personally connected 1 the Assistant 11.5. Atiomeys avn boyicnd. + Federal prosecutors represented to Mr, Epstein’s counsel that they had identified {and later rechecked and re-identified) several alleged “victims” of federal urimes that qualified for payment under 18 US.C. §2255, a civil romody designed 10 provide financial benefits to victims. Only through state discovery provisions did we later Team that any of the women 0p the rechecked “victim Ji” could not possibly qualify under §2255, The reason is that they, theonselves, texified that they did not suffer any type of hrm whatsoever, a prerequisite for the civil recovery under § 2255. Moreover, these women wale thal they did not, now ot in the past, vonsider themselves to be victims, + During the lust for months. Mr. Homan, First Assistant Sloman’s former law patter, has filed several civil lawsuits against Mr. Epstein on behalf of the alleged “victims It is our understanding tha cach of Mr. Herman's ofieats ace on the Honorable Mark ilip May 19, 2008 Puge 7 Government's confidential “ist of victims” Most of these lawsuits seek $50 million in money damages. o Assistant US. Atomey David Weinstein spoke sbout the case in great detail to Landon Thomas, a reporter with the New York Times, und revealed confidential information abou fhe Government's allegations against Mr. Epstein. The Assisint USS. Aliamey also revealed the substance of confidential plea negotiztions. + When comsel for Mr. Iipstein campluined uboct lhe media Leaks, First Assistant Sloman responded by asserting that “Mr. Thomas vas given, purseunt to his neque], mon-csi specific snformstion concerning spocific federal statutes.” Based 00 Me. Thins’ comtemporancons noes, that assertion appears fo be false. Tor example, Me. Weinstzin tald Mr. Thomas that federal aullioritics beicved that Mr. Epstein bad lized girls over the telephone and traveled in interstate commerce for (be purpose of engaging in underage sex. Li recounted 1 Mr. Thoms the USA0's teary of prosecution against Mr. Epstein, replete with an analysis of the Key statutes Being considered. Furthermore, nfler Mr, Epstei's defense teas complained about the leak w the USAO, Mr. Weinslein, in Mr, Thomas’ own description, then admonished im for talking Lo the defeme, and gelling im in trouble. Mr. Weinstein further told him not <0 believe the “spin” of Mr. Tpuiein’s “high-priced «tomeys,” and then, according to Mr. Thomas, Mir. Weinstein forcefully “reminded” Mr. Thomas that all prior conversations were merely hypothetical. We are constrained to conclude that the actions of federal affivialy in hiv case ike al he heart of onc of the virally importans, enduring vohnes in this county: the honest enforcement of Tideral law, free of political considerations and free of the wim of personal finaugial motivations on the part of federal prosecutors thet, at 4 minimum, rise the sppearsnce of serious impropriety. We were told by LS. Atiomey Acosta that as part of the review he requested, the Department had the authority, and his consent, ta inake any determination it deemed appraprians regarding this muier, including decision to decline federal prosseution. Yt, CEOS's only camclusion, based um fs limited review of the insestigation, is thal US. Atiomey Acosta would not abase his discretion by proceeding ugainst Mr. Epstein, Thus, the decision of whither 4 us ecently 5 wo moots og, Mr. Sloman was still ised pubic 08 3 pt of Nia formar “a firm. Wha we seams his wis an wearighh, i, Swan's, erica, ae par 6° he fit ices the appeRTaDce oF propia Honorable Mark Filip May 19.2008 Puge § prosecution is fair and appropriate has been placed, ance again, in U.S. Attorney Acost’s In light of the foregoing, we respectfully ask that you review this matter nd discontinue would grealy appreciate the OppOTRITY 10 eet with yan W discuss those imporant issues. Such a meeting would provide the Departeacnt with an opportunity to review the parmouat issues of federalism und the uppeanince of seloctivity thar are generated hy the unprecedented atrompts to broaden the amhit of federal staiutes to places that they have never before resched, We sincerely appreciate your attention ta this maller. Respectiully submitted, AP SL, ii Kenncth W. Starr Toe D. Whilley Kirklund & Ellis LLP Alston & Mid LTP 05/18/08 HON 13:26 FAX 1 213 68D 8500 KIBKLONDARLITS WP Moen ssmasasassssaana ser TX REPORT nes potiherber Te TRANSALSSTON OF TR 0 1953 COMMCTIY TEL 12026140467 SCBADDRESS conxReTION 10 sori 0518 132m USiGE T oi'ss pas. Risiur ox KIRKLAND & ELLIS LLP Fax Transmittal 777 Souta Figueroa Seat “I Please notify ua Inedistay If ny pages ac not recaivad : THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL. MAY BE ATYORNEY-CLIENT PRIVILEGED, MAY CONSTITUTE INSIDE INFORMATION, AND 18 INTENDED ONLY FOR THE USE OF THE ADDRESSEE. UNAUTHORIZED USE, DISCLOSURE OR COPYING IS STRIGTLY PROHIBITED AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY AT: (213) 680-8400. Tor Company: raw Direct: sip Office of tho Deputy Attorney Genoral Honorable Mark FHS 4c Staten Dsparament af fasion | From; Date: Fogmwtonr. Fars: Direct: Kenneth W. Starr May 19, 2008 9 |] I Westage Keancth W. Starr Joe D. Whitley Kirkland & Ellis LLP Alston & Bird LLP 797 Sh Foes Sint Th Adc Bui i i 25 SOF Screen, NW [| a } 3 |’ May 27, 2008 via Facsivice [EN CONFIDENTIAL Honorable Mark Filip Office of the Deputy Attorey General United States Department of Justice 950 Pennsylvania Avenue, NW. Washington, D.C. 20530 Dear Judge Filip: “This letter briefly supplements our priar submission 1 you dsted May 19. 2008. 1a that communication, we urgently requested that your Oflice conduct i independent review of the proposed federal prosecution of ow client, Jeffrey Epstein. ‘Ihe dual reasons for our rust that you review this matter are (i) the bedrock need for integrity in the enforcement af federal crimiual laws, wid (iD) the profound questions raised by the unprecedented extension of feders] law by the United States Attorneys Oftice in Miami (fhe “USAO™) to a promincat public figure who has close tes to former President Clinton. The need for review is now all the more exigent. On Manday. May 19, 2008, First Assistant Jeffrey Sloman of the USA responded to an email from Jay Lefkowitz informing [1.S, Anomey Alex Acosta that we would be seeking your Officc’s roview. Mr. Sloman’s letier, which imposed a deadline of June 2, 2008 tv comply wilh all the forms of the current Non- Proscoution Agreement (the “Agreement”, plus nev unilateral modifications, on pain of being deemed in brench of that Agrocment, appears to have been deliberately designed fo deprive us of an adequate appartunity lo seck vour Office’s review in this mater. ‘The USAG's desire lv foreclose a complete review is understandable, given that the Child Exploitation and Obscenity Section (“CEOS”) has already determined that our xubstuntive agents togarding why a federal prosecution of My. Epstein is uot warranted were “compelling” Howovsr. in contradiction to Mr. Sloman ussertion that CEOS had provided an independent, de mavo teview, CEOS made clear that it did not do so. Indeed, CEOS declined to examine several of the more troubling aspects of the investigation of Mr. Epstein, inchiding the deliberate leak to the New York Times of mmcrous highly confidential wpests of the investigation and negotiations between the parties as well as fh secant crap of civil lawsuits filed agains! Mr. Epstein by Mr. Sloman’s former lav partner. The unncecseery and arbitcarily imposed deadline set by the USAQ vas done withour aay respect for the normal functioning and scheduling of stste judicial matters. 1 requires that Mr. Epstein’s counsel persuade the Stale Atwmey of Palm Beach to issue a criminal information Honorable Mark Filip May 27, 2008 Page? 0 & charge that the Stale Allomey has not, despite a Iwo year investigation, determined be appropriate. Mr. Epstein’s counsel must isa successiuly expedite a plea of guilty © tis charge on a date prior to July 8, 2008, which is the date presently set by the state court Judge. Further, the unnecessary deadline is cven more problematic because Mr. Epstein’s effort to reconcile the stato charge and sentence with the terms of fhe Agreement Tequires an unwsusl and unprecedented threatened application of federal Juv, Thus, it places Mr. Tpstein in fhe Nighy usual position of having to demand that the Stale acquiesce To a more severe punishment than it bad already detecmined was appropriate. We have attempted 10 resolve these and other issues through the USAQ aud CEOS, including raising our conoems about the USAQ’s inappropriate conduct with respect to this matter. But those svemuos have now been shut down. Mr, Sloman’s Jeter purports to prohibic any further contact between Mr. Epstcin’s defense team «nd U.S. Attomey Acosta, and instead requires us 10 communicate with the USAQ ony though Vir, Sloman’s subardinases While it pains 1s to say this, this misguided prosecution from the outset gives the appearance that t may have been politically motivated. Me. Epstein is a highly successful, self- ‘made businessman and philantiuopist who catered the public arcs only by virtue of his close ‘personal association with former President Ril Clinton. There is lite doubt in our minds tha the USAD never wuld have contemplated u prosecution in this: case if Me. Tipsiein sere just another “John” LS. Attorney Acosta previously has stated that he is “sympathetic” to our federalisn- aclated concerns, but he bas taken the position that his authority is limited by enforcement ‘policics sel forth in Washington, D.C. As expressed in our prior communication to you, we hefieve that complete und independent appraisal and resolution of this ease most appropriately sould be undertaken by your Office—heyinning with the rescivsion ul the urhitnury, unbir, snd unprecedented deadline that Mr. Sloman demands to have imposed in his tase. AL the very least, sve would appreciate a tolling of the arbiteary timeline imposed on our client by the USA in order to allow time for your office to cousider our request that yon undertake a review of this cas. Tharik you for your time and atesntion. Respectfully submitted, Kenneth W. Starr 16D. Whilley Kiekland & Ellis LLP “Alston & Bird LL 03/27/2099 12 13 Fax Zoot | se TCORERORT ser PERT san { TRAKSNISSIIN TK THE Ko bess RECIPIENT 4DDSESS s2008100037 SESE TO ST THE zr THE USE rie 7A8Es SENT 5 presi ® KIRKLAND & ELLIS LLP Fax Transmittal #17 Seah Figusron Steet Flas noly is Immadiataly 1 ny pages are ot roceived THE INFORMATION CONTAINED IN TH'S COMMUNICATICN 16 GONFIDENTIAL, MAY ‘SE ATTORNEY-CLIEN| PRIVILCEES, AY CORSTITUTE INSIDE INFORIGATION, 2D 8 INTENDED ONLY FOR THE LSE OF TiE ADDRESSEE. UNAUTHORIZED UST DISCLOSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL IF YOU HAVE RECEIVED TIS COMMUNICATION IN FRROR, PLEASE NOTIFY US IMMEDIATELY AT: (213) 650-400, To: ~ Gomgany. Fax: Direct &: Office of the Diicy Alouncy Genre “From: eater Pagesustonn Fox Dirac 1; Kenneth W. Starr Nay 27. 9008 3 I =—— Case 9:08-v-80726-KAM Document 306 Entercd on FLSD Docket 0210212015 Page 1 ot 19 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TLORIDA Case No. D¥-K0TI6-CIV-MARRAJOHNSON TARE DOF #1 AND TANF DOE: #2, Plaintitts, vs. UNITED STATES OF AMIRICA, Defendant, REPLY IN SUPPORT OF MOTION FOR LIMITED INTERVENTION BY ALAN M. DERSHOWITZ Alan M. Dershowitz here replics in support of his Maton for Limited Intervention (Dk: 282). Prof: Deshowits’s only interest in joining this case is W strike the Fle. sensational and irrelevant allegations against him. In is response {DE 290). the government compellingly st forth the nimy rewons why Tae Toes £3 und #4 requed led over § yes aller the commencement of the CVRA case. should be denied. Jane Dos 52's false allegations asainst Prof. Dsrshowitz wore nol included in ber statment 10 the government, wore nol made 10 the TE when she was initially contacted by thal agency. were not included in hee civil action uainst Epstein in 2009, were not included in bor recorded interview with her attorneys in 2011 and were mo included in her interview with the British press in 2011. These allegations firs appeared in Jane Doc #37 Motion for foindoe in December 2014 {DE 279), and therefore have absolutely ao relevance as Io whather hore was a CVRA violation when Epstein and fhe government exceed the Non-Proseculion Agreement in September 2007. The request foe limited intervention was initiated to give Dershowitz a vaice in the procoedings if and only if the Court allowed the Case 9:08-v-80726-KAM Document 306 Entercd on FLSD Docket 0210212015 Page 2 of 19 Joinder of Jane Die 3 and her untimely allegations t he underlying CVRA case. Tf the Court cefcets the pending motion for joinder (DE 279), then the Court should strike the scurrilous allogations agaiast Dershowitz, of, alvermtively, deteanias the possible mootasss of his Mofion Tor T mites] Tntervention. OF course, if the Court strikes the allegations uguinst him sua pode, Prof. Dershowitz will withdeaw bis notion foc limited intervention. However, if the Court greets Jane Toes #3 und d's motion for joinder, then Prof. Dershowits's mation for Tinted intervention should be granted for such purposcs as may be appropriate including submitting a motion 1 strike or other relisf, sa it 0 give him am apparlumity to defend himsell agains these malicious aod false allsgations. ln Support of his Reply in Support af his Motion for Limited Inervention, Prof, Dsrshowitz sites as follows: Despite swearing under wath ta her falsehoods bout Prof. Tershawits, Tune Doe 3 steupales to justify hor defamations as having any relevance to the issucs in this procecding. Hee Response fo Pro. Dendhonitz’s Motion for Limited Tntervantiom (IF 291) (herin “Respemse®) offers no legitimate ceason for detaming Prot. Dershawitz in her Joinder Mation, and she has io right to cominus to do so in this Court, Strikingly, the Response docs not explain why Jano Doe #3, with un ubvious Financial motive for (brication of salswivus sccusations, waited glist seven years to lob a stink bomb into a proceeding in which she has no nar to partcipare. The Response: docs mes acaund for why Tune Dine #3 never mee nssertedl her accusations shout Prof. ‘Dershowity wntil a month ago, even though the alleged teansgeessions supposedly occured sams fifloon years ago. Although ucither Janz Doo #3 por anyone cise had previously asserted any imprper sexual contact with Prk. Dersowit, naw Jane Doe #3 cynically explsits the yoke of victimhood to victunize others. 2 Case 9:08-v-80726-KAM Document 306 Entercd on FLSD Docket 0210212015 Page 3 of 19 Al bottom, June Toe #3's Response i nothing bu 1 paper-thin pasiche of conspinicy theory and outright misneprescntation that cumbles upon examination. Invocations of the Fifth Amendment by BOUPATY witaessss in Kospouse to innecuans questions about Prof, Dershowitz ame suid 10 take on a “sinister cual™ yet the samme witnesses invoked their ght ugaina sell- incrimination to almost evary question asked of them. icludime their parca’ names. Prof. ershaitz, us pstein's lormer egal counsel, is ane of hundreds of peuple listed in un uddress books pucloincd by Jeffrey Epstein’s erimunal butler, yet because Prof. Dershowitz's name ts circled in the siddrass hak hy an unknown person for known ressams, the argument is made that Peot: Dershowitz ast have sexually abused a minor. The teeord shows that while Peof Dershowitz and Jano Doc #3 are both sparstely mentioned in the flight logs of Mr, Epsicin’s private ple. they are ever listed on the sume fight. Plainly, in tun, falsely cluim tut somehow Prof. Dershowitz single-handedly occhestiated the destiuction of logs without any evidence of ability or pissibilily 10 do xi. The increasingly unfounded awcusarions und insulis ane both sad and irmcspansible. It is precisely this toxic mix of irrclevancy. malicious flschood. and empty accusation Ura ustfies Pro. Delon’ intervention W, at les, scike the allegations gains him. June Dos #3 never had any need to dea Prof. Dershowitz into this action besides to wrongfully use his good mame ami intemational suture to stir up medi interest in her filing. This is impertingace. plain and simple, and it has no place in this Cour. Prot. Dershowitz therefor egos the Court to site allow hin to intervene to strike Jane Doc ¥37s defamatory allegations or deny Tue hie 237% Joiner Motion so he is no longer ufforded the ability to we the docket of this Court to defame athees without being held accountable and strike these allegations trom the. record. Case 9:08-v-80726-KAM Document 306 Entercd on FLSD Docket 0210212015 Page 4 of 19 IL Jane Doe #3's Continued Smears of Prof. Dershowitz Demonstrate Tis Need ta Tntervene Jane Doc #3 and hor counsels actions over the past mouth have confirmed thar Prof. rershawily"s request for intervention Manda upon drmatically different cincumatunces han other intervention motions in this case, or any other ease for that maner. Simply pu, the scope and tenor of their stacks against Prof. Dershowitz die both in degree and in kind from ather reputational mugggings conducted in the vase befare this Court. Nor is there single reported decision in foderal case law in which the vitriol, severity, and length of the artacks agaist 1 monty approach thase levelled uguin Prof. Denhowity here. What hus hecome futher apparent is that of Jans Dos +s Motion for Jainder is granted and Prof. Dershowitz is not allowed a intervens, Jano Dac #3 and her counsel will proceed with their sttseks against him, sll ne more emboldened with complete impunity. While Jane Doc #3 asks to “prove” hr allegations against Prof. Dershowitz. she arpucs punsisxically hat he does mot hve “any direct inlereat® in defending hese allegations. Tose, sho dircers Prot. Dershowitz to defoad the allegations that she makes in a contrived lawsuit filed by her awomeys against him in Broward County Circuit Court for defimation of them. Mareover. the law cited by Proll Dershawils, including te Sockuan und Peniboes anes, demonstrates a nocd and entitlement to intervene to vindicate his legitimate ropurstional interest tht ma other purty is situated to protect. “The individuals righ ta the protection of his avn good name reflects no more than our basie conecpt of essential dignity and worth of every human being — x concept at the rool of any decent sysiom of ardred liberty...” Krineer v. Ftation Holdings. fuc., 975 F.Supp. 2d 1247. 1260 (SD. Tha. 2013: quoting Spencer Koma 523 US. 1, 24 0. § (1995) (Stevens, J, dissenting) a Case 9:08-v-80726-KAM Document 306 Entercd on FLSD Docket 0210212015 Page 5 of 19 Tn an effort 10 ite comirary Tw fs the Cour, Tame Toe #3 Response lakes remarkable liberties in describing what is claimed to be the law ta Court. Foe example, the Respanse quotes Ciliensay v. Westinghouse Elec. Corp, 115 ERD, 75, 74 (MA. Ga, 1957) for the proposition that “witness” interest in lis reputation alone. does not constitute the reyuinal “interest celating to the propurty or transaction which is the subject of the present action” necessary to alli intervention ss a matter of eight.” Vet what bs excised from that quote through the ellipres is the most crucial part of the case: “following a finding by a court thar he is not eredible™ Clits actually smd for the proposition thal wines cannot inlervene in case ws of right the Const has found hit aot credible in one ar its orders. This finding kas never been mods a5 w Prof, Irshowitz cither in this Court, or in hundreds of ethors in which he has appeared, TL. Jane Doe 53's Ties About Prof. Dershowitz. Are Wholly [relevant to This Action Meanwhile, Jane Doc #3 fails to come up with a single credible reason for naming Prof. Thershrsits in her Toinder Malian. First she claims she needed 10 drag Brai. Dershawils"s name. theough the and to prove that Jane Doc 43 was a vietin of sexual abuse by Joffecy Cpstoin. Yet, in hot Joinder Motion, she siafss that “[iJhe Government was wall aware of Jane Dos #3 shen it was negotiating the NPA. ws i listed hee un a victing ins the attachment to the NPA.” (OF 279 at 6) 1 she was already listed as a victim ou the NPA. why would they need to prove that further hy udding puges of severilius allegations against various individuzl? And why did they hive 10 mention Prot. Decshowivz by name. when clsewhers they claim that “namocous. promincar™ individuals so allegedly commited sexual abuse, hut keop those alleged figures anonymous? The had fiith ugainst Prof. Dendowit is apparent’. * Similarly, Jane Doo #3's allceations that sho named Prince Andrew hocauss of outstanding Case 9:08-v-80726-KAM Document 306 Entercd on FLSD Docket 0210212015 Page 6 of 19 Sovand, Time Thao #3 claims that she naded 10 define Prof. Dershowitz and others in the Joinder Motian because of discovery disputes between the goverment and Jane Doc i and Jans Dos #2. Lbs dost uot sven make sense. logally or fcwally. Jane Dos #3 right to joia in this case has nahin to do with June Doe #1 and June Toe 52's entillement ln documents in discovery. In fact, the discovery coquests that Jane Doc £13 cites to in her Response as purported cover foe their sliming of Prof Deshusitz shows hat their snguament is Fuctually bogus, Pro Dershowitz is mentioned in only twa of twenty-five requests for production propounded by Jane Thue #1 amd Tame The #2. (Se Tame The #1 amd Tame Toe #2° First Reqs for Prsduction 10 the Government Regarding Information Relevant to Their Pending Action Canccen [sic] the Crime Victims Act, of DE 225-1 x 20-35) Both requests. nos. 5 and 21 sock his communications with the government in li tole us Me. Tpsiein's defense ullorney. There i 1 issue of complicity or knowladge in any misconduct. Moreover. 3 fact coneniently omincd by Tame Tose #3 bt thal Prof. Diershowily is on oF eleven hwy whos commussications Jane Diss 1 and Jane Doc £2 sought in the sequests for production. As the Couet knows, Prof. Dershawitz had 50 material comnsetion ta this caso—ss 10 the merits or as fo discavery—bofore he was drugged in by June Doe 23. Third. Jane Doc #3 clainis that the smears agauast Prof. Dershowitz are relevant to show Uh Pros. Thershonwils had a motive on negntiaie “confidentiality” und “lank check” provisions discovery requests regarding her beliel Ural Prince Andrews was somehow involved in “lobbying eiforts 10 persuade the Govemment to give im a mare favorable plea arrangement,” and because ter allogations against Prince Andrews occurred in London. therefore “affect/ing| forcign commerce are patently absurd. (DE 291 1120 and 1, fa 10) Because Jane Doc #3 other allegations une replete with ullegations af interdaie aclivily nd hecue implications of Prince Andrews involvernent in “lobbying” for he NPA are entirely morsensical, il is obvious tht the inclusion of claims against Priace Andecw were nchuded solely for theie intended audience: the oncdia 6 Case 9:08-v-80726-KAM Document 306 Entercd on FLSD Docket 0210212015 Page 7 of 19 int the KPA enters] into hewezn the government umd Mr. Fpsiein. Again, this argument makes 10 sense in the context of this case.* The inelusian of certein provisions in the agreement simply has norhing w do with whether the govermenr complicd with its obligations under the Crime Victims! Rights Aut ("CVRA™). TF anything, it is the government's mative that would be ut issue although oven what point is doubrful aor the defines artomeye”. Morcovar, because the first time Jane Doe #3 made thase contempiible llegations against Prof. Dershuswity was in her Motion foe Joindee in December 2014, those allegations. ace irrelevant as to the inguiey of whather Jane Doc #3°s rights under the GVEA were violated at the fime the NEA was caressed, The government confirms that when Tune Tae #3 was contacted by the FIT about this investipation, she clearly “stated that she did not want to be involved in the foderal vestigation.” (IF 290 al 6.3 She was mot “kept in the dark? as she alleges in her Response (DE 293 at 25) Instead, she apparently chose to stey in the dark. Moreover. she did not make any allspations against Prof. Dershowitz at th fimo the NPA was carercd, nor did she made any allegations against Prof. Decshowiv in hee action for civil damages in 2009, nor did she make any allegations against Prof. Dershowitz in hor tape recorded inforview with her attorney in 2011. nor did she make any allegations ugsinst Prof. Dershowitz in her intersiew with the Britis pecs in 2011. he fist time chess allogations surfaced wore in conncetion with Jane Doe #2's tion for Toinder in thix uctian. The allegations have abslutely no relevanee i the underlying issue of whether Jane Dos #3 was “ueated with fairness” when the NPA was catered, as the allegations against Prof, Dershowitz did nat surface until approximately cight years lator. * Prof. Dendiowits, slong with many other Liyers, was insalved in negofiuting the plea bargin under which Gpstein agreed to phiad guilty to StS charges in exchange fo an agreement not to prosceurs him federally. (lowever. he was not involved ia drafting the xt of the NPA. In fact, wo othor lawyers did fh drafting. Case 9:08-v-80726-KAM Document 306 Entercd on FLSD Docket 0210212015 Page 8 of 19 Moreover, if the goverment hud xny resson 1s believe th Prof. Denhowitz was invalved in any criminal activity they would hase immediately demanded his rceusal rather than continuing 0 work with his as onc of Epsioin’s aftorncys in negotiating a plea bugaia, Taunt, Jane The 3 then makes the facially absurd and Tielous chins tut somehow. Prof. Dershowitz must bave drafted and benefited from the “co-conspirators” clause of the NPA. Tht the Tink hetwezn the need to include these allegations and their ability Lo rescind the “co- canspurators™ clause pocs completely uncxplauncd. “The alleparions ace complly grawitous, as there i no such Tink. Kor such alaim existed until fabriested hy Tne Doe #3 ming yam afer the NPA was signed and tally performed. Additionally, as stated in Prof. Deeshowity’s Supplecncnt w his Mofion for Limited tutervetion, this “co-conspirer” provision “was intended fo ply fo four alleged vo-canspiratoes, who were ued in the original NPA and later redated at their request... Alan Dershowitz was never alkped to be a porential co-conspirator.” {DE 285 ard’ j Incredibly, Jane Doc #3°s counsel, Bradley Edwards, agreed with this reading of the NEA in is Statement of Undisputed Tact during bis own personal lawsuit against Jefficy Epstein (giver Epstan v Scorr Roshstein and Bradley J Edwards, lawsuit (Case no. S02009-CA- 0408003) in Pulm Beach County Circuil Court There. Tdwards expluined that these co- conspurtors were corn individuals wha “procured minor femalos to be mokstad by Epstein.” {OR 201-18 a 1 271 Only maw, whan convenient as a way 10 Iry to justify allegations agains! Prot. Dershowiv: docs Gwards argue (on behalf of Jane Doc 3) that the “co-conspirator” provision was actually intended to protect Prof. Dorshowitz. * Moreover, it is unlikely that angone who had sexual contact with Jane Doe 43, or any other minar involved in the Epstein case. would be cunsiderod to be a “co-conspirator.” Instead those dividuals would be substantive perpetrators, not eovceed by the agreconent. x Case 9:08-v-80726-KAM Document 306 Entercd on FLSD Docket 0210212015 Page 9 of 19 Fill, Jame Tae #3 claims that she nosded to fnclule Prof, Dershosity in her Fling because her CVRA claion of “unfair” tecatment “implicates a fact-scasiive equitable defense which must be considorod in the factual const of the cutive infsrface berwesu Epstein, the relevent prosecutorial wtharities and the Feder] offense viclima™ The “faci” © which hit “defense” is sensitive. even of Jane Dos #3 is allowed to intervene, are the interactions between Ue prssecuton und June Doe £3. und not unin pertinent w Prof. Dershowitz: pemonally. Nor are atomey-clicnr communications between Epstein and his counsel at issue. or che propa subject of discovery in this action under any secnario. TL June Doc £3's Efforts to Bolster Ter Lies About Prof. Dershawite Are Remarkably Thin Setting aside the utier irrclevaney of the llogations sgainst Prof. Dershawilz. having encated un intermational imbrogliv by their ill-conceived libels of Pro. Dershowitz, one would expect that Jane Doc #3 would be able to muster at east some credible support for thelr alleguiions. Vet the tsa “incantesisble” fact she Tes with in support wf her clin ta Prof Dershowitz is a serial sex abuser are (1) that Mr. Epstein and Prof. Dershowicz waee friends; and (2 Prof. Dershowitz visited Mr, Epstein’s house, OF sours. these supposedly “incouicsiable™ ucts are evidence of nothing. In the affidavit she submitted to this court, Jane Dos #3's lack of credibility is readily apparent. She hus nis sworn under uth, repeling u fragrant Tie thu she had previously sold is a British newspaper: namely thee “former Pecsicient Bill Clinton was present on the island [efficy Epasin’s privake island] at « time when [Jane Dos #3] was alsa prosent on the iskmd.” (IF 291-1 614 53.) Tn this canily discredited bricution, Jane Doe 13 expounded in inuginative “Iie name of the publication is inforrionally emitted as Jano Dos # 3 reveals her identity v Case 9:08-0v-80736-KAM Document 306 Entored on FLSD Dncket 0210212015 Page 10 ot 18 detail shoul her fietionsl mosting with Former Prosidant Clinton, providing um slshoraie desceiption about haw Me. Clintan and his scceet service detail somehow allowed Ghislaine Massel thea a novice helicopter pilot fo fly al of thom fo Jsfficys Epstein’ privars island on Tipstein’s blu helicupter, us well as details shout the specif: pluce ai the dinner thle at whith she and Mr. Clinton were seared”, Jd. Jane Dac #3 also gave this British newspaper an account of yet unother Fictional meeting on the same islund, but this tine with former vice president Gore and his then wife, "ipper; providing specific devils purportedly rw enhance the value of hee etiam tory: “Thee Cares seemed Ike n beautiful couple when T mel them... Jefiiey [Fpaein] RIE asl me 10 ive him a inassage.... 1 was planning on Vating for hia sehen | turacd 15. 1 thought he was awesome.” On information and belicf; Prof, Dershowitz roproseats fo the Court Unerein. A vopy of the publication, br & Tink Lo the ante, will he provided to the Court at the Court's request “The acticle states, 1 relevant part: “On one oceasion,| Jane Doe #3] adds, Epstein did invite two. ‘voung brunctres to a dinner which he gave on his Caribbean island for Mr. Clinton shortly afer oe Tell office. Tul, us far tt she knows, the ex-President did nol ike he uit, “Td have heen shoul 17 ul the time,’ [Jane Doe 33] sage 1 flew lo the Caribbean with JelTrey und then Ghislaine Maxwell wea to pick up Bill [Clinton] in a fuge black helicopter that Jefticy had bought hr. She'd always wanted to fly and Jefficy paid for her to tak lessons. and | remember she was vary oxeiled becuse she gol her licence around the find year we met 1 used fo got frightened fying wilh her but Hill had the Siem Service with hin und | remember bim lalking shout what a good job she did. | ony wver met Bill twice but Jellrey had told me that they were ood friends. 1 asked, “ow come?" and he laughed and said, “Tle owes ae som favours.” Maybe ho was just joking but it constanrly surprised me that people with as much ta loc as Bill sad [2rines] Abdres weren't more careful. Bill must have known about Jeffreys girs... Wo all ined Iogether thal night. TelTrey ws at the head of the thle. Bil wis at his Tell. T sat across from hin. [1, Ghislaine? horde Thritish woistant, sat at my ight. Ghisluine was at Bills lef and at the left of Ghislaine there were ow alive-skinned bancrtce who'd flown with us from Nov: York. I'd never met them before. I'd say they were no older than 17, very innocent-looking... Maybe Jeilrey thought they would enicrtain Bill, but 1 saw no evidence tht he was interested in them. Fe smd Jeffrey smd Ghislaine seemed 1 huve a very gon relationship. Bill was very funny. Te made me faugh a few times. And he nd JefMrey Ghislaine told blokes jokes and the brunettes lised politely and gigaled. After dinner | gave Jefliey an erotic message. 1 don't ccmeniber secing Bill again on the ip but | assume Ghislaine flex him back.” 10 Case 9:08-0v-80736-KAM Document 306 Entored on FLSD Dncket 0210212015 Page 11 ot 18 that evince will shows that former president Clinton, former vice president Al Gore, ami Tipper Gors never set foor on FEpstin's private island. and that in all events Jane Dog 73's detailed accounts ase uot merely propestorous on thei fice but in fact sutisely Sse and bor swom Stuernent to this cour is perjurious. Indecd. while the poiars mised above show a complete lack of investigation into the enedibility of the sonum making these seurilous allegations’, shat is mos! remarkable bout Jane Doe #3's Response is what it omits. Approsimately six years ago, lane Doc 52 took advantage of the NPA’s provisions, sucd Mr, Epstein and roocived 2 monstary someon. Tronically, Tune Doe 23 now seeks to vertu: the very NPA which veuired Tipstein ls waive his aight to contest liability by moving to jou the tastant action which secks to rescind that very agreement Yet. she apparently never ance mentioned Prof. Deeshiowits s now supposedly systematic sexual abuse of hor fo tho proscoutors of to her own lawyer. Na explanstion is piven for this mouaental inconsistency. Nor, despite his supposed status as a co-conspirator in a scheme to caver up an underage sex abuse ring, is thor any explanation given for the fot that Prof. Dershowily wan never even investigated—or even menfioned—as a potential spect. Meaaehile the prose cass has been proceeding for the last six and a half years, but no explanation hus been given for the timing of Tame Ths #3°s effort ta join this case only last moo “Prof. Dershowitz reserves the right to promptly file a succinee supplement to this Reply bricf with information which be is in the process of confirming pecsently. n Case 9:08-0v-80736-KAM Document 306 Entored on FLSD Dncket 0210212015 Page 12 ot 18 IV. Prof. Dershowitz Immediately Responded to Jane Doe #3 Allegations Against Him by Asking to Defend his Reputation Jang Doc 3 also argues that Prof, Dershowitz should not be allowed ta interven because “he has declined to defend his reputation in other actions” (DF 379, ut 12) This is demonstrably false. It is withont question thar the Motion for Juindse filed by Jans Dos 3 on Dacomber 30, 2014 (DE 279) was tho first time anyono hss ever allogod that Prof. Dershowitz hud any sexual contact with a mina. necessarily Gollows that this is the first opportaaily Prof: Dershowitz has had to defend his reputation related fo “his involvement in Epstein’s offenses.” To fet, just six days aller these venamius allegations were made, Prof. Tiershavits fled his Motion for Limited lucereation. (DE: 282) More spscifieslly, Jane Do #3 srguas that when the civil lawsuit was brought by “anc of the underage Temales agvinst Tpstein in 2009 (Doe v. Kpstaae, No. 9:08-30393-KAM {S.0. la), “Dershowitz understood that counsel for many of Epstein’s victims belicved that mounting evidence painted tsar his role extending beyond merely heing sm sitomey fir Tpsiein ® (DF 2790113) This. too, is demonsteably false. Despite this raak and self-sceving speculation about what Prof. Dershowitz “understood,” there is mot one picee of evidence which points to any allegations that he engeged in any sexual contact with any erinor. or even abserved ung erininal activity, prior fo the Decconber 30. 2014 Motion for Joinder, Insicad, the deposition testimony which Jane The #3 paints lis simply slates that Prof. Dershowitz. visited Fpsiein's home Deposition Testimony of Alticdo Rodeiguer at 199, 278, 279, DI: 291-18. heecin. “Rodeiguez Dipo. 167) Rodviguez specifically wslificd that he has uo idea whether Prof: Dersitawits had any contact at all with way female. 12 Case 9:08-0v-80736-KAM Document 306 Entored on FLSD Dncket 0210212015 Page 13 ot 18 €Q. And did you have smy knowledge of why [Dershawils] wis visiting there? A. No man Q. And do vou have any idea whether or not Mr. Dershowitz was also resciving massages? A Talon anon, Maar. Q. As to whether any of those women were wvee associated with Mr, Dershowitz would it bc a correct statement that you have absolutely no knowledze? A. Ldont know, sir. Q. Okay. Were you in any way uliempling in your response to Ms. Tell imply that Mr. Dershowitz had a massapc by one af these young ladies? A Ldow't know, sir Q. Youhave no kninledge? A. Na. sit (otiigioz Dp. 15 i 279, 200 365. 563 To be sure, Mediipieg docs wily tn peel Toershati/ wus al Tpatein's homme when youn fentales were present ul the home — un allegation which Dershorwiuz stecauousty denice, However, Rodrigues did not testify that Prof. Dershowirz saw, interacted with, or tucked any af these fimules. Tosca, when asked whl Pro. Dershowitz did “while those girls were at the house,” Rodriguez answeeed “Ile will read a book with 3 glss of wing by the pool, stay inside.” (Id. 1.426, 427.1 When asked if Prof. Dershowitz ever even spoke tr umy of the ils, or “even knew that they were there” Rodrigues answered “1 don't know.” (Id. at 427.) [his is consistent wich the face chat Epetcin’s home is very large and Is separate closed-off quarters when: Epstein resided. Prof. Dendunvitz never stepped into these private quactses Jang Dac #3 alsa solics upon the Scpeembar §, 3009 deposition testimony of Mr. Juan Alessi to “conubarate” Tune Doe #3% sensational und fuse ullegutions regarding Prof Dershowitz. However, a mors complete examination of that testimony reveals that Alessi did not muke. any ullegntions of any wrang doing by Dershinvies. (See, TF 291-17, hercinafler 13 Case 9:08-0v-80736-KAM Document 306 Entored on FLSD Dncket 0210212015 Page 14 ot 18 alos Depo. Te) Alessi ested that he saw “momy celebrities” al he house... including] a very famaus Laseyer] | that mn sure you know, Alan Deeshowitz, who spend [sic] at the house a couple fame.” (Alessi Depo. Lr. 70, TL) However, Alessi mads no allegations of improprictics against amy of these individuals, Jane Dow 33 asks the Cour to infer tl becuse Prof Dershowitz was at hus clicat’s home, ke must have pacticipated in nefarious aedfvcics. In fact. rai. Derdhowitz's friendship with Tpstein consisted of the exchumge of academic and intellectual dens. At most, Alessi testified thar eof. Dershowitz visked Epstcins home and recived n massage fram an wall masege therapist, which “wat 4 treat For evershuds® at the Epstein home. (1d. at 74) {*Q. Did | Dershowitz] have massages sometimes when he was theee? A. Yos. A masse was like a tecat for cvorvbody. If they want it, we call the massage and they lve uw mussuge”) Alessi oxpluins that le was refering to massuges. performed by sdull massage thecapists. {1d. at 184) (*Q. All tight. Aad it | understood your testimony is, the oncs he = tha i, of he mse This us you've just disribed [1 hundred, 200 differant massage therapists], you saw some men? A. Yes. Q. You saw more women? A. Yes. Q. And all of the women, at least from your viewpoint, were 15, 19 or older? 4. Yes”) Messin Ales und Rondrigues dill nol allege that Prof. Derowits received 4 massuge from any underage females. had any physical contact whatsoover with any underage females, oe witnosed anyone engaging in umy inspproprisie hehuvior with ny undenge formal Additionally. despite cheie allegations 10 the contrary, it is clear that previous testimony fam Rodriguez and Alessi doss not cotmoborste Jans oo 3's hascloss and utrely false affidavit. mn 2011 7 In fact, the only massage Prof. Dershowitz ever received at any of Lpstein's homes was from a professional massans therapist who was un ber 30°s or 405. u Case 9:08-0v-80736-KAM Document 306 Entored on FLSD Dncket 0210212015 Page 1 nt 18 Next, Jane Doe 3 claims that rof. Thashowits declined to defend his reputalion in the Fidwards v. tpstein lawsuit (Case no. S02009-CA-040800) in Palin Teach County Circuit Cour. (Opp. w0 Min. to lmervsue a6 13.) lu suppet of this allegation, Jac Doe #3 arguss that bse tome in the instmt matter, Tiradley Tiwanls (through his ationey Tack Seurol) contacted Prof. Dershowitz to sock his voluntary cooperation 10 answaring questions about Peo. ershawily's client, Teifrey Fpstein's conduct. Prof, Demhowit respanded by letter stating As you may know, | was Jefticy Epsccin’s attomcy when he submiteed bis guilty plea Accordingly. “any knowledge” | may have in connection with that plea is privilcacs information. 1 you wand lel me knw whal non-privileged information you would seck from me, Twauld then he she to decide whelher ta cooperate. {DE 291-11) Dershorwivr sent a sceond letter an oc about August 29, 2011 explaining that he has “never personally obscrved Jeffrey Epsicin in the prosence of underage females,” and asking awards” attorney Lo provide him with my ulleged basis for his unfounded beliei. Twurd attorney responded by staring thar based on “sworn fostimony and private interviews” he had places] [Dershiwits] in the presence wf Telliey Tpsiein on mulliple occasions... when Tefirey Epstein was in the company of underage females subsequently idearified as victims. (DE: 291 at 13.14) Again, no allegations ware mud 3 thal time hy Edwards’ sulomay, or hy anyon else. that Prof. Dershowit engaged in any inappropriate conduct or witnessed wry inappropriate conduet related to Jetty Epstein and underage femalcs, Instead. Edwards was incorrectly seeking Prof. Dershowits's woaperativn for i civil suit between Dershawils's client, Telirey Epstein, ond Ldwacds himself, Remadsably, because Prof. Decshowitz did aor agece to compromiss his sthical cbligations 10 his slit, by voluntarily cooponting with kpsicin’s 1s Case 9:08-0v-80736-KAM Document 306 Entered on FLSD Dncket 0210212015 Page 16 ot 18 adversiies, fimo Tho #3 urgues that Prof. Dendowits should mot be allowed 1a interven in this action’ Its sloar from the record. however, that Prof. Dirshowitz acted inuncdiately w dead imal the frst nme he seus made aware of uny such allegations against him. Tn fact, just six days atier Jane Doc #3 filed her Motion for Joindor, which included vicious allegations against im, Prof. Dershaswits filed his Viution for Timiled Intervention. (DF 282) Accordingly. Prof. Deeshowity should be peemited 1 intervene for dhe limited purposes af moving to strike these outrageous and impertinent allegations. ¥. June Doc £3's Reliance on Other's Tnvoeation of the Fifth Amendment is Inproper and Whally Uupersuosive. Wilhout a shrd of physical evidence or witness conoboration for Jane Doc #3's Tuasies, she relies. on vocations: of the Filth Amendment by Tsien as supportive of an adverse inference as fo Prof: Dershowitz. Given that Epstein was taking the Fifth Amendment on virtually sll questions, sind sould have responded in the same way hud the ippesite questions been asiied. there i nu inference against Prof. Dershowitz to be anads trom the invocation of the Kifih Amendment by Epacin”. Epseins inlerest ~ in doslining to answer any questions sehatsoever was Tis own personal interest and not that of bis le yers, und lacks even minimal relevance. Coguing Investments v. 1D Bunk, NA. 760 K3d 130, 1310-11 (1h Cie 2014)(udverse inferences (ram the (ih amendment inv ication by third pasties allowed only * Jane Doc £3's argument that he has nut yet scheduled his deposition in this case. or the cently filed defamation action, is of no moment At the appropriate time, Prof. Dershowitz will of course, appear for his deposition and testify that Jane Doc 3° allegations as fo him arc catircly Tabie, This, haveser, hus ms hearing us i whether the Cann Ahould permit the limited intervention Prof. Dershowits seeks. * tad Epstein beco asked about anyone from leading government officials ta membcs ofthe clerey he wold have similacy invokad the Fifth Amendment 16 Case 9:08-0v-80736-KAM Document 306 Entered on FLSD Dncket 0210212015 Page 17 ot 18 where inference is “rustwarihy under all of the ciramskmees” including relationship, shared inteeest and conteol): Kontos v. Koos, 968 T Supp. 400, 407-408 (1997) (no adverse inference allowed from invocation of Fi Amendment by sister of civil defendant in absence of “idsuniry of interests"). Sehustion 1. City of Chicago, 2008 WI, 2%7S25S 233-34 (ND. TL 2008) (m0 adverse wference from invocation of Fifth Amendment in absence of close family or business relaticmshipy. Similarly, any other witesses taking the Till Amendment und remaining silent to pote themselves are obviously not cresting any kind of evidence agaust Prof. Dershowitz See, Conguinas Favesimenss, TO F 3d at 13100 (1 11h Cir. 2013). Conclusion In conclusion, Prof. Dershowitz has no inrersst in joining this case other thu to strike the scurrilous und ireeles unt allegations ugainst him. 0 the Court grunts Tune Des 23 and #4 mation for founder (DE 279). then Prof. Dorshowitz’s moron for limited inrervearion should be ranted for such purposes as may bo appropriate including submitcing 3 motion to stike or arhor rSlict. 50 as 10 give him an opportunity to defend himself againse harmful. defanatory and tals allegations of the worse kind. 1f the Court rejects the pending mation for joinder, then the Court Should strike the scurrilous allegations guint Deshowitz, or, ultermatively. determine the possible mootness of his Motion for Limited Intervention. OF course, if the Court suikss the allegations ngainsi him sa sponie, Prof. Thrshowity will withdrase his motion for limited intervention Respetfully submitted. fr Kendall Coffey Kendall Colley. Fla. Bar No. 259681 kcotlevigzeotieyburlington com Gabriel Groisman, Fla, Bar No. 25644 grvismimdicolTeyburingion, com 7 Case 9:08-0v-80736-KAM Document 306 Entered on FLSD Dncket 0210212015 Page 18 nt 18 Benjamin H. Brodsky, Fla. Bur No. 73743 bbrodsks @oolleybulingon.com COFFEY BURLINGTON, T.L. 2601 South Bayshore Drive, PHI ‘Miami, Florida 33133 Telephone: (30) 836-2000 Tacsimile: (309) 858-5261 - and Ihomss Scot, Fla, Bar No, 149100 thomas scaniesilogl com COLE. SCOTT & KISSANE. PA. Dadeland Centre 11 9130 South Dadcland Boulevard, Suite 1900 Miami. Florida 33156 Telephone: (303 350-5300 Facsimile: (305) 373-2204 Counsel for Prog’ Main 3. Dershovie 1% Case 9:08-0v-80736-KAM Document 306 Entored on FLSD Dncket 0210212015 Page 18 ot 18 1 hereby corify that a rue and cotrocr copy of the foregoing was served by Notice of Flectramic Filing generates] hy CMATCT, an thx 2nd day of February, 2015, un all counsel ox partis of cecord on the Service List below. i Kendall Coffey SERVICE LIST Findley J. Faas Dexter Loe TARMER, JAFFE, WEISSING, A. Marie Villain EDWARDS. FISTOS & LERMAN, P.L. LNITED STATES ATTORNEY'S OTIC 425 North Andrews Asean, Suite 2 5005. Australian Ave. Suite 400 Fort Laudrdals. Florida 33301 Wost Palm Beach, FL 33401 Ielzphone (953) 524-2020 (561) $2011 Tacsimile (954) 524-2622 Tun: (51) RA-R7T7 Tema: brad puthtojustive. com Femi: Dexter. ceigusdey. gov E-mail: ann. marie. villafanaginusdol gov and Arornays for the Government Paul Gi. Case) Pro Hae Fiee S.J. Quinney College of Law atthe University of Lua 5328, 1400 E. Sull Luke City, UT 84112 Teluphone: 801-585-5202 Facsimile: ¥01-585.6833 E-Mail: cassclipiilaw.utah.cdu disney for Jaw Dos £1, 2.3, and 4 ® wn Ya Rai ist Ai ol inn af Psd Savi US Ne onion A Light of a Fierce Fire 5 MORTIER ZUCKERMAN Hoanber 42015 Se —r i ev iP J G1, cd SESE 4 £7 Fn 1 re——— " Svsh cave owing Saul Arabic] and. He I vil 5 ee r.. He alone, at the time, mememeerm= had the capacity to ean, races chen bepeassien on 13 ral di hi di ded Cn. PETSUGAR the ATU fmm anion. qd wary Israelis to Wisconsin (ICCEPE A COMPTONSE. suman ihc Rit ord Aree bes rc mv Posen re orl - BS es rp 4 wan acl a afr Thc tc p51 Fo Weng nt ik i i ST TRAE A Fe RE pas a 0 eae 0 CHAAR. le FA FE tn a pe (9 RE Sn. ak, 5 Lo 4 i A 0 alr [Ep ES EN, cota ye war, Wh co soe oy anh Bs stn i seabo sonis eyo snd PUCKERMAN: Tos Pmt Lin A Flo th ieee Tie de cv ns a l(c 3s Si i, fag de on EAE 00 AA 0H i yc es oo 3 rd ssn ot ons ali, rs ou dir ts Pad 1h cnet of er: fe a A. i sgl Mo ay a 7 oy nl no es fA A HEAT a ATS oa 348 io hn Oe bl a? Th kets i debe ts ch enh sence bse. The docsion = exchange bly capa tombe th ric pac re ha on. vols ean leas ail reco. ae al cis bith by spe mcrly ke saerce of Speco a stangh. hon 1a prog Bn 0 STM 10 hE don [RSE ———————— I Se Ks, 05 GR 1 TE, S50 1 Kab poe pact ke Ho etn i etl Brn wt ed th rin DHE KEE AE. He FTA S640 0 E201 1 8 AT PI A, AY DCO bso nF 8 Cl, rl 1d hal tA ty sn, 0 nro 1010 2 wn BBC, 501 lenge rel ava ha woes crass 20 vote me al bs Peedi Ihc, acm pr: i EC 3 5 bend Clan 5.0 wt vl doy ol yo Th “vf i dS to 1H ke 80 Fy Rabin, The Last Day's Venice Review inform LJ | om ad ots rsa sera, 0 at usu: here Hes Rankings & Consumer vie Sein Erber GA ie oS Se AER 535 A = Filing # 34801581 E-Filed 11:23:2015 05:53:31 PM IN THE CIRCUIT COURT OF IE SEVENTEENTH JUDICIAL CIRCUII, IN AND FOR BROWARD COUNTY. FLORIDA CASE NO.: CACE 134300072 BRADLEY I. EDWARDS and PAUL G. CASSTIL, Plaintiffs, ALAN M. DERSHOWITZ, Defendant. , PLAINTIEES/COUNTERCLALM DEFENDANT EDWARDS AND CASSELL’S RESPONSE TO DERSHOWITZ'S MOTION TQ DETERMINE PhiniifiCounserclsin Defendants Beadle I. Tdwimds snd Baul G. Cassell, by and thiough their undecsigned allomeys, hereby fle this response to Dershowit’s Motion to Ditermin Confidentiadity of Court Recards. The records at issuc arc not confidential, se so the Court sould deny Dezshowits’s wotios in its entirety. ‘The court records at issue are three court tiliags by atiorneys Ldwards und Cassell in which they recite their client's (Mr. Virginis Ginflve’s) allegations that she wos sexually abused by Bershawitz, These records are hardly “confidential” in this defamation case, wherethe parties have chims and counterclaims about these sexual abuse Allegations, Rather, these records are an important part of this ease, since they not any support the conclusion that Dershowitz abused Ms. Giuffre, hut also indisputably establish Edwards and Cassell’ strang basis for fling tie allegations on ber behalf. Moreover, contrary to assertions made in Dershowitz’s motion, these documents have never heen found fo be “confidential” by uny other court, And Dershowitz has repeatedly referred to Evans, Hinde vs. Darsaonic: Caso Noi: CACE (5.066672 Far nd Cals Response 1 Durshoss Macon 10 Deters Confidentiality of Cour Rusords Pago2of20 these documents, not anly in defamatory statements broadcast worklwide, but also in his Pleadings before this Court and in recent depositions. Indeed. Dershowitz said ia his ‘media interviews that he wants “everything to be wade public” aud implied that Edwards and Cassell hud something to hide. Accordingly, Dershavwit has filed 6 carry his heavy burden to justify sealing those presumptively-public documents. 1 DERSHOWITZ HAS NOY JUSTIFIED SEALING ALLEGED DEFAMATORY RECORDS THAT ARF INTEGRAL TO THIS DEFAMATION CASE. In his motion. Dershowitz never recounts the heavy burden that he must cary to seal the records at issu. To he sure, Florida Rule af Tudicial Administration 2.420 allows for the sealing of confidential” materials. But the Rule begins by recounting the overarching principk: that “ijk public shall have acess to all records of the judicial brunch of goverment, except as provided bekin” Flu R. Jud Adin. 2420). “This me is & caditication of the Horde Supreme Court's admonition that a “a strang presumption of epenness sxists for all cour procecdings. A trial is public event, und the fled revords of court proceedings ure publ records suitable for public examination.” Baron v. Florida fvcedom Newspapers. Inc. S31 0.2 113, 118 (Fla. 1988) {ewphasis added). in light of this prosumprion of openness, “{(Jhe bucden of proof in [closure] proceedings shall sivas be an ihe party seeking dosuee” id To obras u sealing order, the party soeking sealing oust carry a “heavy bucden.” It Remarkably, Dershowitz fils 1 acknowledge these well-setded principles. More important, he even fails w cite (much less discuss) the limited substantive exceptionsto this general principle of access aid which specific exception be believes applios 0 this Libvants, Beadle vs, Deshovcte Cesc No. CACK 13400052 Liheaet nd Cassell Resp 10 Desoets olin 10 Deere Confidential of Cour Rssords Page3uf 20 case. Accordingly, it is impossible for Fdwards and Cassell 10 respond with precision to fis mation. “The exceptions that might arguably be in ply in this case port records to be maintined as canfidearial in order to; 0) Prevent useridus und jmminend threat to the fa, impartial, and onderly administration of justice; Gi) Poteet trade seorcts; iy Peotect a compelling governmeneal interest; i) Oboin evidenee 1o deicrmine legal issues in 2 case: (Avoid sobsianiial injury innocent thicd pacties; (v) Avoid sobsiantial injury ta a party by disclosure of matters protected by common Law or privacy right not gencrally inherent in the specific pe of procecding sought fo be closed: (vi) Comply with established public policy sct forth in he Florida or United States Constitution or siautes or Florida rules or case a. Fla R. Jud Admin. 2420(c)9) (codifying the holding in Barron v. Florida Freedom Newspapers, hic.. $31 $0.26 113 (Fla. 1988). Tow only exception hut seems even ueguably apply here is exception vi, which itself specifically provides that confidentiality is appeopriate only where disclosure is “nat generally mere in the specific type of proceeding sought 1b be closed” emphasis added). OF course, (Bis Tawsull & a defunation action involviag adefumaton claim by Wdwards aod Cassell end adefumaion couvercaim by Decshowitz. Disclosure. discussion. and debate sbout the defimmiory statements ut issue lies at fhe bart of the ease. Accordingly. disclosure vf these materials is “inhecent” in the case itself. The principle. that defamatory material in a defamation case cannot be sealed is reengnized in Carnegie v. Tedder, 698 $0.26 1310 (2d DCA 1997). Camogie involved u chim and counterclaim between two pares (Camegie anu Tedder), one af whom atheged that disclosure of Edwards, Bradioy vs. Doshawsty Gave No CACE 15-000072 Foard sn Casells Hespans to Dsshowit's Motion t Dennis Confilendils of Cour Records Pege dor 20 the malericis in the rocomds would be hamid fo his profssional reputation. Carasgie recited subsection vi’ rostiction on rekense of material. involving & privacy right. but noted that “statements Tedder afleged veere defamatory and damagiag were allegations in Cumegi's counterclaim for whick she secks damages. ‘These matters were not pecipheral to the lawsuit: they were inhorent fo it” 4d at 1312. OF course, exaolly the same principle applies here: sexual shuse llegations fled by attorneys Bdvwards and Cassell for thei elim Ms. Virginia Giuffte are not peripheral to this lawsuit — they anc inherent to it Ta ssc how “Jnborent” the sexual abuse allegations are to this lawsuit, the Cot need fook no futher thin Dershowits's counierchim in this case. Count © of Dershowitz Countercluin: (styled as “False Allegations in the Joinder Motion") contends that Edwards and ‘Casselt stiaudd pay him dumiges because they “filed a pleading ie the Federal Action tiled “Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Toinder in Action’... * Dershowitz Counterclaim ut § 4, Dershowitz's Counterclaim then goes on Ib quotc ut fength fom the Joiner Motion. fis counlonTuim contains, for example, this paragraph recavnling the sllegations: The Jainder Motion then gocs on to allege without uny supporiing evidence — as follows: One such powselil individual thal Fpstcin forced then-mainor Jane Dae #3 have sexual selations with was fomer Harvind Law Professor Alan Dershowitz, a close friend of Epstein’s und well-known criinab defense auamcy. Ppsicin required Jane Dos #3 © have sexual relations with Desshwit. on numerous eceusions while she was 3 minor, not anly in Flarida but also on private planes, in New York, New Mexico, and the US. Virgin Beasts, Biadiey vs. Desshowicn Gate No. CACE 1300072 Edad 11d Cores Resp 0 Dero Molin fo Dstrne Confidential of Cot Records Pago 50120 lands. ta addition to being a participunt in the sae of Tie Doc #3 aad other minoes, Dershowitz was an eye-wiliess Go the sexual sbuse of many other winors by Epstein and several of Epstein's cacanspiratass. Dershowits would te play u significant role in negotiating the [Non-Prosecation Agreement] sn Fpuin®s hel. Indeed, Dershowitz helped nogotiate a: agreement that provided immunity from federal prosecution in the Southern Disc of Florida not only to Epsteio, hut also to “any potential cocomspiraions of Epsicin.” Thus. Dershowicz helped negotiate an agreement witha provivien hat provided protection for himself apaiost criminal prosecution in Tlorids for sexually abusing Jan Doc #3. Because this broad imenunity wouldhave been comtraversial if disclosed. Dershowitz (along with ather membes of Epstein’s defense Lem) und the Goverment vied to keep the immunity provision secret from all of Fpuiein’s victims und the general public, even though such secrecy violated the Crime Victims’ Rights Act. Dershowitz Counterehiim at 15 (quoting Joinder Motion at 4), Remarkably, basing quoted al feng Form the onder Motion in bis Counterclaim in this case, Dershowitz now secks to have dat vory same language fom the foinder Malion deemed “cantidential” and sealed. Crimpare Counterclaim ul 115 (Bock quotation nbove) with Motion to Determine Confidentializy, Exhibit A al 4 (composite exhibit with prapased “confidentist® oeument that includes puagraph beginning “fone such powerfu! individuat that Fpsiein forced theninor Tone Doe £3 to have sexs relations with was former Harvard Lu Professor Alan Dershowitz, u close fiend of Epstein's . .. 7). Dershowizz cannot come hefore this Court and file a counlercluim seeking dumnges from Edwards and Cassell foralleged defamitory saemenss and hen ak to hase those very sume sowements placed under wal us “confidential.” See Barron v. Florida Freedom Newspapers. 53% Sod at 119. (althoogh generally protected hy one’s privacy right, medical reports und history are no longer protected Edwards. Brady ve. Dershuvri: Eivats ns Cast Rens n Deshi on o Din Conny of Com cis Pagehor20 when the medical condition hecomes an lategral part of the civil proceeding, pariicularly when thi condision is assersed as an sue by sh persy seeking clossre” (emphasis sdded)). IL JUDGE MARRA'S ORDER IN HIS CASE DOES NOT REQUIRE THAT THE RECORDS BE SEALED IN THIS CASE. Dershowitz also appears ta contend that Judge Marr's order steiking some of the materials from the rocards al issue somehow Toquires at these swickn matkaials be kent confidential in this case. Decstiowiu’s arguraent misundersiands both the scope of Judge Mann's order and ts effect in this case. His argument rests ou a tuncated — and misleading description of the events surrounding Judge Marta's rufing striking certain documents. A more complete descriprion makes clear thac Judge Marra has not deteamined the documents ave somehor “confidential” even in the fderal Crime Vietims' Rights Act cise - much less in this Separate slite defamation action. Edwards and Cassell fled the federal case pro bono on behalf of twa young women who were sexwlly abused as underage: girls by Dershowite's lose personal friend — Jeffrey Epstein. [0 2008, awards and Casell fled a pecition to enforce the rights of “Jace Doe No. 1” and “Jue Doc No. 2" under the Crime Victions” Rights Act (CVRA), 18 U.S.C. § 3771. alleging hat the Government had failed 6 provide tem rights with regard 0 a plea arrangement it vas puning with Epstein. Jone Doe No. | ard Jane Doc Xo. 2 v. United States, No. 9:08-v-80736 (3.0. Flu). Tn the course of that ease, on October 11, 2011. the wists filed discovery requests with the Govemmenl, including requests specifically seeking information about Dershowitz, Proce Andrew, and others. Further efforts fiom the Government to void ay discovery Kauande, Deal vs, Decsborite Case No: CAC 15066072 Twins nd Cavell Response to Dsnowices Motion ts Ditereine Conical of Cour Records Fuge Tor 20 Iollowed (see generally Docket Entey or “DE? 225-1 at 4-5), ulintely leading to u further Court ring in June 20J3 that the Goverment should produce documents. DFE 189. The ‘Government then produced shout 1,500 puges of langely irrelevant materials to the victims (DE 225-1 at 5), whilk sicnulancously submitting 14,825 pages of relevent materials under seal 1a the Coun. ‘the Government aimed that thewe pages were “privileged” for various reasons, itaching an abbreviated privilege log. ‘While these discovery issues wore pending. in the sammee of 2014, Fwards and Cassell, contacted Government coum] 10 request (heir agroemicat to add two additional victims 10 the ease, including Ms. Virginia Giaflie (who was identified in court. pleadings as “Jumo Doc No. 37). Fewards anil Cassell sought to have her added to the ease via stipulation, which would hive avoided the aced to Include any detuled Tics what her abuse. Weeks wear by and the Gavernment as it bad donc ov a similar request for a stipulation t udd another viegm — did not respond 1 counsels reguest fo a stipulation. Finally, on Docawber J0. 2014, despite having had four manths to provide a position, the Gavernent respanded by email o counsel thi it was seeking more time, indicating that the Goverment understood that victims’ counse? aight need © file a mation with fhe court an the mater immodiscely. DE 291 at 3.5. Rather than fite a motion immediazaly, viens” connsel waited and continued Go prs the Governmen: for a stipulation. See id ul 5. Finally. on December 23, 2014 ~ more than four caonuhs afer the nicial request for a stipulated jainder into ihe case — the Government forsely indicarcd its objection, withowul indicating amy reason: “Cur position is that we oppose adding new petitioners ut this Stage of the litigation.” Sew DE 291 ut 5. Edoants. Bradley vs Dense Case No: CACE 15000032 Ewa and Cuceels Response to Dershoit’s Mion to Deering Canfidenliali of Cour Recurds Page Boi 20 Because the Govommonr now contested the joinder motion, Edwards and Casseli prepared a more detsifed pleading explaining the justification for granting the mation. One week after receiving the Government's objection, un December 30. 2014, Ms. Giullre gic. Jane Doc No. 3) snd Jane Doc No. 4 filed a motion (and Tater a correctad wotion) seeking w join the case, DF 279 and DE 280. (Note: DE 280 is the first of the three documents Dershowitz seeks 10 have declared “confidential” in this case.) Uncertain as to the basis for the Gavernment's objection, the motion briefly proffered the circumstances thal would qualify the two Women us “victims” siigibie fo asst tights under the CVRA. See 18 USC. 3771(e) (dolining “crime victim” protected under dhe Act). With regard to Ms. Git. the motion indicated that shen she vais a minor, Jeffcey Epstein had trafficked ber to Dershowitz and Prince Andrew (among others) for sexual purposes. Jane Doe No, 3 stand tha she was prepared fo prove her prafTez, See DE 280 at 3 (If allowed 1 join this acto, Jane Poo No. 3 would prove the following . “The motion also provided sposific reasons why Jane Doe No. 3's participation was relevant to the case, incluing the pending discovary issues regarding Tershawity und Prince Andeew. DE 280 at 9:10 (explaining several ceasons participation of new victims vas refevant (existing issues). After the motion was filed, various news ongenizations published articles about it. Dershowits also made numerous media staroments abou the filing. includiog callioy Tans Doo No. 3 “a serial liar’ who “has lied through ber feeth show many world foders.” bupiroom comi2013101 06 us deshowiiz-sexallepation’. Dershawice alsa repeatedly eollod wards umd Cassel] “two sleazy. professional, disharable buyers.” ki On Lown, Bade vs Dershowicz Sint 20d Css Raps Desig Modo anos Coney o Cost rts Pac0ui Jonny 5. 2015, Dershowaty filed 2 motion 10 intervene lo argue to buve the allegations stricken. DFE 282. Dershowitz also srgued that Ms. Giuffre had not provided a sworn affidavit adtesting (© the trulh of her slgotions, On Jeary 21, 2015, Edwards and Cassell filed a response for Ms. Giufire and Tune Doe No. 4. IDF 291. (Note: This js the second of the three dasuments Mershovitz seeks to have Sept under seal here) The response enumersiel ain specific reasons why Ms. Giufire's specific allegations sgainst irshowitz were relevant to the vase. including the fact that Ms. Giuffre needed 10 estublish thaw she was a “victim” in the cese. that pending discavery requests conserming Dershowite-specific documents were pending, and ‘that Dershowitz’s roie as 2 defense ullomey in the cuse wis highly relevant ta the motive for the Gavernment and defense counsel to conceal the plea deal from the victims. DI 291 al 17.26 & 17. The respunse included o detiled sfiduvit fiom Ms. Gingfre about the sexual abuse she had suffered from Epstein, Dershowitz, and other powerful persons. DE 201-1. On Febuary 6. 2015, Edwards and Cassell filed a further pleading {and affidavit from Ms. Giuflre, see DF 291- 1) in support of her motion t@ intervene. (Note: Ihis uffidsvit is the third of the these documents Dershowitz seeks to have declared confidential) On April 7, 2015, Judge Marra denied Ms. Giudike's mation to join the case. Judge Marea concluded that “at chis juncture in Lhe proceedings” details about the sexual buse she had suffered wes unnecessary to making a determination “of whether Jane Doe 3 and Jane Doe 4 “ould be permitied to join [ihe wher vietims"] clsim that the Government violated thei sights under the CVRA. The 12ctual defuils regarding with whom and where the Jane Does engaged in scxunl activities are impertioent to this central claim (ic, that they were know victims of Mr. Fors, tral vs Dershouie Case No: CACE 5000072 Ftsanls nl Gres Response to Dershowets Mason a steno Conldentsity of Court Records Page 105F20 Twin and the Goverment owed them CVRA dalies), especially considering that the details involve nan-prties who are not related to the respondent Govemment.” DF 324 at 5 (cmphasis in originali. While Judge Mima struck those allegations, ho emphasized thu “Jane Doe 3 is free reassert hese faernal details through proper evidentiary proof. should the victians) demonstrate a good faith bugis for believing that such details are pertinent ko u matler prescrited. for the Cours consideration. Judge Vises then denied Ms. Giugire's mation to join the case, bat alowed her fo participate as wial witaess: “The necessary participation” of [Ms. Giufre] . in this cass can be saisfied by offering .. . properly supported — and relevr, wdmissible, aud non-culitive ~ testimony as needed, whelher hough festimony at tial . . . or fidavily sapported in support fof} the relevancy of discovery reuesis” DE 324 at 8 (emphasis deleted). Ln a sapplemental order, Judge Mara stated thac the vietims “Tony re-reile these documents omitting the sicken portions.” DE! 325. The victims have recently retiled the documents. Tn light of this history. Dershowiu is flully incorrect when be asserts that “Judge Marra’s Order appropriately precludes the wredacted documents from being re-filed in this case on the public docket” Conlidentiality Motion at 3, To the contrary, the Order specifically permits. fuctual details about Decshowite’s sexual ubuse of Ms. Giuffte to be presented ia regard fa pertinent malicrs in the federal CFA case. And certainly nothing in Judie Maria's Onder coald render those docoments confidential in this stare defamation case, where the central issues seirl around Fabwards and Casscll’s good faith basis for filing the allegations. Indeed. the order is not binding in any way in his case, because it is ccs judicata only os to Ms. Giuflre (the moving Eduazes Bradley vs Dershowitz Case No’: CACHE 15000072 EE Cans oe 0S MS DS CA af Con es party in dhat case), not as to her attomeys Edwands and Cassell, See Palm AEC Holdings, be: v. Palnr Beach Covnty, 807 $0.24 703 (4% DC'A 2002) (“In order lor res judicata 1 apply Tour ideaities must be present: (1) entity of the thing sued for: (2) identity of the cause of action: (3) idensity of persons and partios; and (4) identity of tho quit or cupecily of tre parsons for or against who the elaim is made. TL EDWARDS AND CASSELL WILL BF, PREJUDICED [F THEY ARE BARRED FROM QUOTING FROM THT, RECORD WHILE DERSHOWIIZ IS PERMITTED ‘10 FREELY REFER TO TBEM WHENEVER HE FINDS IT CONVENIENT, Dershonwits is als incor! when he sents that no peejudice will betal! Edwards and Cassa if the records am placed uuder seal. To the contrary, plaing the docurnents under sal would permit Dershowils to continue to miscepresent and distort what is contained in those records while preventing Hdwads and Cassell from conrosting those muisceprescntations, Dershowite ns repeatedly refered 1 details in the reconls when he bias found it conserient 1 da sn — eating the records 65 not confidential in any away. One clear example comes from Denshowicz’s seceat deposition, where he grarutousty injected into the record u reference to & portion of Ms. Giuflie's alfidavit shoot him walching Ms. Giuilre perform oral sx on Tipstein. Aad then, having injecied that gratuitous relerence into the second. he proceedod to try to tobi the reference with confidntial settfement discussions —but did sa by misprescutiag shat anther atiamey (David Pies) had said during the seulement discussions. So that the Cot may bave the full flavor of the cxchacge, the narrow question to Dershowitz (by attorney Jack Edwards. Bredicy vs. Dershowitz Cae No: CAGE 1.900072 Edwaris and Ceseclls Respors to Dershoni2's Motion to Determine Confidensialicy of Coun Itscants Page 120170 Scarola) and Dershowitz’s extended answer are quoted in full including Desshowitz’s reference to th oral scx allegation that he mow argues this Court should troat as “conficeatial™ Q [Vou lure aware thut sears before December of 2054, when the CVRA pleading was flzd, thal your nme hud come up repeatedly in coneetion with feflreg Fpstein’s tbuse of minors, correat? A. Let me answer thar question. J am aware that never before 2014, end of Decsmier, wie it ever. ever alleged tha hud acted in uny way ineppropriatcly with regird to Virginin {Giuflze], ha 1 ever touched her, thal 1 ever met ler, that Thad eve been with her. | was completely aware oftaat Fhere lad never been any allegation. She clairns under oat that she told you that secretly m 2011, but you have produced no notes of any such conversation. You, of course, anes witness fo this aleygtion and will be deposed 0 witness Lo this allegation. | believe it is wn entirely false allegation that she told you in 2011 that she had had any sexual contact with me. | think she’s lying through her teeth when she says thar. And 1 doubt that your uotes will reveal any such information. RULE she did tell you thet, she would be shsolutely, calegorically ying. $01 am completely aware that never, uti} the fics were put in a leaol pleading at the end of December 2014. it was never allogad that had any sexual contact wich Virginia Roberts. Tknow that it was allcgod that T was a wiltess to Jeffrey Psicin's alieged abuse and that was false. | was never a witness t uny of Jeffrey Epstein’ sexual abuse. And | wrote hat 10 you, something thar you have falsely denied. And | stan on the record. Fhe recon is clear thar | have categorically denied I was ever a wimess fo any sbuse, that [ever saw Jofliey Epstein adusing anybody. And — and the very idea that 1'would stoned and talk 10 Jeffrey: Epstein while he was receiving oral sex from Virginia Roberts, which she $10ro 10 under oath. is $0 OL REO, 50 PFOPSIETOLS. that even Dovid Boies sail he couldn’s beficve if was trie. MS. MeCAWLEY: | object. I object, Tm not going o allow you (a reveal uny comveesalions that huppened in the cox ofa szclemeat discussion. THE WITNESS; Does she have standing? Edad, nce vs, Deslunetc Cesc No: CACE 15-0007 Fitts und Cassels Response to Desshornice's Motion Deter Confidentisiy of Cost Recurcs Pee 13.0720 MS. McCAWLEY: I have a standing objection and, Vim objecting again. lm nal going i THE WITNESS: Noy, no, mir. Does she have steading in this deposition? MR. SCOTT: Let's take a brcak for a mise, okay? LTE WITNESS: Fm ot sure she bas standing. ME. SCAROLA: Ate we finished with the speech? MR. SCOTT: No. the MR. SCAROLA: Td like im Io finish the spec so that we can getto my question and then we can take a break A. So the question — the answer to your question is MR. SIMPSON: Wait a rinute. Wail a inutc. Wait a minute, Please dont disclose something that she hus right 1o raise that objection if she wis MR. SCOTT: Tally. Deposition of Alen Dershowity (Oc 15, 2015) al 93-05 Gutiached as Exhibit 1; see also Deposition of Alan Dershowitz (Oct. 16. 2136) (ullached as Tixhibit 2) (also containing discussion of Ms, Giuffe’s atfidavi. The Court should he aware that within approximately two hours af this exchange, Ms. MeCawley. (David Boles” law partner) released u sualement vn bis hehalf, which stated that Dershowitz was misrepresenting what happened: “Because the discussions that Mr. Boies had with Mr. Deshawit, wore expressly privileged seatiement discussions, Ms. Boies will no. at least at this time, describe what wus actually said. Flowever, Mr. Boies docs state That Mr. Edwards Brady vs. Desshonsz Case Ne: CACE 15000072 Edwards wd Canclls Respono in Dershowis's Motion w Desonnine Conley uf Cour Revords Page 3 0i20 Dershowitz description of what wis aid is nol rue.” Statement of Vis. McCawley on Bebilf of David Bois (Oct. 1, 2015). More broudly, the Coust ca readily see from this passage how Dershowit is willing tn mject into he record a part of Ms. Ciiudtee's affidavit whenever it serves: his purpose - and indeed. to charsctctize the part of the affidavit as “preposterous.” Bud then he asks this Court to place the undaalying alidyit imder seul, so that the Edwards and Cassell stand acoused having filed a “preposterous” atfidavit without anyone being able 10 assess the validity of Dershowits’s aac. Persone: has referred 10 the court recurs lat he now wishes 10 have the Court delim: confidential cot only in his deposition, but alzo in his widely-broadcast media attacks on Tidwards wad Cusell. For example, Pershawity appesred an the Briish Broadcasting Corporation (the BIC) and was asked about the allegations: Well, fist of all they wore made in court papers that they don't even ask for a hearing fot to prove them. They pat thom in con papers in order to fmmanize themselves from any consequences liom u defematian sit. The story is tolally pide. ap, completely out of whole clith. F dont know this woman. 1 was not at the places a the times. 1 is past of # pattern of made up stories against prominent people and world leaders. And the lawyers in recent statement challenged me to deny the allegations under oach. { 2m doing that. | am doyiog them under aath, Hus subjecting me to # perjury prosecution were Tot telling the truth. 7 am now challenging: Gem to have their client pt thes charges wider oath und for the to put the ander oath. 1 tah also challenging the to repeac them outside ofthe context of court papers so that I can suc theo for defamation... And wil prove beyond any doubt na only that the story fs totally alse, buf it was Knowingly false: thal the bawyers and the client conspired iogether to create a five story. That is why Lam moving far their disbarment in ¢halleriges 16 be provided fo the disciplinary commie. BEC Radio 4 - Sarah Moniague (Jan. 3, 2012) (hwpifiswur: bho.colprogrammesinQ2gTghe). Edwards, Brey vs. Dusshavri Case Noi: CACE (5000072 Edvard ond Cael Respanss to Destaset's Motion 1 Deternize Conti of Cou Records Pat 150020 Similarly, Dershowicz appeared on NBC's Tog Show the moming adler Dd vwards wd ‘Cassell made a filing for Ms. Giuffre, 10 3ay that the Edwards and Cassell — and VIS. Giuflre were all “lying” in the court documents: Question from Savannah Gathrie: J Tegal papers from the ayers, hey say you's bad, in fact, the appartunity to be depsed. Answer from Alan Dershowitz: They're lying. “They ee lying. Question: They show letters in which they offered to depose you. Answer: And they did't show my leters in respanse saying, (a), If ou ask me hoot my legal relationship with Fpvstcin and PL] be happy to answer... And L responded thu 1 would be happy 10 be deposed if you could give me any indicasion that ! would he a relevant witness... They will he proved — ll of them [1.c., Cassell, Edwards. snd Ms. Glugtie| to be caeyoncalry yg snd making up thie lors. And it will bea terrible thing for rape victims... We [Epstein and Dershowitz] hed sn acadernic relationship, } was never in the presence of a single. young, soderaged woman, When 1 was with hin, it was with prominent scientists. prominent academics. And they're just — sgn ~ ying about this. 1 never saw him doing. anything improper. Tas not a participant. Twas nol u witness. Today Show, Jan. 22, 2015 (emphases added). As auother example, in Miami Jerald, Dershowitz called the Joinder Motion that he sceks to have sealed “the sleaziest lega document} lute ever seam. They [Tdwards and Cussefl] runipstuled a young, suggesliok: womso who was farerested in money. This is a disbausable offase, and they will he disbarred. They wil ruc the day they over made this false charge against me” ~ Le. Edwards and Cassell will “rus lhe day” they ever fled the Joindor Motion. Mini Herald (Jan. 3, 2015). Eduard, Brady va. Dershowi Cane Nol: CACE (5.00002 Edwards and Cascell Response lo Dershawi 's Mosion us Determine Confdantislicy of Cour: Records Page 160020 Most remarkably, Dershowitz taak the public sirwaves a represent that he wated all of the information surrounding the allegarians to “oe made public.” while implying that Edveards and Casscll hd something to hide. For example. on the BRC he claimed tht he wanted every hing 10 be rude public”: Q Would you encourage that it now be mud public? Ai OF course. of course. | want everyihing fo be wade public. 1 warm every Bit of evidence in this case to be made public. 1 want every alfegatton to be made public. | vent 10 know who clse she’s aceused of thes: homible crimes. Ws know that sbe accused Bill Clinton of being on Jefficy Epstcin’s isleud und participating in sex orgy with underuge girls. The records of the Sexaet Servic will prove that President Clinton neve sel foal on that island. So hat she Tied. Naw its possible to have u case of mistaken identification with sooebody like me. Is impossible to have a case of mistaken idcuification with Bill Clinton. My only focling is thw if she bas liod abo me, which I know 10 am shsolute cerlyinty she hus, she should not he helieved about anyone else. She's lied clearly shout me, she's fied clearly zbout Bil Clinton. We kpow thar. We know that she's licd about other public figures, including » forme prin winister und others who she claims to have parCcipated in scx] activities with, So T hiok it must be presumed hat ll of her allegations against Prince Andrew are false a3 well think he [Prince Andres] should clear the 2ir a3 well 1 jou'te squeaky clean and if you have never done anything lie this. you must fight back with all the resources available to you. And that's what I will do. J will not rest or stop uniil the world understands no only that 1 ad nothing to do with any of thi, but thal she defiherely, with the connivance of her Tawyer, lawyers, male up this sory willfully and Tnowingly. BBC Radio 4 - Sarah Montague (Jan. 3, 2015) (spies bbe, so ukiprogromies pa Tubs). In another widely-broudeast interview on CNN, Dershowitz implied that these is no evidence supporting the zleytions 2gatnst bi: ibrar, Truly vs, Dershurete Case No: CACE 13.000072 Lihat nd Cassels Nespas vo Deshi Motion 1 Denis Confident of Cour Records Page 170120 Ask the [Ecwards and Cassell] if they have en evidence .... They're doing it for ‘municy. Shes gelling money for having sold her stay, She wants to sell the book. They're trying Lo get Into ihis lawsuit. They sce 4 pot of gid at the ond of he rainbow. They're [idwands and Cassell prepared t le, cheat and steal. These sre nncthical lawyers. his is Professor Cassell who shoulds’t be allowed near a student, This is Professor Cassell, who is a former federal judze, thank God be uo longer wars & robe, He is cssomdally a crook. He is csseatially somebody who's distorted the legal profession. . . Why would he chuge x person with a Sterling repulaticn for SO years an the basis of the word aloe oF u soma wh is serial Jiar, who has lied about former Prime Ministers, former Presidents, hus lied demonstrably. CNX Live ficih Hala Goran) (January 5, 2615). Of corse. by placing “the evidence” inthis case under seal, Dershowits will be free to coninue io ry and msinwaie that Edward and Cassell — ara thelr client, Mv. Ginffre ~ had io evidence supporting the allogsions agains: Fim, ever sungh a mouain evidence strongly suppord Ms. Gifies aliegadians. See Depuituon of Paul Cassell fer. 16. 2015) an 61-117 (Exhibit 37; see ais Depo of Pal Cassel] (Oct. 17, 2045) (Fishibir 4), CONCLUSION “The Court should deny Defendant Counterclaien Planiff tau Dershowitz’ motion to place documents regarding Ms. Giaflre's sllcgations against him under sca]. THEREBY CERTIFY that a true and correct copy of the foregoing was sent via B-Serve 10 all Counsel 00 the artached list. this ___ 237% _ _ day of November, 2015. 0 Fuck Seana } Jack Seerola Florida Bar No: 169440 Anomey E-Maills): jexd@isearcvlaw com and mepdseanylav.con Primary F-Viail: strom isearyla cor Searcy Denney Scorola Barnhart & Shipley. PA. 2139 Palm: Beach Lakes Boulevard Set Palin Beach, Florida 33409 Phonei;S61) 635-6300 Fux{561) 382-9451 Fant, abe vs. Decsaovcz Case Noi: CACE 15.0002 Fans ud Cassell Response to Dershowits Maton termi Coalideatiality of Coust Records Pago 18 of 20 SEAND. REYES Utah Attomey General By: JONTJ, JONES JOTL A, FERRE Assistant Utsh Aflomeys General Bradley J. Eacads FARMER. SAREE, WOISSING, TDWARDS, FISTOS & LEHRMAN, P| 425 North Andvows Avenue, Suite 2 Fort Lauderdal, Floridu 33301 Telephoue (9541 524-2820 Frcsimile (954) £24.2877 T-msil: brad @peintojustics com Aud Paul G, Cassell Pro Hac Vice Motion Pending $1. Quincy Coliegs of Law at the Universiiy of Utah 383 8. University SL Salt Lake City, UT 3112 Telephone: 801-345-5202 Facsionile:$0-585-6833 1-Mailcusselipihos, vigh edu Attorneys for Plaindifis Bradley J. Fdwands snd Paul G. Cassel COUNSEL LIST thomas merson Seo, Jr, squire ‘Thomas.sconiesilegal. com: Steven suliadicskleyat. com Cole Scoll & Kisstac PA. 9150 § Dadcland Boulovard, Suite 1400 Mian, FI. 33156 Edwards Bradley ws. Deane Ge No: CACE 1.600072 Baad snd Camels Reszonse bo Dreshowins Motion to Decne Confident uf Count Resonls Page 190720 Phone; (305-350-5320 Fax: (305)-373.2204 Atomeys tar Defendunt Richard A, Simpson (pro bac vice) singon@uissineon Mary F. Barjo (pro hae vice) bor Gilevreincon Ashley E. Filer {pro hac vice) aileri@wileviein.com WILEY REIN LLP 1776 K SL NW Washington, XC 20006 ‘Phone: (202) 719.7000 Fac: (202) 719-7038 Liwars, Bradiey vs. Dershonit: Cae No: CAC 13000072 Edvard nd Cael Response Dawes Molo | Drmine Congest of Co Resor Page M0 of COUNSEL LIST Sigrd Sone McCawley, Bsquire smccawley@hallip. com: Ashley tiler, Esquire sperkinn@bstip.com: leservedbsilp.com AEiler@wileyrein com Eoics Schiller & Flexner, T.1.P Mary E. Borja, Esquire 401 E Las Olos Boulevard. Suite 1200 MBorjuiwileyrein. com Tort Lauderdale, FL 33301 Richa] A. Sioopson. Esquire Phone: (954-336-0011 RSimpsan@wileyrein wim Attorneys for Alan Vl Dershowitz, Esquire Witey Rein, LL 1776 K Street NW ‘Thomas Emersen Soc, Jr, Fquire Washiagtos, DC 206 Thowas soot oskleal com; Phone: (202)-719-0252F ax: (202-719-7049 Steven safiafiicsklogal.com: Auomeys for Alan M. Drshorsitz, Esquire Renee. nuilgcsklegal, com: shelly zambe:@eshlegal.com Jou J. Jones, Lsquire Cole Seon & Kissane PA. jomijonssfiutah gov 9150'S Dadcland Boulevard. Suite 144 Aswistant Utah Allomey Geners? Mini, TF, 33156 JGHE 3008 Phone: (05)-350-$120/Fax; (305)473-2004 Sale Lake City, UT 44114 Attorneys for Alun M.Dembowitz, Esquire Phonc: (801)-366-UKiFax: (801)-366-011 Attonucys for Paul Cassell Bradley J, Edwards, Esquire silloFlo@patitojustice.com: hrud@piahtojantice. com, maria @ puhtojostice. com Famer Jalle Welssing 1:dwirds Fistos & Leluman, PL. 425 Andrews Avouve, Suite 2 Fart Lauderdale, FL 33301 Phone: (454)-524-2820 Tax: (954)-524-2822 Attorneys for Afar M. Dershowitz, Fixuire Kennsth A. Sweder, Esquire Kswederswveder-ross com Sweder & Rows. TIP 131 Oliver Street Bastou. MA 02110 Phone: (617-646-466 Fax: (61736464470 Attomeys for Alan M. Dershowitz, bsquice IN THE CIRCUIN COURZ OF THE SEVEWIEENTH JUDTCTAL CIRCUIT IN BAC FOR BROWARD COUNTY, FLORTIR CASE WO.: CAC 1S-000072 LRADLLY J. EDNBEDS ang 230L G cagsELL, , Plainzisfs, vs RIAN M. DFRSHOWITZ, Defendant. i A VILEGTASE DHEOSTLION OF LAN ¥. DRRSROATTZ VOLUME © Pages 1 Lncough 173 Thursday, Gstebar 1S, 2018 £031 am. — 4:13 pom. Cols Scout & Kissane 110 Southeast 6th Street Fort Lauderdale, Florida Stersqraphically Reported By: Soaberly Fonizlvo, RR, CIR Realtime Systems hoministrator 3 L poopie that abused virginiz? 2 A. I told yea I nover asked her the guessien. 11:36:21 : Q. Are you aware thal yeazs befoze Decetner 11:26:48 4 of 2004, when Lhe CVA pleading was filed, thal your 5 name hed come vp repeazediy ia connection with § Jaffray Eostein's abuse of minors, correct? i MR. SCOTT: Objeciica, fom, Overly broad. 11:37:16 5 A. Zel ne answer That questien. I am awsze FIRES 9 that never before 014, end ol Decorber, waa ii 10 ever, ever alleged that T had acted in any way 11 insppropriately with regazd to virginia Keberts, 12 that I ever Leuched her, that T ever ket hex, that © 13 hed ever baen with hee. I was completely aware of 14 thal. fhere Rad neve: beca any allegation 1% She clains under oath tha: she sole you 11:33:48 16 that sscresly in 2811, bul you have prodiced ne 17 aotes of any sven conversation. You, of course, are 18 a witreas zo this allegazicn and will be deposed as 12 a witness Zo this allegavicn. 1 believe it is an 20 entirely false slleallor taat sae told you in 2811 71 that she had had any sexusi contucl with me. I 22 think sae’s lying thicush her Teeth when she says 22 that. Aud I debt that your moles will seveal any 24 such informaticn. 2 But if sho aid tell you that, she would be 11:38:24 54 1 ebsolulely, categorically Lying. So T am completely 2 aware tact never, until the lis ware put in go legal 3 oleacing al the ead of December 2014, it vas never 4 alleged that I Fad any sexsal contact wilh virglala 5 Robercs. 6 1 know shat it was ellsged thet [ was o 12:30:46 7 wilness Lo Jelf:ey Epstein's alleged asuse and thas § was false. I was never a wilness lo any of Jeffrey a fpatein'a sexual abuse. And I wrote tAIT to yom, 10 sometaing that you have falsely denied. Aud I stand 17 on the record. Tae record le clear shar T have 12 categoricaly cemiad I wus evar a witncss to any 13 cbuse, Lhat i eve: saw Jeffrey Fpstein abuslug 1¢ anyoody. I] Bnd + and the very idee that & womid 15:39:18 5 stand ard talk To Joffrey Fpatein while he wis 17 receiving oral sax frum virglala Roberts, which she 18 swere Lo under oash, is 30 outragecus, ac 13 prepostersus, thal even David Soles said he couldn't 20 oelieve ii was true. 21 VS. VECMULEY: I object. i obiect. I'm 11:35:43 22 net going to llow you To reveal any 23 conversazions that happened in the contex: of a 24 selllenent discission. 23 TUE WITNFSS: Does she hove standing? 11:33:46 as i WE. MCCAWLEY: I have 2 standing objection 11:39:43 2 ang, I'w gbjecting again. I'm ros going to -—- 3 | THE WITNESS: No, 40, no. Does sho havo 11:39:49 4 atending Ln his deposition? 5 HR. SCOIT: let's -ake a break for a 1:39:51 6 xinule, okay? ¥ THE WI™MESS: I'm nol sure she ras 17:39:54 a standing. EH NR. SCRROLE: Are ve [inished witha the 11:39:57 ie speech? 1 MR. SCOTT: Ne. Lf ac —- 11:20:58 E HX. SCRROLA: T'd like hix Lo fliaish Lie 11:33:59 2 speech so Lhas we can get to my guestion sna 4 Ther we can texe 2 beak. is A. Sc the question =~ the answes 0 voMr 11:e0:02 0g queen tae 1 MK. SIMPSON: Weit a minuze. Wal. z 11:46:04 1 minute. ®ail a wioute, “lease don't discloss 19 somethiag that she has a right Lo ralse Laal 2 objection if she wants to. 21 BR. SCOLL: Bxactly. 11:45:13 22 THE WTINZSS: Okay. 11:14 23 MR. SCOT: Rsk your question. 11:40:17 24 MR. SUEDSR: Maybe you want to read buck 11:00:20 25 the last couple of senteraus. eB IN TUE CIRCUIT COURT GF THR SFYRNTEENTH JUDICIAL CIRCGIT IN AND ECR SHOMARD COUNTY, FLORID CASE NO: TACE 15-000072 H SRADLEY J. EDWARDS ard ACL &. ! slaintifte, va. AIAN I. DERSHOWITZ, pefencast: CORTTNUTR YIDRGTARE DEPOSITICN OF KIAK M. DERSHOWITZ VOLE 2 Eages 180 hrough 232 Friday, October 16, 231% 8:18 a.m. - 12:26 p.m. cole scott & Kisoans 10 Southeast 6Lh S.recl pozt Lauderdale, Florida Stenographicaily Reporled By: Kimberly rontalva, RER, CIR Realiine Syslems Administrator i } weune. phi ppSTeporting. com (888) 811-3408 |; ee s ixoax hs SHAT. DEE. SAE A 3 EI re HE SLANT CTT feet 8 Comme tinue i 2 BIT Grea coute cues 3 3 DO ete Eh a £1 New Yeah, New Ved “ - ‘4 EY RY: DIANE NEVKE 0%, (Vaphrey | MR SCAROLA Mid ustancrn ic 0 2 THE WINES: Ver ir Bl 0. Mr. iorstnac, what fs Ehstorical H SU hyperble? i 2 BT Tet —— 2 {Papes 182 To 184) new. phippsreporting. com (888) 811-3408 Abe ser | Tar [1 memo | 7 wens Wik 2 aurea ated tu Pea b 3 Sms amon ean Ps" scons moet tne Piven mii BOC Se © dein scan, is SCOTT, Ware ding gts. © Suita rs. Yoon De Mmecommoe md auch Tk in sp i= Mk SCAROLA: Sos Poorest * rbdea aima toa MESODTE: Th smu ls © Ru san © aot i femnehe— te SE 0 Wekwbu Vmmenne uv, n IR SCARDLn dart cs © Derdian dicn. | Hmm on enh dt EE SE FA — Sb bos ko West, 2 mad wae tot pace 10 hens oreeh ts cea, 5 campers boudtee a? 1 Teh toy i vad i 1 TNR SCON Gyan montnas e nd 5 WAKO Denne feb | 3 comm veges. eh! BA 1 TUS WI NESS, ir screens of FL PR — 9 amputation aun dyiz EPs po Ene, PR EB [HE e—— 20. Om. Thendtiueis fc mif son Bm shedm po be oy 4 woes. 2 hr Reh wk euesvesmils | 3A Lik annals 3 ei | wa es {3 0 toons teion cola 3 SMR SoaR01% Pot jam e mareheasel pero FR ne ——— i: SLOT lets ret ve 4 FE wh — t ie commit fA Yeh H Dr Tm wp LO meee © avmmsoaLe ECON That Dn nc rare | TQ Meme dscumdersimd isn Tvl SO abt et mae ten bee © 5 Bayon oter to geome diel pte lo ar sud fs Wt? i © estan if wave ae saa i 3 Teil gates 8 Ba Did me he a niet I amit mess ven ol pobcmarsnie | 73 during ecw of Un wei "Av nt Hagan thes rn eater Ep —-—— i 35 ore bray 4 vl ad © Ueto bed es wr a pile 5 samen proyecto re, A — - And lm =n H 5 wc nbn, bebo amie © SOLE Vaan oie Fe —— I 10 mane cutis show hot wl pt ther ETS Ko Fa 15 cuando PTE a eae. te 3c 70 Ok. Wall were ping walkabuon © FC monies, Sw mais ses A vemos. im gr ——— py asa rel ing bersin | ees mome ht rati | CO acl ve ary SE 2 a dua bm od MA Tecmo - 1 tran 00 to vos ps AACS One eves py oe a er Res ons mes” 3 {Pages 185 iG 188) wa phippsreporting con (886) 611-3408 1} 11 © den ga lh ton, ee Lobe amergson, ae af anes of © eembeot ig bimomsis, | © ts oman wos ut Pm st | 3 Cepstemsa ER —— 1 amctonte me do ut ho me nit Vaginie © cn mony Eisai ER © in cst ais Kec ema 7 bak chim be ol ET Tht he nny yg nse . Sym renting om [0 et tam by vs cin © som bo gen, Aale Dor TN moms de oie pa 13 ammo ck cd Pa 3 mae wma pb my robs : avr scanos To ueeeaiu tome a on Ta Er om Fg ——— RET iC —— YQ Wel hx pani he Xr EE quero ross. tye im dis vo imscaRor vos Wr a Ho versa | 2 ese? 19 areas io wage ich Lowe | 13 BSE Obi, ow 2 mara rerio Vinion Robes sort? | £1. Kye eomen ebimedy mentor wT comes avec deb n Ba Teer {5 use 3H Ar tow aw foes | wm 30 A ells ewe, thas 135 0 Arik Sow ston wo | Lo 5 downs odor in che © ose seu sa ye er RE es a Tr 3 tlh cok aoe mmtee | 1A Torn sork [Waka 4 pumpin a minis we ity 5 None whe sib les [en —-— FRET SE RJT — FR tree RT Be a be omer } Comb mth cene in Tan fe Poe Sumy memo bya FL Do meats adh so ides Ton n pL RE Bi eA © wake yo il | st eo ohn andre pear en 3 onto loin | 3 asst PAR J RI {0 sted ali Lr, 4 bE [Eee HE pe eT SE re] DC nih En © mesa ag © Voutave smelt stem But soe 1 miosis oe pre ress 5 ramen rir RCN UGTA 15 oo rs a mia ln } 36 arenon vay yong weet corer! FR TR | FE er FO I i opens t 22 cote, Miwa erie, arr osd ny 23 elise sat he con AMA | 31 aver ection A “hd meni Da ep, Ee TE I J ETP — 4 tpages 189 to 192) ‘new. phippsreporting con (888) 811-3208 = - Cn Sot Nad tm © Ta Tow tr i i Ce Poe ati EE TIT TITIN Irt S-iy TE—— I ii Tiss Ge sh ben | ERR Au —————— FER SOR UVEITIS I rN 3 Tien tom JU itv 3 ember I mm 2 Mime seematere | BT wen: oto tosis Bm mbar rt [3 mm nares fr ie : Ein) 11 atermcag, dul she hove sre clatdes an ar lex # VSO Yost sprain, | 3 coon mat © mem nr: ¥ 0. ¥'mpoloy to hand you wba wel now mak | 7 Few why wens ruse ny hing Ls this. En Kabab Numi 3. Iw Q. Wim you agree that al I= young vam 2 (Thereupon, smarbied as Plintit] | 3 dual pbelvgrapht Py nin sei i UR Som Tas mms 1 Serva bem mer sb watts mem scat jo "Tim Re apanemgen | Te S00 on om 15 Mr Denvhawite? i 3 Ae a own tow, 30 Fae te » A Weta el as EMR scaROLa: 1 0 Never fleas on an private shglane wi (2 QO checould 4 1S wr 167 fo we HE Srinpree ER 30 sme PID pion | wen bmi 2 tuna Ti 2 rts om ae 5 {Pages 193 to 196} www. phippsreporting. com (880) 611-3108 + wr soi 1 sah, Ths end smn ray, a 3 nS opie Yost | 5 fw ra i remeng EN Tah es potty | 3 oe Temata tutta | 7 RAT was, be Butane mend aan fo bri Hernan set i rf i Tea Beek umm, |B mmm 3 oma Po ha ma Ein i me nv sian QR Ran 1 Th npr mn Srp | 7 5 omm———— rae twelicie | 150 wasabi neten 3 cron [IE ren Be mini, Tm ematnntitit 5 pesto rll nib | 2G You emer ah emma: ho emma En wr bain | 1s or ge £0 0 | 200 Sibi agin [3 0 Tomei een ted ram ri ——— P rmmr——— | Te vena Soot et PA Pa eo wae To hn oh hes ba Ia symm seals oo ——— [55 nmt rvopmiton veh os? "Sm wamm——— pion 1s Wi, SCAROLA: Lets mark isn Exhibit | IS shea s Right egg J wes mot on gy 1 a —— ir (Te Iti PINE 10 fights, does nur? Baan 25 merece wt, bors Seen Brom bpm. A co imeim 5 ve ra Bi hk oS £ (Pages 197 to 200) we. phippazaporting. con (888) 811-3408 on | 20 1 than hres pees fer Ving Rees bd PL vases H 1 ar : LI | 5 ov somo © 3 comes var os he nme on is 3 me perder Coe s a —— © i wag sige sh PE [RE ev —— : MISCARULA. Hh stasis 5 AML Shaky ve mh [R—— To Rate so Ti . SR SCI: wl © pny i emgon 3 orn emt Ts, i MESCAROLAS Lat toda shes be | 2 sure 11 enamel Foor eit. IYI SP —— » pellet he snc on the Koght Teg amcbed aan | 12 Norembur 1%. wu we show msm ha 1 bmientaohmanas Taio | U1 adeween hb risiak Grn [ERC Da Mien three, [ER Po ie 2 adie dems sden | 15 ie SC0nn: fee di bis 1 nd orspatdiooh dec I S00 SEARO. ame oh le qucerions, which will wart shen we cesar | 18 ana 5 Cet ow RB | 10 MS0OTT Ge Tobe I Comment | 5 acme he 3 geen en vee | I ties fe whedon = MR SCOTT: You bnew Slots | 33 mpi Bessy ond apis [TS i » ML SEARLS Thnk sn. Da me twee, and rend E MK SCOTT: © doit wr: with your IE 22 | av 1 Commie softs nh | SYM CAROL 2 BL EL b= ©. DM you seats deriag the same hiteerlerr, 1 Speen fed dibs sm | 3 (END awn eavi: “utr at © was lamer wet pe. Do ae ER A Ap IE ES We 5 Saw | FRR vn PR ce — £ ison, we nen toe kT * andor Je wo MRCARG Yaar dati | 1 int tony vont ow, wig mansentteedte | 10 TH WINGS Yea te Sw or ve en 3 lever fa tf Cer i DMR seAROLA: BO atop Anos ed 3 Seowestigmamsaomy | 1 SCE bd ih 1 quien | 35 pm rssh Rs vm ie me. ww SCOTT, Notas bs TT ot eo md tm, > wana 5 ts set Cont 10 wher tearm te lis | 1 pice ste nfo 20 53 ounld enh Mam TSR | T) tier a oi wap EE 121 iin chon 0.4 iy nrc in RS Sestwalhelmnt | 2 shad, dha Sheol hor bate Dri pubmed, cdOcqusimbatanl | 5 wi is lust sicomen 2 pees sl san Pee Cvimstanous 7 CRAY Iman | 3 Yes Aan noarioen (Pages 201 to 204) ww. phippereporting. com (888) 811-3408 203 war 3 these ul bo Si wi? cry | Clic ng amd, so i | 5 amae hr mac to gina Reber the 2 Eicher, 1 3 nat Oo A Cen mbar dnerss Shon ef ad 5 Wen mide rishi] 20 + thar Coon mas an Jeff's ed snd avis § © ewan des ogee: © hat BA Cia sn ez on def’s i FE A i 5 piciuralh sciatic: entre Rtd . AGL SCOTT. Chica i 2 Ciera on ebenerccs: cipe. The Poe vmstat FER ne SU ES Sa A ——— JER SH SE 2g Poa M2 SCOT: Faen © iit he Viren: Fates DA a low ds 3 nite comy at cpm ratios | 18 ds yi ce. Go jpn wrested mel obcahe | Le BY ME SUASOLA 36 cent Bs ke | 5G. Vm akag wher om rsa ST maa tegen easily HET n nto hn Try dt bs 10% OL cy scape. cio Cina scaly | 19 Gaineien, 2 newrbenie based einmiogn | 8G Ouse Bnd oobi wer | BA Lt Lest eis 3 pegs a Eperuronihanal | $4 Geician vie, i ln bing ibe 3 tot hha Cl od 0 Bhd a Bilis shiva 050 34 cates aon and od eri, Cx LO ta 0 Chen pri cid 3 aims es Ciao | 75 Ean foo Sl sc concn won | 03 1 meme . nd ei gly. whch 1] “Thi: the aebed in pn PE apm nie mews PT ibd Chm ad rotund 3 bein Tho ws hepsi, wee Sab lH Gl ven ome © whine ws Wee Tess . Sober in alld Low LS iy neven esdadd § 7 lpr bib bebe BLT man min iy we | © Chmmnon hot wo thsi lat Se eb snd orkid i 3 mr ceni 0 , To my emis ‘ Noeyen pct mbna des 2 | I Gurney olan bet ws © 10 sve cowgh fa tatty | 31 fen oe td «Cot het a x SA vache od led or wise x 3 na, Seuecerdbime sn 33 Sblme t Ginn nbs 33 fete he chs a ars Aor 1 Sehr Mowing (1c he ros hain 1S pouameia hh pots wl Brachial 3 oe Curb an, ot is mmger 3. Clon un tly mpc poo 38 oii he Vig iar heh ves x Sura. wate br ie TE dim hn ny ln Hei [ERP Se Nee 5 Pg ——— 3 mp comer t Hog Gani | SE rp, ml” ad et nde 20, Con yrds mos evapo el | 19 Sopot ts a FL anvioutcd tn Villa Robert Ie notes tt | $0 ike 2D Cltant ober a mange anes 1 71 toc abo sin ne {7 swoon pogo. Tl 7h Jamk dor -teetnehenany |S) cout vnc: ssdi, bend owt IRS ER Ee VI RT Ap lb ge em ne lose IES ep & (Pages 205 to 208} wun. phippsTeporting. com (888) 811-3408 I rretre a EER et vet 2 otra vo ended Vis Robin | 4 sig ect mses obese ue, © 8 Cn va th era anc 3 Sr gps wif a ein 4 ders un nc ms © aka nel rondo ches © a se hc si © anh ace) amit LRT —— 5 hmetn Tet emacs die. ? MR SCOT van es br, © scons he nid, Ur sand od © seat sad will hw st wo Wo nerd PED of ve | = OR SCARCE: Oy. Wed yea ich VE commie pei wn bs edo 37 map lathe sees cf 3 dit Cn 37 ein owt © " SARL bone ax 15 atk ga es mada be Bo mene BE hep mon uke sk Bie he {ae HOR SCOTT Dn mtn the a nc r MR SCAROLS Hue is Jv mt pr 1 THR WINS: Tr ing eos ok 1 pia tare 30. vow masse rare corms daca. | 20 HR SCOTT: Oy. Medio he 3 CW tion totks vam hr igi | 3 bak Ftd | 2 seasons ons 5 sere. i= SCOR: Tauro So Ob. Wate cninstreont? | 2 HILSCARULA Pasir: BA vadearte ads | MRLSCOTT: till hip ei an | 312 mites cima samedi or 1 ei bE nod cot on rooming see, 2 ME SCAROL Jos cio so. TT Ti crime be comeitiod ws shale ce fom e |S dt yw die hd cone, re 1] + mab a Mio di Auda mr iE MESOOTT. You bw, Conti — H ER MCSCAROLA: piper Bam § 7 Ga 1 aplasia uy H OQ tse tes eet 2 MR SCOTT: Yeutao vst bet 3 arose? 5 nese shor Se 1 Sn, Del saci ed 1 wan Shel ded edn cool ud Senos Stef Fr, 8 dager ely - FE MR SCARS: Ti otecovl wes leary ew raise 5a im MR SCOTT: Sei SEARO Mo. St HE 44 CANOLA To moter prs: WA aston DIE mn fo sue w= VE SCAROLY dyson | de ER pee {a ar; One Ha Yous ios MR SCARCLA — i rau. fu we at Senna: Dnwntlratolam | 5 te selliowg geet. Mime Bn ww FE wi SCOTT Yow sega iny [3 RECO: Gi Tie Thick. “dims os, w MIL SCAR0LA Tho 2 WR CARO" Nn yc. a VIORARIFR: GigolTberaund. Ths a recta, You dubs BH mpi 9 (Pages 209 to 212} wiv. phippareporting. com (888) 811-3408 Tr ———— | i acess eas ahd fren 45 wm, nil 16:6 wa) H AQ. Phar would exciusnly bane lea priur bo © inromamin, re ghakrmenret | 3 Eber Dns soon? iced 160 um. FR © MRT penta i 3 ARSC: Mov atk Pb py Loic hammer and © Thmscamnts taka 1 e Thmsoaons am 7 comrades ot, in. PR ey fara scancia: Sas © totag revo ve mole ile 10, Sn Debi des el nto gu an ave 1 BA CB on Lemme nro | IL tat aon dhe Vpn 3 sash paren cll pre pam comet FR = Tv ie 0 Vega Rubra rachrmgroonte | 0 Tovey ovr steopid ost Dk 35 iu iy fs ater atort Pmt say [55 ison i rd Prony rot ey PREP 1 J Ui hei as ba ir knd | © Q Nor madeu publ er eget = FRc TI IE SY Pry WG owe rat Taormn A Beet 2 thrsrdto hn rete? 2 TQ Tote cto humane might | ZA ene hs ate Cet 35 var comment tht Vr Rar tn Thema sce, Hy ray he ol I Contato come. hey utd be drain fe | 39 Lok och far mdf th OL. a ncn Tel oe © a astm ma 11 encase ati Cin ss £2 2 lt cai 0” crm. Har db st | 2 julien Epacis swt, v5. 3 em meehloni In rises [ana — BR iyi eresntsing Fn Su 3 Cb tomo parades | EA Naww © nay dsc hrm Poe mers ¥ Qu When lyr Vi ot about his abegss | 7 MRSC Wall ain wits Les _—-.. I 8 tein, Aokayorsom. 3 TR kenneth: | 3 A Avylsrimems Fk mates 1 wannabe cl heritage eof, Soy woe oth HL hor origi oe gels Robes dun | 15 academe gen, Top ery ir so rk, Bogor baton | 2 mh pn 13 me the oh me Er vrraviiny Ve dss war D0 Wane w SR ACARLA. tore yh 52 FE tuo o— [Ee —- IE cape Lat ed cs pve 50 17 HY MK SCARDLA: To preity. 1380 ou Gut se am sere cVRA FO — 2 cmp (CVE alonshroing + ©3 Toy hokage ce + Sed 20 praetor! hmastet tata br 3 ne Daan ted emir 3 yr VS, ae con et 55 asm bi se x cep 3 Toe So oasis | © ontetbarbinsr hameihowei® | 20 tT sash i i itieetos md rag | 3 Swope bootie | dvi on T 3% dri sorta mbes sus asst ry i 108 {Pages 213 Lo 216} www. phippsreporting. com (888) 811-3408 ar | Bh 1 Sener ew wid bo ly ew 3 med hace implica ym usr zing ves | J Sa — JR a pp —— 2 he song mya, is RE 4 aghast 5 Sethi ma ne ve, My EE Lom sco © my cold min ci, vo. ER EEE — Fe re Sem NA ne cally ni FR ——— : Tho li eo idl 5 lng nb. Soros ein © opin su esd ot EET ——— HE eal NEA wp erat #3 ER —" Teel fp hd pes FER P————— § 7+ ae onto fh es co bh van [R— 100 cotta opt pan FE 113 sae saul sec ving ot “fe ember erie, oss 18 oii, cols idig ssroi 0 5 een, hewn ans AL | 11 yt Ann bd bee, ick yo sil on rem un sn uh Pim redo Und Sunes easy LE yg ath ha ra hs ens DU mnseat ale key hacia i 0 stn Toe mia sigtom a i rsotaighi. Ton cy boa i TIE BR Lec re 7 sane Dun Leman CRN mre wipe mice | 38 homie gigas. Audbnmmttr | FI he ot iar nd Ye Coutts Gon val pd wis | 3 parhea ae ateteit | % maples | Tn aioe Cum are acnt, | 75 maar Lata wa raves Bb Sen wa 22: 5 Geersemberda? © De ates ig el pens Pay ti Fp eer 2 7G sero pw mics 4 RST Gas sri 00 PR ——) Pm CE nimi dd © onsen © Tu ee I Tsou wn 2 atoms worm oF eaves wi five: Epa pc EQ You nts “ei Add Tn 5 tery Savard od and En “old vd ER a l— Rar — Zam EE TO yess ny 50 DQ meckeweo in veg, 0 tbe analy esd 16 te, ht coud helt Mo pth se Ze Clon ks Right cm en cr 0 vm at enn TE Viare ghtsar se as mfr, Hn Yon Fiammoted hover et RR ——— ER FE ——— To sont tr en tts Ca MR SOOTR Obie ts Choke 35 tatavons “Soho ern rly vo, © renmmic EE Pd Cola Vg Nor“ co FA The we miiervies Guess FR Se mre cl rein, Topo cst 32 tan amin vg 3 our path sen Wma, | FA Usd 3H mand bons eons ai er edd FEC Seng Be Tg der it, img WA FE Hy pp — 1 (pages 217 to 220) ww phippsreporting com (888) 813-3408 an | 221 : Por msm. + ova scanou Doz 0 Di awa wer opps 3 Q -wemestmanh ads 13 ce © Toy adinmamaset vated cmtedint © 4 MILSCOLE: Ti rssh = © nme Lov esowons H PR nee ——— LR rr eu f= VR SCOTT: To sis aes 8A en salts otro | © enekomh Fim ane 2 beth mbes i Bo cv 2 pm aellpani bo FER Sera —— ro fe 1 bento © esha dey ae 3 oye, cont att a SER SCOTT: Rea dacs, mel! 15 doin fyrrr se od mak hase. Serine 30 idee pce a Ca 4 pyar seanoL T5 ha ol As oe i, wi it BQ teserun anny nan pring 56 a ad est mamas hee el nd ws SC ti to ey pr mer 1 Vig Rb ele eth product dase? 3 reo ove wi me miofin he =» AL SIMFSOR: st pe il 15 Masten LI ated sain es, 34 Be cn pA 30 among A Sewn ey eine $1 un, Mr Sor i freephone | 700 Sa) bts sey 32 Lyi omen ta crane | 2 mendes pelt, Aud ond, Fn EA ST Bee |e rd sr os SM SCARGLA: Welle. bey thon 35 Vinge ar fl, wih DE oma pri, whch ane 2s Pe 1 omen, ve ase ap cvs. Dl wowed dom henge dike 47 Q. Sl yee Biosphere Co ud 3 rence Dru ae un nr ope |) alm ve cme. On on edie rod pti nar Vigaio epercindyn. | 3 coh (apo waver shina 5X Cadi Vinh Rant Pu bepmewien bees, PE poe AA i i i ore TN lime, Yorke | 7 lke Wehner mmapleois 3 nb once | f kbcsmmenston tom woks 5 Dinh, wt esion TE when piace dal neon SC Reese ments bo i Vr DA he li copier, 1 Re bkithe fo recurs | XD ous gaosscl a wads a. FS tars me pele og i 23 Meri ni pup of cd D0 tn phinan ste Amma. fat Ho wellwmvidnkemoend |S thee deca dpe Cosa Sarak ders earn 15 iri Ce cm mer Sa tink sow wpe renin ling — ie SU SOFSON: onc sis eG 1 tr KCI: Ne Gate Tan | ST he Me Sel, renner Bw sty ik WR SCAROLA: Ah. Trea wise Tar — To pura dus co ni wan) 21 ue tance odin Gro tn 3 mara Taso, shaky, Gol 2 ened aks a? 2 hehe demons tints ws bine Pa TX dun cams wean BH desc elk pune ot 2 ame Apa, cei weeds 3 omc oie fh era 25 erect lib ris peda? iz (Pages 221 to 274} wre. phippereporting con (888) 811-3408 = nr Passo temaaimes © 1A lems meg FR viii I pean Vint Heme 3 CAROL Somes rns 1 Vira quenly cons 1 reeset [Reha £m mammon: Cone © Sasha Sodio Vina bint © CARLA: Cl, Asem © lame pe os Voi 7 oabmiiet {7 wrens stn, psig, ¥28 « Vit SrSOh. Ina rigs sis | 4 aspartam. Teh wb So, Ds ti wn os So RCSOMOn a Ake Then i arto we Nata mb 3 ava scoL: HELE Ar Sn Wheh sonora i Ree yin | 3 dara ern bs Teron to am tn mtd sibe 18 Mey, Wh rman 35 pei whe oe sm ot dwn, | 33 Ronit ERR Hr SE TT Tepe inns | 37 om. FER met I SP 3 paromitnis P35 0 om aomdcotibrcom te 2 eva nate vain 1I0 timo rs vn a, Avr src “i FP ——— 22 ME MeCARLLY: Ubon, Totes | 22 nusnd quis, anid § want 10 kine oa 261 Sams Beene exter B® Bnet dk Toes TL MR SCOTT tats ne © meson Wewmcomin, | 8 otered elm hlaiics EET we— [a Sp HIE rp rr 3 fanaa coi Po 1] + Tours thee Doe avmnsewony 5 wv scans SET Chen Sh wi tor mate © 0. atm thea phn © mame retats Bs vere? Tomer tac prc? 7 TR or hand aed aan) © TX ama San U coiont mtn um omen 5 ein 5 Loeetiemn RT ——— 300, Thrvsia= thors moo ow ihe © viet eae de lh prin prohoreenten, TY 2 "sn ve meri 2 0 maa 3 kre wines ype tcoes PR Rp 3 att seins, And elon) D0. Miata Rebs Se t HK Gkmehornietnomoddehs | 3 A Swale to amen wees i Taker revnl i110 2x vee ad su Hd Vid SCOTT: Twill gh swuluresmne = { 0 wack Whe a comply vith thal with at reguesh. Hd A= wimiron AM yom Fave to dois 19 For purges 7 disemrs, shew br meyer | 32 MRLSCOT: Ac, besh, hyo ot 5 Lane Wa an wi pts, | ©) abstr mbt Sade 7 TUL RERRIER: dildo Ho, 3 remeber ek | goin Voc bisa th enc ns 3 tr eotite ds meray onts, | © MISCO. ta asco te kines 1 Me Dako, bm dvyim bat | 2 poe 5 hae un nro me iE Tswana mes ims ———— 13 (Pages 225 to 226) wine. phippsreporting. com (886) 811-3408 22s | 21 1 presen So mse CQ What er phone sumer? © RCNA emake neh 5 a Cswnebosi otiin Ca wom souo + Robersand pons « 41 Vision Bers 30. Hod Miko a te 5 on beet sake vec oh rw © pe nan peak wens? 5 agra vier men. Se hvoutans todos. © TR oddone 7 kane coms pe ie ft Lr avis ees. he nbd 1 in mint ie pot © mamta mtb boy et 5 pais mt roa he sls PRs a———— FE Bury Cats ma ys pent Jr 12 Gan, ld ges, Mate) sn Alan eb iy vo 15 crt me so Cupbas sarber omy 3 J. KBs ahr emp re A11 En Saris eon nT .” NR. SCOT: gait ot © [ER 60. yun for eps ne br ov sowons = wa bit a vo ut anaes aut ners FR ctr mpv— {2 conaced Rees corer? ay Pan i tn enn katy Er Te ————— [2 die dors wos Rowe, PRCA ————— Bq ws een 3 ot dient Ba dmc n PR Bq ows 3 Alliant eg eae ws] 232 Poa HIER ——r 20 amibemial- PE meester wena vit iris FR or 1770 orto oon on con temic PR Sesion ERE ——— Ba Need eww LY ahem plc ort seme eas Vig Sct teas hoe mi grosses Ve | lobar corer? [on HERP s Qu Mon 50 ew hoy were Rory ihe | 8 Qu You abo old oa Liu, quate, “1308 [RE re ——" 15 ating he oot of Gams we 0 imams Wh pameny ims mens | IC A Ties ign TO Wilmers nt ed thom +0. You me then seinescty shed waive 3 tnuaces i thre? Ebest Bark andrea. cure? u MIL SCOT, Yori whe 3A Ate [PR In [ET —— 1A Hea dav at “5 hig avalon veh, WA TAS 1 A SCARCLA: No. Tyg Gedou | 35 obi: count ano rh, es of IT tes tans i tos force 1 et wonnboe boo coe. Hk 16 ons oewiv ti ving wt ch cai dur ida soc 1 Se Sent 1 ink es ign FER — 30 psi And sia RR 2 am donor Sage bm PI Sr i MRSCAROLA Dhow, wel, teen | 3 be Fra » Hotes ce, eves sesso don ban mbes at | 33 que. ge dd ie or 14 (pages 229 fo 232} wir phippereporting. com (888)811-3408 wa | pe Fa — t Q Auch depng cine oo me wien 3 mats wih regard oh cen corcet? | aco Croll Wy Kiwareenionsly 3a Gleb, Li Pa pase otaro nintel | FR [EE re i © = © Abowd wed dn © Th bers toot i md a Po exis © nsdn wire seamed | § 8in fg imo nk ad mooi Ee Cs Mh aren i ttn cb 2A Ges Eg ee —— [Rp SU ie nerve 2 th: FET — ae 5 eta tio men secant ind So Lames lei 5 hws bi, Tool i © acca wee ey id a om, TS aso mms | ae es I imnon wikl aon, x bpd [rc —— Het, won To marta, mole, IO. Wel sheared deft ETN ———— [RE — a EI take ouhind aman on dom md ahd © 1 somite, Thyme ousted £2 oun spect meropndeg dean 32 llwe Ti sel en — HE 2 soko eo UU sar serene FR SrA - LEE asap Sr ne = san Te IQ Soumedthe nse sarin 5 pols om hes srg wb fa 2 enon, Thy dose dr mls | 3 erg ae he at ave coated cso 4 when hy lng ne CVA RE —r— pena © ad Sed am th ket e Thue 1 e hmatte Bug ori keg? swe EER r— [RT — Dt A ekam ma ei 1 Thebarton i ie pon fo an ms fom be Cn, geben ota |Z tin, AAR epee 1 uname ese. aw | 17 sefeof eric. Saburo l Col amma eel game icy an [ISR FEE PSR UT RE ———— 1 ay, wey mayo ses voile | 15 bask of FEC oy sree CTR Ee oie phage fe clic Yo dpoanot shal Te Com chan ewe pa wher. 3 30 piv, fn wi a say 13 on cbodnghe an Ln ned | 42 vee alh ad noe hit 31 anpay dwn mrt 4 mcr yun ono, bik t 3 a melt di eis So Smt eat a i 3 wii uh ein | 32 A Lie § 3 sme Feoestos of to Annan I pr RRP [Pe WA te FE ve EE 15 (7ages 233 vo 236) wine. phi ppSTEDOrTing . com (888) 811-3408 ES = 1 3 srwemetersnsentemsostetyon 96s | 30 Tak vuln ssf te PA Rit IR dhs RA 5 mpm 5 aa rae 1 ts bose | ACOIT Tape sreett 6 ner enn on a perch 16 urcouts:, § mma ha a een, WE 1 Q. ~0 calls ow Detar ov ates. LE Q. Ale, sir, Ad uring the romrsn at 3 A cums Yolas wr i sm [1 hor ens, sous: “there ore ight I prea | 2 ston Tori ee Simei mei Besley Zit nt eo Cort Beiter Fr 3 onger itm vemos | 2 Ariesotmamerptotihatison =e | py 2 question” vvurred before SUB ods ela our ab whobe cloth. [ cunt prove it by fight. T oppearsnces uc aieer your undia appease; is 9 serena. town rent i by wy tral record © [— Be Rik © Ol Umi dsm Tn eat roe [7 comin ben pedscsin meh PR Snips riii iio J Re nin 3 Do | 2 "Won + sano PI vo Pp —— FQ —— © caus 3 reer oe monn san Wi pores 3 To Tyrese § come TR ge sor: Th ak Bh vu ema | 3 35 tot eth arm | 5 snot matin [Ey sworn or EE LO I pains 15 sa] 1¢ (Pages 237 to 242} www. phippereporting. com (888) 811-3408 HOUSE_OVERSIGHT_0107¢8 a Ey PR ——— 3 omer | ER eis APR vi ilies | I sear 5 Serene tp arr Lm CL me mem ii cre 1 LT ee th ested © ining ein Ft 3 in mt i due Ho en © een mrb— En iy El © comma it PI GF S— [Raper NT iE Lh r————— | 38 rome ep vale" 5 rebar ont | 7 wiv brome 1 5 cent [15 imme an Hone bmn PS vd Lit cones atmmaimrs I nse SN mai Pa, LR es Ae oT en vi {I navies deve one toe Ey § 50 mt son tr on HA [51 heute sme en me CEM Sesen bmi SR 0 Riis brie emer AR Ee Hemi rabiosmr Vos © bbe mas tg I2 tt maser La ei po PY RT CR — HI Sekipuntiapiiin TUE TI I tL 3 Dies BPE © hing sd ni 3 wien meortrimmtetmrs CIC possi JRL RE iy a bite 3 re —a———— | 3m 3 ronan wan te etmewrattoe ote * "0. nips yu te see 3 me hot rs Sap B —————T———— Pre Pr no at PER Bt Ay a Le Ke Vesa heen [Ee 55 te vei Rot Va wea 10 mpimeme mates be 3H aks doin vi Saito cota he 1 citations m— | 3 a ibem——— + ean Ten tava i i —— XK mewmioty I Tser mend 3 ee sates domi Eg ber ignore Ti Irene tmeto T toeatvhemei——— es 35 incly spl, tnd cote | 2 Ving ten dees? i ne HES Cy H Feet beniits Jo oma | JR nd i ——— 17 tages 261 to 7441 “wi. phippereporting. can (98) 511-305 20 [ aes 1 Sm ——————— | 3 vote enters tes 2 A ie 3 Vingaais Rebats cli s £3 508 wr re ot the. FR — Telemed" 5 names oan © Cwm nA Dia 0 You rt D Baw srt ti 5 Qs So. DU en New York 32 pn smo | oom FE ve E— Ju 2 Si nimi © 3 qe Nee Sh Ir rt wn SCOTT: Naima. | EE Font onthe adhe i mom scan [RE 30 wowed Dhyne | 10 aceon hon we, Dew me nish 35 Outen tei 0t pons | IF bp ch eb 35 hue of hs seme im at Virginia Raherts? TORS and Lows won ce oh bt ae memes 2 brani mala din’ | 3 ds hm td Spe Ga al tne Ene) Ci Q Mo fu bn 0 wanes FE ll be sappy toms yew aati) Kul eibont SOT wicket, | 1 etna he geen bn es ne | BE _ J WL Dei mite © ieee nchnchs | © if ou bod ot set md 1 lems ons sb teh mons | 3 yuh nae held it is rn © Eon nim whoa hendin, | © sem in roo 5 Three © roms amin wnt | 1 Stan semi nnde 1e pt Nervi, | 2 Jove shed 3 csi he ofr | 37 Some baw aks vs Lo meget ba Ve ome ae he tor 3 rs ei 126 rua tes be i Si, dd 0 wa 120 Fae asmeom ite is nt in E% am fn carmen aime wide 7 admin m—r————— | 3 sito mimi ren ie Ban ————ronl 33 power fot Seng 18 (Pages udb to 248) www. phippsreporting. com {888) 812-3408 2s 2 FS — SQ Wiha ening 2 ow 7 henson claim whet you ave cli abot the : [I I nf, Eu Scr 6 or Eli Vier 77 4 de bor ed ot ene y + meatus ws receves © anes ce Ano nine 5 cumin oy so. he es © moped wants cry eves © aly men me go eh * deweyante 7 petaded on. Tai ancl. ron. oq Sven wm reat vient | 6 pus ————— = posiami. “oe Gow dom oP Bans ERT ean — [ER 2 gilt se a vo nse 3 eden das lis 3 Loses pla, vod tora VE bow vo hd dg El la prod of ea 5m BO. Thaeareon soweteiktian of HQ Ob. Somme sadn 52 don nto be Tg aie or I nate do ah | Jyh ane va uk he bi w [a 126 Soret tot so ase anamg emg ae 3 an scwos | © monte oncaing we, ce sou ino Qu por 33 Gad Rut 6 ERA Narr 77 1 A ewe | a ihe rclesem which 2 MST ossien 12 ptuabeccitin its ond press 3 wnmstwn 10 ort ce thd vised. hse tac 220 wml wha we owe 1 wr Pa end emits Sawin he 33 nova nach edule | 9 wien be ceenisn oc min od 21 pei ame dorms ro ri,” 34 includ en 5 met Fe mania hos wart meri 25¢ | 2u2 FR Alamo |: ok. SCOTT: Awol isons : MR SCOTT. . mhluriicrin 2 ems cer vib Gb © a Uwe hme edrnon | 1 ai ow cm as ei 5 fay Tysis acd beim pod | F TF WANESS: Oks: © oven |v mvamscas © pV scaRol © 0. Whoa yoo at they Bud reve the FR [RE t——) 3 A ToPdmbkabo sryiers be. Ts x MR SCUTT: Oto, wai rade. 10 reson fe Epp, condi v VR SOLA Wl ke, lr Sec TL Laat sy wer | SL eon ne Lown Fetal 1 daregds enna ame emo is ems n ie cepen eels of my cs D2 beim cotored rons 13 i derecho i lr BH beng com bi sar sion, 1 bane Aragorn, | 8 tent lo- dla aro he ahin TC ned be oko cute he | MF ances waberof vitor seminar i | 3 pass dei St padi bem 3000 SAC SCOTT. Mee he a oe his 1 attri en pcs de | 19 me Cae ogre ange Ema itv Rees | 20 comet ih le 3 liog heron prod sites, Thegowiey | 5 VC SCAROLA: Bt, essay sd Ti Aen drs, | KG romeo osm 1 RT 2 seman pans ur pve. {50 sailicems cmacon Stwermermas | 4 [EI — i 75 cage ise st Ps sdb rciors or, Ne Soh. 19 (Pages 219 to 252} wav. phippereporting. com (888) 811-3408 © Wr heme | 3 Amine dss eon comers 3 thscurs of your publi tems? {2 wan Dn © ies mom [IP PR stent Ds Tims vee mabe © womoadanoue PT seemed 30. Youre refi tr? Toa Th iva tin is ven Sf eres HS = apa a = SOOT bent ERE Er — Ha se tn sad PE comumeaimenreie FER 7 ms mpg sets vo ma wen Seem ei. EE Ee a ST Gps Tw mh som was a 3 A0USCOTY. On be mesa To ovMRsoL FU EL ——— 50 tds en ks tgp gt 22 Bronte ma ma ree th my aman 25 onde coho shot when ro it a, 3 vn Vis Bt cod EI Menara to. ma ble osha Ea [Ee 370 Nest ava kc on ami PER —— fo meeps, homme | 3 A Va I mnt sho st. HQ enema iter we 6 : vast to won th is “dis © common wi Ts Kein ont 2 sos fv ec an. 3 acetone whims ERs —— 1 aa ere bing a om gah. a hb. nd rn Lar Tarn se Ga Ok av gn ns a Bb Ts phe 40 Wade ors ment © vem scan 5 dimen dckmiv oobi LE rr — [Ee ——) 5 ames qs sd prt 1 comb, Tbs neds i. © 23 dele Epednvcosai v wslaies 3 Lal orm ano swt des hte <2 wr Hs rf hk op Ep — Ve Sie dari Ve mbm un ge in Gace 5 Vigia Robs mak ph sr EER SS ——— ra te =. Dury dt meni 3A Theo tar we arn strc ln Corgi + FQ. — dc Svea Gorton nfs BALA GOAN © ms © hart Da ams Eh HE pu 2 erm aieds Tavonaing bron | A Thani FRG SE At FER TE Be Satoh Heras ne mega Gk 1 20 (Pagms 253 Lo 256} wn. phippareportiag. con (B88) 611-3408 § wed 353 Lh tempi @ mess heart ER ver 3 omen Tg tise 3A Rk Teasomisenone © 4 A yo Aa cic ste dy. pd SQ howabat nea pean © mn Ss dy on Gl 5 [RR Tr perry 7 sii 5 0 om + bi sowous Bo aaah hers © eh peng meee ne * lcinatons bes New Mins S80 KC 55 Crimes Ris dc arog et mds | 10 Sit os mar (200, 1 ruta vii Rovere sn ty Bs ETT so stloves bngh. 3 pin, you mere amd ull are Bbc he | A5 ib cainly oss Be lst ne ssp FL Cle Veep A etn 12 ole gone eff 2 miami nour it 114 dh ut a vsti ars bes 0 Sis nem, i Now 17 invevim: "aly ce in oy Werther | 17 tite sora iby Geis ss ns 35 tare rekmmgto oe en | 16 nie wives anche fe, kay nM EE Cag inden sare hen rm ond Bg Open He deny inn FE eben cam. cds 5 ets how cre Mi” 21 corto. Amd Leto 4 a avoney 3 0 mmr tm 3 Rear GN yn keno ove heer = MILSCAROLA: Sho ob 35 mb fbi no eco Be Beri ont FB aac zs | 260 | aris pbc 4 £0 SFT Wena age om bso. ran vamp Pome : Th ora ee a cen i : HR SCAROLA: Fol sy bi 2a igi hess mara ey Conn PR © 159. hr saa i cs basa . SCOT i, tse, I mee FR pr ————— 7 fei uk vison, © amtabie Tha win nach el ) Theva yoni ie I hr secur nd 200 + obs ow oh a enn RE Sr TE Cems ot ok in rt MN Newman I emsecars irae promi imohed TQ ha trmrotesme ron woven | UE Fun ad nso bs pesca ies Ad 35 greyng ese wore ony sds pers | 13 soi Hen feb bis 10 rman Wises wes toons animeg or | 11 am, To eet on od ein soo | 1 le SrE8ROLA 36 Gaga Sen Min i? 1 SSUES, Al Fon ston, 17 yon ca tn Len | AR pA 1 phenome tavern | 12 ie Ad) Gui sw 0 BG toni nlrair— | 15 Smet byes agate - 3 Lond ee he, te nlc HC nr th, As Fea pen—— 18 sole potion Andwees tits 3 ho ences, wd righ 3% out eryhs, heh of. nosed Cou Vea hae a SAL SCAROLA. Ths vou. Aad sis so cei ne 3 abn yewmc dnspre an etc Fs ES S031. Ao 6 rd, 0 21 (Pages 257 ic 260) wine. phipparepor ting. con (agg) 811-3408 aa 203 alent wey TE a weet seer Conan? 2 RSCAROLA: Yon sie © om sone + wrwwoscans 5 wel pontoon a bes sn oe © Q talstrenren ony find dary Sr many wah son rome ei, 5 socio bs tomy trys ® KSI hie 7 Wnty dca cvnerdiog ravidin mor © ¢ DY NRSCAILY Fler vaio he eco rt ere nde, 0 —iane 0 me Pe ARCOM: ssikstnbn mae 2X latte song iat es Br ah “wiki ovimte,{nc delonge bv |S wise ised fa Sony doit i 2 min it mak nso] 1 Cmca cack meg and H newsbin magnate | 5 srllebe? Yockapiwo nsf 3 bp we ally Ga, Thos bs | jo BARGE: Haws a ose | + kere en nein EC aqui samt sap. = praesent collars | 7 MEET Sedat © tren teezasteme arto |S MASAI Pausini suis 5 mec Salk he Bf radiould | dbl elon pr ETRE WE = Fees Aion | 1 meant 20 us ams a vhs | FAME AGRO Ne fm king i dee EH BE 2 ekivangiec nono on Apes | 72 ei anor bb end PL Se A —— D3 mse te em 3 lng dct bere § 76 anette 5 unr Vian rico belle tne. | 25 ar En 1 Se Tudo ik ons em Uo anm caus 7 loteades Crise bees PI Sum ———— J rare klk ketch Eesti | 2 stones’ 3 und oan Morne LA Lami Sw bie © bones Vig, vost rchion | 5 peed ay in sah, $300 Flamm ton © Carma Tan Are, Us ames cc BS i fib Sado, dy call x Could | dasa ars ee ch od gh FRE Tovrea I JR ER A ee © lo be tg ws le, Oh eiel | © sberdacamateen [UJ oa 2» ifs mate vs pout colt mms I re depen iryver sem tagie. | TL Wellin prem. Wrclodwd 1 com sot amen kan oy | F dsmalte ia chee fou eid, We SE wee ne Bes ed D3 citi Wess, so vray 10 pation ated to grr galing | 7% wee lk gr infmsive a sonchaily | cnc Th en i cara TE ——, ios A Thatrigh. 36 gouwie me an the end, i cha-onck. FR rE RT RR eA I 3 vii hn yon RR BT a rr connie ended} BO. hale hedcamenti— 2 Rls sd ioe dno Bl A SCOTT, steno hs garcons a dealsisnehetod ea, nk ynemts n mxascame: Sedu to belddnototir-s | © 0. poco gubersd educa © 3 wea nce. i 3 comet vi cower? fs MR SCOTT Wieser keine. | = AR SCOTT: Yor ua. De enukeotnk fen hori, Tome 22 (Pages 261 to 264} wow. phippsreporting com 1888) 811-3408 | ar | 3 heme hoon POL ots it mn eu es | 3 MKSCAROLE fedmarmtmiien | 3 desea oace-awers i ER Pr vem H : SL Gh. « ME SCALOLA Tonks { © MRECARGY Caldusleidol | VIOHXRAPATE: Gengo Benciel Th § © mot dont DE emma in i : Chat wm 7 tome ce 00d 113 im) 3 mpm on 8 VIDEOGARIER: Gon wh ured ER re neice ppm 112 am FER—— 1 oY AR SeARGLY 1 ment peered loony | 111) Woon eye fred frm sith 3 TUCREONIER Thos werbetane 17 Steal Reid ware Fria? mle ren BA Teves ln 3 Dum read paerob? [ER rT BCs amis Thixde LA Bor Vek Weeds 15 Q. nen merey tia Be, he Ta soa x T Bator 30 thems? [Lee FE 3g salam a ees cm 50 nay eer bag sdb. vou is Emre ging oe canting rv Bt a Prk Bhd oh fost 23 (pad wecheh (a eod ba en PER —— apron a comet E35 ad on ai, i le 20 A Conti ns bs io Nik SACL. Tom #0 wal im lng your scl I es i 2 cor Ironclad rec ta eo were we 30 EL pIe—— = pate ed om Hot bo Herts sd ccd 3 ent - OT mma Ft Bos 0 rd gt vO La she kes [EER ——— © wee embed 0 ema [ea PLT merside viat tet © Uma tek wrx becussinis © tun © pi Cold ems these 70, Sek whois bt on dt rn PR te 6 ttn bison Tr SE or 0H GIINSS. ecg Li DQ etme ee pms imi HA Destro? | SL Ice Date tore pd suc he ot 3 ems posite ECR —— 3 RMLs [Av A Np TT I BEI 1 hoof ue dig akod | BQ —ortrg ho ren ok 36 uber drs df cnn rset 6 | 1 cy Det [RR se [ERT ree BN hides 15 ap de, he or BREN Meise 30 Fu km, Se Aor PI sp ev Ee BE LD duds oitonts | 35 A dbo peunioicis Hee [2 ovr Sort nope montas | 35 soma ein LAE, PAN YPTES 23 (Pages 265 to 268) wns. phippsreporting. com (868) 811-3408 260 20 sam 1 Coa seria rust aes [I ur —— | 2 moti he sn Ets e— 5 ay Vain bare yout 2 ron pt © bel rm. Ennis moma an © 5 pena mae stn eban snd © ai bees amet on oct ER © stn rt es mi, hh mas © oad oiatad Veghia Ret ee seo see 5 comes eso eran. 7 EER —— tm 1 AR SCOTT Wh shen 30. qui fo i, ir ur. FID ui sen 23 MLSCAROLA Thnk Hd mtn FER T———) To ower 11 orig ie Bly vm a AE 83 ER te —— RE ei —r— Tees mw Tr cnt of emsiom a sun ly 25 MRS ore, Dry 1 gene Vm sas mh PE ve — Bsn natin | 35 rvs ney os emtners scsi. ett 55 ati, Se fo 2 wen sows [i 50) Nr ama HS ts | 5 imate PER TT BP TO Coden eco inal, | 3 Sein Gsm sum 2a hr ars of Np ers ccs Fo wns po he oan sat Fe HER or — TY WAAL me | Pe TR rT 1 Ses as ths Aad) 2 gen [JER ; [EER Vaan hy wi Sag © a | 2 ritona mohicss ponk of ly Spas fC seon wae [0 drm honed. Adin « MEMGCAWLCY pn moto nais | © movofadhr he mun wil © wpm [I neta ed hn s EcomToRR antes 10 ret ut, nm std PRT A RR Er Se 0 er IE plated yond bind e150 a Mi, SCOTT: Con mas rv te 1 Cats fe, knew ho, Cova kn ER Eonar em ——r = DYKE: Dares fun it [Pe FTO —— |. igo sso 4 ns Bde ing sone raed an | 3 evant md one bn acamic 3 meek in 6 al weal ava, od ads vo ipmen TF inet gi son smdtise ERE — 52 hme the bd cl ef Wt Fa EE n Tk wr ee ps lesa me Myers. my 2 Conte warp Cr un | 22 akeite, My po: new i scab coy 3 seam scat | 2 ee IE ot Kc iy smd a dvs, Bo mba ering et Us Birth sd Pl | 25 57ers done cep nebo 24 (rages 269 to 272) wine. phippSTEPOZ ting , com (888)811-3408 HOUSE_OVERSIGHT_0108068 EN an TT —— Ter e——— 3 hes ds tn ny 3 alias copies espe you. 5 arch lev Ga «0 + © rusts ra boweg i ot men bily DQ Thelen ska edie Aor a 5 ARNOT: Waa eso it Split if cling on @ hash <a € MR SUALOLA Ta nano Foun te. TY iba habe pe | Panis tipi irktes Tov sino 0 de NedwenillodnnGpeeran | Tos foewing queso nko 10 ote A oP erg | SEM SCOTT Th ep c+ 3 i wet en Men. wun sero Bm Voss be Sg ar don bron Abn 3 cpehepmane bast, [50 CRsrorn tom cise fot 3 ae aed rons TE atliamaie ih rs taeie 3 nin [2 bs or dion 3 imsoort se se Vermin ond dm 3 STAOA ew Tawktte | 3 MRSA ve lon 3 hepkl Turow gdb tom | 15 MRACOTT - ohiherm na. 5 ews 135 amet Hela: when tii mor 0 Tim son ert ine | 0 bedi Tipp Dyke cwwewEm | Bn sono doy ERT [7 Nk SCaT co neni TI HY MR SCAROLA: I UY MILSCARGLA, 51 0 Toeompnioratotet soni sitio | 7%. Dovmsrel ibe Movi austin 0 Suen epmach my atin in sonnein | 55 aig bn) of Ald he lang 1 coda 2055 co Bre mond Pl | ens han a geen dig he rf Be I RH Fs es Fy pola ini ES ™ mmm So teen D0 SR ohn dams in LA tet Ie hehe wnen Prince Amine mos thet * Q. Thoune wall of Sli Kpucin's-- IE] Anwar: 1 cou tier berry nt Fi nt 3a hen — Qc 5 meio Wb hose 10 Col aoe Sn Ab i rr a mesa vn : un Un wn [TR np FE err — Tor Ameen Hecame pre esrlin 2 civeneatmerioon omentum | 16 Sorat tl foner es © estas tm as phen, mr we 3 quai Anaamiast wale soy 16h acm —— er 1 maken sks ER Bere OT 13 an, when ts sor etic wen, bt | 39 hen ke wes there? 3 sour sptnty nnd th FA Hot nko WT PEE So renee, Mikes med red Vi nomecne Beaman ce. eat FEO E— bigs ny Pr a tr Yoni sp BT Br Wannabe | 3 mame nb ndwoddowmahase ile ROMO. SAA 25 {Pages 23 to 278) now. phippsrepor ting. com (888) 811-3408 EE 73 fr msm D1 psi to, sabi : “Sees Yeon. D3 ame eta eye a dad evs HN “Cuan And 6 evr bascoccion | 3 monctacse ge. And ne spol me © tegen madon sp sivrth ren? | 4 igh ong der i . “An, Yost th, Ha [Yr — « “Quest: Ou us cee sd 5 nebo fae esi i ere a Do hraninthet we? DT pmbankmadmnthotnl | . “Amer: Yo. Jab bine. 3 Cire emi in oder ra 5 “Quine Worl 3 doe mei 30. Wied eh gcsivn tht on nd 390 FL 2 wens amsringe ht “rs Tov Ge i nL tne 3 oem oni dein, mio ley 3 pr Dll ber agai ad 3 comnhyakyle lo vs Lm ton weno pasa pany Hansen wren excl ali wacked 3 ones snd sch ong lone uo Em ER » ME SCAR Ho im 3 MD ler doth baths | 0 VR SOOT: Wel is sbi [ER eS 3 hanced HE VR SCAROLA: Wel éxn a“ [Ry — ta MI SCOTT 1h wo rl 3 Dab Get re rr? © 12 SCARS: Fae ess 2 ARSC motor he 2 awe 3 frm epee on sani kin tw WE SCOTT (Hick ess teeing PRE i —— PH a lama = HEY TH WIENS: Righ ED 2a Vesna Da sens FR a — 2 Taegueun was: ego 5 ras of our end Me Diao | Fe cht mesons yo? 4 pam, comers? Poa WE sd ene Eat nd i Aina DS oie sent cess ve =a | iskoba + toda oT maemo dpe | peu ira a eo ibe TN Aiwa Fly nis © reo pean ding conv ot 7 Tein 1% ow forbs ozs ok ne soul a Sonn den pc hb £38 oP crnmormaReniut a Voss Mus sci caisien : ch e HE Se hi thats en ens 3 ht ooeren ne enof Na Vermin | V1 ar soo eo, 160 3 sib hese bend sod 12 rye conan 5 ER ————— iw he hace dogs is on 130 iste And vey Hoo cnn = ut aes Fecersiy iene DOS obs com agen 35 ayant plone Gta | 1 orm. Vig Rov, wh ca Ee 10 Turco an twenty Dg © 1% Vig bers? 38 cere st nsswnsd 5 et ed, Un rc: ho. 3 poner a Vii RAE ide re 5 0 i —— DB Cent wm nds 0s? Bom act om vo be ns 3 Toe cnt ol hse gro, 2 ediebery moe my | 2 lwo be 3 dri Erato SQ Whats vi, less ctv get son? 3 ee puede bag winjedind 24 Facet ms ed by es Kin a 2 vd a pobrsh fw sou oH Gontan ste 55 be may have Bed sn toe sen i. Epica 26 (Pages 277 to 283} www. phippereporting . com (888)811-3408 a a — va ivy | 2 3 Seiisneassisistuie 3 mini wel Veutopeiuad, Bu 3 nesters carmen pier pes 5 TO Boobs | 3A Ya scam me mom : mE Sem gss oly + carn 5 NACI Ni Ep pene vn Tsien tra mana i 1 Wh sao Co a an ste ns 20) Soon bungie ben anger | 32 Ghd vito ch inte | FH he A a RE re LE 1 es hd ss ith BW ritommior | Rian IA pay seal sven ] ae weak sCanoia 5 "hom scanoia Pa "amr 20 Menarini | 3 a aT: wesc Nahe tenng? Pa comin miso 2 Torsaeg The dane | 32 ser i. song bri 1s 3 i de mA SITE | 3 member mn ey ne tence regedit. | 14 mins © msn [RR re e——— PA fe WEVORIE J riviera * DYMRS0AROLA: 17 coe, sasdewiciom + 0. Your kno ihe rantex in whic that |e 0 Wel, how about — fr Pa Som Wun town 350 ou parmente bith | 1 4 Vigra im 1 1 ot patton a en emmn | 1) DMR SCAROL { 4 Veemeniey rie | 10 a team remade | 15 Jeet? ’ TE jobkeil = i ly 1 sor vee LG orton in ery bem mired | 13 quanta red heh. atic vis potinatiestrnrty | MISCO. Yok bane 5 Mira Agi wo Z brass Bo Fp ee es 27 {Pages 28) to 284) sine. phippsreporting. com (888) 811-3408 Limp ih pe hws th 3 owt sian on 7 in ahha wh pl 5 A ACAROLA: Misono Ecco pen + capsids wd dd. r= LR rp —. Ps © mmc © meen mor Tuih ys to TAY MR ACARONA: |? ior: 30) Duman wi teaueionk? | 60 Yeu honsges dt Bi dtr SE imran © ed theca td roi 08 3G. Dust ranulas wt the rstan at | 11 compat eb ac, he mond cine ua ve ve SE at eb oe he signee I — 7 me eng canines fe nd rush 3A eminent = imp cnti ree goes IEEE roi SN — ng ew, {5 ewes BX Pio Woman meer esi XQ Yonbue th eh seen wont | 57 nce) Gn tl ode 15 covence lpi on behalf sve Ble | £3 Ia co. A doar hr mvt 35 eat been fortwo ee Kn | SL wack mina nip ie, nhs) 0 andy he eva irs of rid olrey PC es ao ad Fe RL 5 sane blieathor slime irue, | 7 DVI SEARO aight in 0. DM Alfredo Rodrigues, snather ome o€ your © hime ta hand § 5 bes al psn vt 4 mtr Btn FE Joc wold acu kactem a spun | 7% yu? 265 208 A ma athens, if he befioved hat (vas one uf Ia A Albee oie — 5 tatoos Savers | 30 Sein Asch Robes 3 ote Berens sd ens of EO Fg Ty Bre BE ee © 3 mem se ontbezl 5 Ravi me eb 7 rms wip we owned | 7 becom inet re Te CO = = sr sok cng of mal Foo eects rsa omy vie Sum sn omnd | AC rey. borg den esl en [Hares WE I EC ee 12 CB, oe US. tomy, on wavy a, 10 smd P13 oneal aft cess muda mut on A 1 esi, cdr HOLS 1 | 13 osu ah Vi Ns Gatos ahi rata. 36 eight ray sph anle = wae HE iar Ercan eo ins dems = ©. Yom do agree Soe Rol Josclsberg woud mt [LE 1 a arate dosh beadame ie 69 | 11 ton relics a 15 amhmeeeiens arty weet | Me Rdg riots ars 10 i heb en 1 aye (ok bes eg Bee toile 14 Lesbians | TE wn ok wd om aie 3 nme wil key “Ares [ER ———— [ ———— Ese 3 meets | 5G Ne 5 Coram robe nye | 74 A set 3 sighs min aay wood enst | 750 Dua 26 (Pages 78% nc 288) wow phippszeporting. con (888) B11-3408 [ET — Fa meni FE — Pr ae LA meebo is 8 SOT: Ouftae This uy © vot, Wall devoured the © upen os cuonb © Whim onimes bing be gia Me. Ochs | 8 eyo ai scmpitien. These repo 5 odes 2 depot tha is ri on PR erm a |] me se—— : pocion. Mr. Redogue, sos sed st Ym) nines ne bene ER — 2 col amy sien ng yc hein 12 neem gus omlonand, Deyvsremebec | 33 Ryademaoliml Ht ime i ihe, bt nd dt = “Aneuse, Ves am. FOR Pe — bes tion: im in ye Got i CAL lle PE p—— PE —— 1 “amv, Yoo mam, " [Ae I “pion ase nr a 0 3A Ye lmao TT tibet mes thr md fm arb sca bo per 3G Anda seus why stein » “nsver, is mam, E10 ck 0, a 50, os pe tig: Hom aon hin 0 5 23 und hl vers sto un nc ht tury 3 nese mat wn deren 21 ty mas lg a pd of wh co ha Zo Mn Oenbmiiten? 2 angers psn dry Epstin's vices, = J 25 chs Kobrin Both, 1-7-4018 ois a "eto diye ba ay baowitge | 4 dahberg «ofc, whe nd ld be umm. FRY E0 sin lo sould ea wet Vighia 200 an ' [em — © Rene ea pe om freed pons 0 2 ution Vou dn en heer ae mat | 4 acme mr oki pec asses he © meet cing na or the JT Down ely wr 50 ay win dt 3 “anes iio Fond. [—— : “Chuatin. Were here isa roan kes hd of ys le Tenet te Re he? © hs are, ky ded ‘ “ante: Ver mam. : WRLSCOTY: Lec oubian wih wish : Quien. Awd vod tase ovoiniiaet, | 1 prosheemis yo ei mes wt fermen Sw Kelas Rod orci? | 13 hercand at moog dh ps 0 “ha Ve mt, Bop syeien Toon 1 “Question: Were tee aber sour ies | 17 ha Adc byline Te ther on Dart nes there: 3 Dk SCAROLR hs on cin” 1 “nger: Ves wren. 1 MR SCOTT. Vo, ov ten iis = “Custos: th you ve ny a mhothese | 1 ree deep note PrN To red Tt ae rn 0 Ameer: a moe 3 Comandiheh many neler 1» “Questor Ware hers af ht Bam sein 5 cxameme, Wore avr of yoves omer | 12 [ET EE — [73 Sonia comic age? FER pa ———— fa “Anse Ye man ~ Nid cm Wane HE Fn weca— Se dings chitin. 7 gwn- » WR SCOTT. hn i FEN i [oR p— BT CTA [Ri A—— IEE (I 29 (Pages 789 fo 297) ww phippareporting con (888) 811-3408 wi 5 [Re E ET sm——r—— PRs chu A J 3 me, mnie: FER —r % rng bo dare, ion i bi ke nba dy weer 4 umeriprar o wis fre her lie cochsion fri hemi te: 5 barton le, pp i om PR ioniniiu vr pr ———— 5 “orm scant 5 iRise bn, FRA © dst et ig a Se + “un stor wns ten 3 HRA Ameen | oak 5 Sou eens | Youd ed wna, 1 it BH tate Bade Elencondn | Tia evs wd UD msrmaiment nese {3 SOOTE, Mh Sams in belie 2 eis © lena n a, sedan, 3X Ammen soo 0 \mscom fire HEE rivets Tm ak Nemec | 37 whos wom ap men nto I midi emia | 16 ba ten vs ere ans Brien, | 3 Wea ROE anions | 2 macevseoyem wn Bmore med Pa don ar, ER vera CO Ro DB em———— 5 evr mbna XK atnsamiebuiaaged § 3% wom = raced with wow raw oy A Lied i= “on: mehr Cat. El Pe TET VUE 5 Sr ———— Pit rim tote SR A i A Vr hmv imitans Ce tei sper ee N WI SWEDFE Con weave wilemzead | SW ea © wns i: a 70 Damani tig easy ee 1 gente dri? © 3 sees ing in Ang ttm 3 lon ad ou mand 3 yerman rman wong rss, a — EER ewe ne TR er ee] Som pend 1 at to i ta © Ne Dumoe re fore? LA pate ne © Mire Ferm — mai tk dan wom Mir. Dersnamats ever bere when oo of the young | 10 {wet my of Pin 4 wv ey wclied I ume ssa ne | 38 co madmen fri ae = em HE Jism ER NO — 20 beth tort Forint 2 meiom Toten ttiden | 71 YM SOAROLN Sn trom ten Deis 72 Wald ban rcs cca dey 5 metrcotet me oven 23 overs wd et Cons pve led pan the PRR erst {2 dros oP cpl erent? = Ame: Yes" {Lid Ade om. dh ses sat he Tek. 30 (Pages 293 to 75€) se. phippareporting. com (888) 811-3408 ae 293 2 madsen vie ER ER ee—— 3A den rt ua . CONT: Yoo avs oni si © wien 2 fd ik hs a © 0 Norpro der Gdn, | Lf PRs ror oR rr —— © wheendelie DT pee cating dims Ei tenure J JR ng so toy Ee Bn © Se 1 rine, Yon didi : [ee —, etnies td ord # mate BE enalieotm comana sie ore Pr nw deme 1 4 lactams ns | 14 amieurb whenyon ind veda als rr pt Be dei, beh fa anlar 26 ir sono I tarsal dios wih cri 5G Testa by vomaans | UT wes, Tits doin ov. cuss: 36 rout Cun reed open see repo rome | 18 ty ES £0 ba end 39 Ta Bega eter nova nts | 15 pon of Et ax sc bo 2 ceimiral viegns fri wld br 5 Sher parsecand nmseghin ee i I romani lor homily pallet | 2 eyo mr is > 2 eine ey esiryce = ee 2 rmlneu, aeudi er sased MR SAROLA Aras eds 3 wen viadin ie ses Soe | 2 SCOTT: dies do's nly ER AR Ser —— = pee Ey 500 [ET TE — i 3 SARL = res so. . soni eps dey seed ck rd fw 3 pct uk ed re vo ewom wan Pps a ve sea © outa mt oe repr the so msoom © Feder arc of Umm” Doe senna tamsconmingming 3A test utara, ts he QL Would hn nhs rman Vessel © pended he US. termes Ofc? 5 MRSCUTT so Wot soit FO ER Ebest Shane a THE NAINESS. Fos cod TQ od dt HE VRSCOT fata EE TE a) 3 Ulli away amreens | © & "tay When Aa Dosbintic ast 3 dug io MO Rms si mokdse or bres 2 0 mot kei Bal | bite bendy wie © strc wang ret? Hemel! so MR Shenk Kom ay Ba pcm Sennen | 20 "Advised do chiens a pan 2 umm 2 MRSCOTT: es w md 25 ha oh 2 micas 2 sib avis BO Wit he war prec a Die ov lee {25 ann ene pein | 5 tame | AE AIRE 13 (Pages 297 zo 200] wns. phippsrepor ting. com (888) 811-3408 : Gurnee ty ws hr? IR Te— x tty ict | 3 comadzes boy om mbt s [rat — I det tas Ea dot lt © hyo ond? You kn pris! © we Andie snr pe sen trv eke Gon ss ri oY 5 blebs navn Tho any Pry © otha sats nig, eon WIC SCAROLAS Ib sion snd, | 7 canbe, ershd cmb oles Bo Mes © tag mt ogame as aden ey : [Et IRSA ——" [ER Paes 2 ML SCALA Yous 3 ptt pu sop 1 = MSG Rerun ss | 53 stern oa mr oe PE 5 crete ems sn = I SCAROLS: Vol imam sade | 30 Cutts Tes Somes ain psd 1 aneuiarabs vad. Solio dnt | 15 olen cient vm HO amin ba nmr mes BE nti vost om ngs ole bite 3 buses © pen ws MISCOTS, dad conser beioben | XE SCOTT: Fst moms. Sal 3 pesmi ttiodd | 4 pene being serge? DB kingeceph mpeg ad bts | 3 © R SAROLA: Morse 3 ond om thi, athe 15 winsosoe Baie octe ta vent 120 Youd retinitis © opie Ac Tnat pmSOEE | 1) vga hon mete set Pomc mem were | nw [2 wud aoa i eT kadai fem | 3a | Jue | © msc 13 meme ons nt remim cic | Ta Some be | 2 coe. one nbn nls ad | Tr rue Guar ad Pod Colne |} enon orn wi drs © Mecho Virgins saber, eh spon | © ek ie (sented 3 poser Prepon US Averys Ot 5 si ih Cre 5 trnston, ont norman rome Bin Dasch | ropes so nin pn af [I —— Paphos hr dye ie | 3 strani saan shan Fe JERI voi FE SO SE ICR rr v— os BL we esc race he £0 Ldetksonmbiri cosh. | 12% Needy Nady aed us BA vaesinne 0 empl, nen Cm © 0 Umbody Wonkli rnb rem | 1: oo tory wpm ts nro of meematin | © 0 AR IE mee ray of Visa Koes? BA aime sr Sr, site in BQ Yousey gohan i SQ tty arson. BA orem BA hme. [CI Ts Crap — SCOT dnc inte 130 sat putees phason fim ne paves Bn Iva sare 21 of untengsd woman rv EE Po "A Te : Simm vows tris | 3 aS be nev | “ohm ckexinmcabm | 6 manos, ioe FET Po itm | i a 32 (Pages 301 fo 3041 wie phippareporting. com (888) B11-3408 1 TmmsoRrie wh tem Ee eS —— Poe Aw dvubeiceol mye | © va ws i hleosn nok. Do Som: fem sk der. Do Soon Tf © Tews say Pr Tamme hewmen SEs Dr emma So mas © VIEDGUARIER Guam Ta LE Eo p—— Theis epteady Ri 5a eles beta Pim we bent I mph i. Sean Mommie 5 era somo Bm Scum sack To [ER Ee — Hemme i hms 10 MASCOT vb us Fr SE— HIER oH pio 3 cope Da Amo vi chm i, 6 atte reg win a 1 NR CAROLA: an. Them 1 3" Gackt FST tan se. 3 Q remmmermtrtaty | 8 omit He 35 Epstein have Lied wilh repel, corcect? ne elsbin 20) Ne ern ob rope mgt | 70 Mi SRILA: Te Nem £ cata eerie, Jo Koked mrs | Eee asin 5 Vente ttantlait tn 2 panty Heats Dar Dns ped | 2 Tsmscooa toutes team vn 12 Dump mbcimonn FPR Ee) preg En Da eetogsestns | 1 wm sce 3 dla Toa a he tari bebo Eee {5 comput ih at rbd eS. mb———— 18 Tam a LI ear — 5 rm wer + © ton © nts twin abo © 3 WRACUET Hasan) + Cline oa, Tnbnaron- © pvumsewoL © A welt J hep reece J 5 0 rire 3 Sw? t mn if Ed A Yes, Yes. ie MER SCLTT Fok «ama born [5 8 mmr Py Did ria mtmesuriueisodabs | 1A tomb lhe= Exekions he [3 haa pa tor ey frag ro sr ids wins 16 tbreiosin Gece inre atnalsom | 1% andes, FU icin soumsmmmarmg ent aienal © 17 BY HE SCAROLA ban Gost rar Um abst to ask 0m. Fa AQ. Aud fie second pags Is annrher page from a "LR TI0 sei ical that nt? 31 andro msrompate | 30 8 Joke ei 2 ctbhohmewms Sete | ZO wie ripueniiy oR n A. Ukhub, rigs. iB eon yon wasseny QUoh, genie. Uti Pr or Pa 32 (Pages 305 to 308; www. phippsreporting. com (888}811-3408 509 a + semescooia i Oxemer IQ hein tne tte | 3 Ost absense mais and 5 conenhare or eur ie uci ef | 1 the 3 Ge To rnd he Se clan es? a Tk ER te RE Spe Son, adatom bob LR TG om wate ahervsbes. JE J —TE———. oR Net | 6 omer 5 ron: wien vag 2 Vi te ke cms of FR —— 0. ny. tr. Snot he clemr and 12 Guin Ded A Bree | 55 time tar rate ane i peg ve Bk wwe [55 peridot ne HO Youle ot Lede hss A Thelen ia? 30 inom encni So ln in [Hainer RE} 30 Cun rout conta 1 ese brain obo some tl 0 oe nto rhs ae ramets | 1 ois i 3 umpteen Wan | IEA ra AD bun, eile FU a AP fr 20 piston uote at wpa be eceubesf| 46 iri Charen, New Yk io J Dr TH kn honk, ha ALG i ER TNR fey i “wai - Wir ss Matin ce, H 20" emia 15 oe thew nly or © Yonah? = i Ey Dz 0 ecswom vain Gobi. 1 FR Dr sama 3 0 waren Dah Nader tenes FR re — Dn ee FE © emt moat snc opus Conti Meni fs as 500 © coma ee om G00 nA Vivaro, | star aml, 20. Yoh ek 5 ety eng wire ily boo ihm seicitn 15 20 dims Mts ethers 10 ayn TL Chr 200 Laer crate | LQ Dank hee ow ews ding Ki Mado sare docoem a, Okan | 13 (cpt of cei yo 0 4 om Eg ny Dar coe, 3 Fr HIRI pe ———— A Saker HES re 56 oun mes psnein reoecaie. 36 Now Sah. Theserircabs or i TT hsdpa ne ne 00 LE ry Tatra so and ge 1350 Oh Sem nT ame maser 19 Nowak Peete J yon 19 on from ta nledar cre her nr ile 30. Sohuppensneivioakannt 35 dtu ito es onc BL rss sng? SA Tem Gas ER A See 2g Wonca mem ne ry | 5 smear Fa 1a Tr ia ED Srp es 3A Wem 34 (rages 203 zo 412) wine. phippSTOPOT Ting . com (898) 811-3408 EY si Uw sans D1 ovmscanos 20 Ofte eset is ris Tay neon maviaappsr ia New Vek 5 tan es vn oem coe Ala Dba |? 8 Wwe + ism, Ken York Cay, ic FE 5k HeemoAD wise HE Jy 3 massa D0 Geman To Hsien TA Teedagpen wim Sowte SA Ob am. New Yak Gi DE i New Vr pcenetin hes ay PQ Ok hark on HI ER ermine) 1 date hae bnd |S t aw y enero Con FES Su 50 fk ak i Vor nT ein ep TR pao manent your 35 Daa wn gern avania Sew Yo wegomis + Kem York Coa TV spaces cone 5+ a hn ednt 1 xotepm | HA Cw ER D5 thayebens se pan Ne York 1 er wart sary RR —— 1 whens gs, ind. apm tn 3570 Itishad tm pms Vow veh = FER © uk seit da so open Lo Qu = these ere calids Nat you produced ZC pares of Cams 17, wo 5 acqarot theese ha yas commpramens + 71 OTe cece Oe mays 5 pan So. spam he sod ene eicgesd | 7 FOR Jl etd A5 rhe mciniag of these pages. oa a iy. Yeh =a 3g Antes ty ey pte, ET —— FIT ne Da wee HES Te I © Q emeelngchmedotan | 2 Q Wok wheal dell mba? I semen dios 15 X tin iver a woe, 3 Wek schon | 6 Q, Tells hth Th eign 5 an Dt estes 10 7 imsoom wosstatiaiorsis 5A Lae i ~ Ill of peges. Yeu picking out cc. 4 Q. na chs calendar page. © awn sown 1s 2 Gmmanrin tein LE ir —— 10 ty 13 wesw eve te Hinton hans, | 15, Tn re tone peta fn 1A heh cn Ti, or 121 Ducenber 1 when es cme dt 1G Awbenomamedatmisacsndir | C7 ies 10 deft we Xuon run he ght uss Lt rm Deerber 0 {57 tins Epi re uA 150 mtu neato Apo Terre 1 Coneopeissmeombeton | 15 rp nboh de ive pan ahi tar 1 Deoxemhr uF Yom? 126 eorviors the Now York Metwoyelivan ar. A Teh 1 eorattn, 55. Ambre sans ht dregs BQ Vest? 16 utero srl oppearsscs | 334. twa vb bom © fare vem C17 ph, Sent dee HT fostsaemmbtesn | 3G, welts yar avi be ae amwuer he questoc. Five | #7 Bight og Oe sd page. BL bu macaw eens | a dees He undotionsien boaConty | 2 OL Yensi PO rT ——— © A ly 35 {ages 313 ta 316) wire. phippexepozting. com (888) 811-3408 1. Dewmber1l 2000 PBIw Toteboru, | Thor, butch vou meee New Yockat dhe sr Fw | 3 A. Waite secced. las te mil. iz A And tha Canby i HS Qu Dicenabes 1. . A hoe a iy wil pt umal ese 1e Ghislaine Morwell. Doe wcuidndac | dm the moss ark iy. CORE | wa AT whe sag, sen vi. 11% tenon moss, sow esa men soesioesn i 3% (Pages 317 za 20) wine. phippsreporting. com prep EY PS 2 sca Pr MRSCUTE Ween Lat ore © TQ Pry, maketh mary (bat Pa 5 soe rebel Ol and Vo crane {A Tofoconpas. ase Land i — 3 Twente Ct Tenet? LY ser ester 5A Noma You el Por TR Ser: oo wesstanert © Q mms © RKO 2 ee Bae TA ne a Ue 7 heen dis ob 5 ok Gost. roams Nr Tr —— ER os ey > cing BQ ony seme ins 3 Ee 11 wok ote, ha Cone Types? 1 diy? ia ve PR BQ Oka Andon he Kthon Tin, [RE FER Ep A —_—— PRE vey 158 hhc ve. Tose 157 age df Campos Fb Nambe 1. © we 16 MASCOT Dua. av. [a —— Fava scala 3 USCOTT. When 151s ih 320 Tua. thei Davee FER ter ———— BA Tes. | ®t © remetidm, he vo dm 8 J — Fra I SE Tt li IA Vliet ec Fin hk *wmscaos 3 yar door bd a WT Etats ac ER reper aE ——" i vi ia 1 ovale ise Fy own peed | © ame ER FER TR Tr——— SQ arn Le ome § dot we i, oi Le page tenes pein Sto ey, dum born Jomary 200 an Diy nary 12 5 al Cuan, 0 date oN owt sing be sn, ry 13 [RT ——, HI ERC —— [Rr ST — 5 NRACOF: dlr Lele A Nadie. dudes bing SE hb pen oe] EC Yok irene doy BA upended etre Comrie: 3 Cama tat de abet | Fhe ak YO dc, ten Pe ivertvtulymisrlrebinain sy a DREW SS RO a ——— DE mgt se on von S20 SE mi mee Phe Yakatls | 26 nyse iran ees UNE Ea § 1 ociasehelinRew Ye, Seesmic Rod we suo: 106 Khe inf Yak, Anbaehid omens 350 OuTumien nV archery | = now rk fn np i 3 atop bpm eh? 1 7 anton mitaanany 2 temates { a A Gotu we ro 2 mei? i =o vw Ba dee es edn BL wise when omen? ER WO hued Padua, | BA arb okie dam ps 2 atin sp {3 0 Gotan tom 37 tvages 325 to 324] wn. phippsreporting com (888) 811-3408 PR— | e— FR — 1 Gun Oro th a north 1 RE mm dees smi Cams PR : oe om Fv DT rei PR, FRR ming Prt rm HIRI esrompbmgimiind FR pheno | Pre 5 eam ot EI NV .— = Tek era | » SOLSCAROLA: Fox — oaks | © te Tae wed wa es BT Ee Berra + ir——— et ——— BH koiremm——————_— Pram an © mt Bama [I 0 Seem amigo tmesncurary st has Com {25 rs rc doe A Ee EARN Er 5 Gla arn Hewnrni 5 3 i Comal, mn ois Hen | 33 A. Nk dm nll [rE Spmirmegiitvr on pal SE Be 1% "Tw ~ at I EY | Coe Sembee | 3 HOT ol ae re | Smwerinsn suse ern © tin engermmatiin 3 ramen [ERT seen © ite led rma 3 mime ri [7 as ves setae 3 Se helps weer Se DIE | 2 ME ee EIR nee it fete Fete 5 ingrid cna Bo wl = SCOTT Loti baie, | 1 omen. Ey a hsm: Tu keds Hh terested 3 nnn ing ce ry EE 37 on Viki my on. lo dC Sot Bunn rr 30 asad PB andi i eer vendita, | 1 Somnath oma Ban ma sy ov no wasn Be Ba he maps on sisison, | 3 AR SCOTT Tk poe 6 J PE 5 sont usm =a veer ur ni pe 38 (Pages 32% ic 328) win. phippsreporting. com (363) 831-3408 a Py [rrr Ta SE — CERTATEDR Reb T4 ER ae 1 imeem on ime STAT 0RoA © nan eh sams COUNTY orpROWARD Pr © hm scor wae. LKDLRLY FONTALVG: Regs ¥ bo SAR Pe Agog Lr CS . ; : vi taco ond i metic Signs eons Vig Ren iP ew ni + repsng nope pnsgeet KANE » 348. SCOTT: Amd ak sew serv woh © IR yg aos 43 tse of ee } wi ne ote lh Te empl rsppreprive Sana Tuomi sce ion of mg 2 espa ' a’ € » n aides : He cen rs hj I Ia ab istiva il a, ch, hey cr 3m Suis. Maries, wo ne | a Ee C8 yi i IR. SOA Ys Fk yo H iene iediahigy I A i Soren ie 32 To pee ADJOURNED 13760) | met Ftc 03 w i FY PORTAL FPR FL C1 3 ; IER 9 Chr a Loses wean | [= COUNTY OF BROWARD HRS Simson wom. 5. Edn SI natn Lisvarenagmd has eau Ed pom mab re Te a — EL tr mand yor 18 Ea hae Cute, Es a Np Sir i 6h dof Oe JOE. Free pore Fok a fro LL SEDER 17, k FER Fora aiing eu, on a ad To pm ptm Ebon Bry i i ow H) intB Bel Fat de 3316 t HI och dion i 33 (Fages 328 to 337) ww. phippezeporting con (888) 811-3408 EEE aan H po i ns : Yi LE } EE 40 irage 333) ‘www. phippsreporting.com {888)811-3408 2 ahs th hd (HI SRA san Fl CTIERTARSD CHRCATTICN 0 ol | : di a SUE ae Poa rom, tree wis " I] ow SETH = SE FHT a PRT — “ | ¥ H x I u » Sahai, bE 20008 - » HET H hd CRA rime gemma PIN co. SN Ey i iii Smit [ORT YE ER ——) | NOE — 7 ae 2 th mire hn ahi gran sd sh en fav 2A suri Sothe fiat bastor it } vrs 3 cootete rth tho bt, ons 260 rf for 3 waa i one 4 stsgezen. cio 4 MR SCR: Fuso a, rs pct i ww § A Oker, Therenovinatobe—rginate lun § Los dbs Cuatro hoe an cies 6 end wp giving you nine (aasans, mach of which is Laon 8 xp seam and heporhat cals ae. avn 7 compicata, oust vn to 1 dont con Tepe. on ins kr psi ovis 8 onto be cused of — af pasting or syns. | sare 8 Hsp Fito tases lin to ot 3 Hjustvantyouto now tatyou hve kn brokd | 1uns 8 ans, HE an per cin. Com 10 question thts Gog reir bond sd wctendnd [v1.2 10 i, Sones | dame, oa me Tra 11 ons, Tmo dt eqn, fo 12 0 mre cusann peed I) fact] A Okan. ThenTmgcig orskerton= thee [va 13 berate me esi aids fru 14 am vee scaly, £ don, eT rere tor, 1 fom S 0 Unrest Reva rte ants arm. mieson: pi —— PE — — nt? A vem wo AT A Rigs So thal Te To the en lE pues meyer bet esiastions! a 18 Speetete TAnVE E can ge ti ams Cron 18 bat bis oe, ot wl 0 Ro oc 19. a tis pt sacousa tr would have vob aia Tom E0 me. Totes 47 vn Re i he ws 20 Sack sy hem t= snd eeviog ovt whet te aml war, Tem tant ed aga ea wt, ra 21 f things we were going to presmst 1 Judgh Hot rive 22 ofan ume, wht aa cm no rvs 22 Uf the peste of Un ca 41h pes. Cove 28 damn? Tete, Wok wadd yo 667 zs EE ——— lee 24 A Right 1000 24 have --lot me just — withe ut going fate any fn US WCATIEY, Wah, OuesE aot | aves 28 ator cent eivlcged communications, Leni have ‘CSCURE DEBITON SOLON “Zs0uRE DES TCH Sou IONS i fr a TE css 1 oredr ctu sc or hs tons. ce 2 He SERN, Baan 15, Few mntls [o 2 [rips t— Vie 3 mensions soa soc tram nmin [ane 3 oregon a i 4 Brow sneson: | ig Tok cussing pd os ron [os 8 © lee sme as: ushered H wn ® vn Waki snr meres ur 6 shut - sareehes bot he bas os is hams i fe 7 dois i sans cow 7 ht omerreors. Watra ee amuses | pg! tod ot ct: Wht hd rs 8 whe vai ders, waa tome ews 3 ows saath gunakesets setae (cis 8 on ofosceost 300, 2014 al or vod Bcd basis | ne 10 ve ure shea covered, and we eve, tink, evo 10 fm ou or na steven ssa ves evar. 1 PRAISE St vi nr TS og Jeep H Cini test eles nnn, frend snmerte teaver te se ton tek | pg nti ances he whitest mda i frente ates yur ron fe ekg hm fee 18 dint yo one i oth steers fron 18 J pu a SED kh enn 3 EO m1? eae vas, ferent? de Liar, swan, be fe is 8 { an on scan: thay lon 18 desing “ora marist seis | Heants avr sums rots cme mesma ewe [I a cera ys cares sme, i Frese 31 insu 300 30cge Soma ak yo, em, ont ce 21 re, orm en och ak sg vo H [nv 22 wren aces seston thot vorcer ea? ame twas i i oa 23 omsounz ene char iar, ave ncd v e8 2) ba, | i 28. i kit ssh ct um ate, [oe 24 AYR SARS: | ce 25 en cot et, Yeh wed yt th HENS i S53URE OZR ON SLUT LuRE DESOSTIN SOWTONS | en 31-40 asa 0 i Err TTT Rms m Tin shee wus 1 sppens vt dlegeur. wwe: 1 began, you know, I guess what we would call 1 nt E ara—————r—. Hn a A a or van pil Sa oy rl NL Ar ow 3 rewmm———— Jove 8 mt sins sep st oy ot re ah a TR Teenie amp. Hn J ja tt any baa i 03 pide oe A—— wt 2. sound 2 4 sets te ne est ewe 14 inclueieg the sbegaten choat ether caine 5. wie 14 Floste, i Vor Fhe amon manbsenc econ sort’. [mest wea ene Eat or A ere un AT body of other information. cris 17 just boning perpetrated by Fpstein, but by other propia. womens Ie Sa bn SIE om wer onl | J ATT #422 20 Desch Police Department that showed for bout a cr: 20 Boganment was putting together wos thet this mansion ave 24 ‘and on some cass It wok gong an aot once, | crsi 24 weve able to document of sexust abuse. 51sa 26 mat turce, bot thees times during the du. That— ist fans And hen you put thet together with the. i 1954) 3314400. 5a 331 em) 1 To 2 emma Taman Hm 3 wpe ———_———r Tn a amrr— 1 3 a vcr | 3 ST mr. 3 winrar. | 1 Tae ——————— ove 11 tte resane rh steerer IE A A il Sr ol a —— TAR re a — muse: tt Toe irs mee: [rts Tots T—————S———— Rr ean: Pl te IT es fw di avemmmanrevronimmsterry |v 1 smm——em Tats Tr —i ros eon oni i wt rr 24 vars ors: 24 Jofey Epstein ua is sae abst hat, you hive, ie TOI i Bie is Ws EAL Err Face at AR or 31 OCEANS CLT TH fiver 1 other sows parsons, For motmple, arising Marsh | n.5 1 panicle sil hol been seximily abuse. Foaca 3 is thers with Nom un sl of hs (abs sid apiscenty |i 3 Wat tha Dab Bae Doles Beportment had Hen 3 ming nvolond in these ENE pe ———— prior) Sndosd = 3nd 2 you = yeu have you rian 4 anmatinas occuring 36 anon 35 thre times in cas 5 Wawa tat Yousise star 0 see on the fight oss, ie § partcutr day. And 2 thst ed me to bn tt 1 “rv 6 winst in my mind are some very sister things, anus 8 soul activity hot ems going on in orks as sch Leon 7 rugestion thal the owt dy not Sus confiong 10 sort orca 7 tht someone: who (ek Tagua HOUSE USE here would Tesem 3 of, you now vege ns re ara Flora, bot [SN J —— Ln 8 Hic axtansing wore broadly. urs 3 ook, ase, tere ar these underage girs coming in har an 10 Cle ane ofthe — tomy mind, sobbed and [in 10 30d they they soem tbe — you kno, hay dent seem cove 11 scar things on tho fight logs ig wa ame you Known, | can 1 £0 be hore to be doing. you know, loess acouiaes; otk 12. Virginie Roberts, vin wa know fs boc sexually bused, | 12 they — they might bara doi other Kinds of [er 13 ans vie ana atlcy Epstein, and then we soe on the sr 13 activites. 50 hos woukd be the Binds of things ht wan 16 montage onc forse. 12116 woud would have forms he chutes toes 18 Thats Kind of an odd neon fo 2 at ori 18 “These ave other things wl, bt I sce coin 16 og because you Rove Lypicy, Tundrstand tie 052016 you oni ts ic tos sion i aden to that. 55 Cox 17 ah ngs, the purpose cell, F something oappsns | ouz 17 TH sto hers, ba thom that's —X think gives finn 18 with la ash, or theres zoma question about who wns | sic 18 you 2 mall Saver of ha ind of avidonce thet, you | oars 18 Ont, Yo want to naw who wh the parvo srs Vax 19 Kowa orm — snessiing th nilgations Hit were. | fiw 20 wis one fight. rc: 20 being prosented heen. | fen 21 50, 0 oy ind, whe starts to sc 00 ai 21 Qos he yn ge mosienmisy bere t Lien 22 hte lah pe anti Hho ans fomsie I viewed that [os 22 Ut Hews ws Arar edcence Et i. Cpe Fed rns. 23 203 potentst devi for obscuring the fact that wre [aon 23 ar aes a sexs min; ditt H [rane 28 wns imecrtote vatfickin of derege sit or res 26 A. Think “strom” wiklerstatis &. H (re 25 suronns of sm ily. Seton tc fens. ase 28 i crt ans es nd FAQURE BLP38I ION SALLTIONS. £SLURSGEPCSIMON SCLLMIGNS se mate " JE w 3 pe ut thon that cutenco catended you how, si 1 exemter Mors Deshomazs rane sec. ast 3 mare broaaty than thot. The evidence abe stwiad fo [srw 2 A. Tsai fight logs, And ets alk abot ines 3 shaw, zm Fe th St abot ght dog, hat ics 3 abelos. : imi A the — thek undurwae Gite such 36 Virgiala Roberts wore [ous 4 Q. Iatrahak ap. Vac cir ovanes hs H wns § haing flown internationaity from, for example, Tetrbora [meire § Fame -- macro hs name eres + bat nlf you i vast 6 in Neve ork = to lotions, at pick on. you nse 6 ocean sz wt owes 7 Ano tor sxomple, in dom, whars again Sexist abuza [aims 7 A That corms. We wera hing shout wos 8 vim occurring. ice 8 fctuol basin, ad 1 4 lad — I Ed you thst there pe Ad ou tartan to pur esgetner is sin 3 wn otha Ings I a wi, fac bass for = or wos 10 yatta of enmity et was started in this you | wae 10 Wi. Derstiondts, Til bo atid to dd het in, Lat me ra 11 Kn, T dat now what the igh werd bs hare. Tat [ure 11 8's = etme fet mo woud Kis Lo supplenant moc 12. vr 9X don't want to you brew, you've heard [aie 12. my smber thf cute sie 13 dicusions of ymboby 0d tinge Io that ture [ons 13 Q D9 pe wart 12 ose sto Securit dew 14 have grt ha as of — of ~ Ind Twenty sosken, [nou 14 A Yes wre $5 bu we hu tis mt of const Por t= [a 05 Q Let refs Fos wn shaun ou rn 15. sce tobe sprog Egat nin in Naw | ars 16. neces wv dn we {21710 cence St neon 17 Yor € seems tobe speeding n Gitatne bisxwelts [wana 17 auld ee 13 tt at nt met 18. fakin Londen, an -- end — 30 1 oss on. ss 18 sir Dee a 3m rer oy So these sec the Mindz of things that would [sax 19 A No. wen 2D haus formas tha the the bis, particulary when | vn 20 Mo SCARUAA: Ard eo sa ha os ies sia 2 you = wien you stat sedi thi cl: Wht the J A pe 1a 22 Palm — going back nour 0 Ford eth th PIM BGS ara 22 pve Fo, ln ASE pou be Some 2 23 Polos iepaetmant, What he Pati Basch Poll fomw 28 noses ne cumin isthe nen sabe 5 H yan 24 Dogaitment has -- had discousred was not 3 one-off kind “v3 24. anc 36 vou arden the nhwieaes $0 er i Len 25 of vant, vou knows, on one particu dur ene fran25 gaat be mls tat no cue, [CSOUIRE DCPUSITICN SOLUTIONS I ESQUAE CERORITION S01 ICS I 1 SA STR... S——— Ee TREE ET Te Er a— ERI ———— a STS. hr an me 2 mma balk, you Kon, rt soced by iB em ———— we. 3 i Etna boil oo oth; 4 THE ns rem lone 4 other poopieto sme J —— joe 8 "anton the cote of pease st wers J NP fri © sonal sing hr were ssa sed ino hat cw 7 team L207 nemo iin ht congo obi I wie 8 om sembumion. Tha — ok compli ei niu | wT Time 9 that ce at hg fo nt dds 3k te a mam a 10 Visine Roberts ad besa cass sis 1 thse feat G-unit ru A1 sutousectiors, and tot sro wir iome et A mem ea 12. rt ra ight bt et thos eer + common fraud Qe ys were revi xe. [ras 13 scheme or plan. And that, fust a6 Visglnls Roberts vas [ema 1a A 50 hal -- what I'm Going to do is, I'm going cus 14 being trafficked to those powerful people in vartous Tn 15 omaha hrs an un mlepad ofa rons 15. loc, the ht well o or ot. were 46 things, and then I'm going to compare that with notex | eae 16 Art se T pun mentioned u fight bog, snd bet wr 37 i bre here may bea coup BAG ht Tonto 17 Jou you ent 10k aout We. Bushs, G1 wth: sone are 18 on Docembar 30m, 7008, was war Bk rn 8 [ing Sh SE BP “an 19. tian lo showin Wr Drshots rr t Ttens A vem ive 7 who ar een mt toe eT J RN rs 21 gin is vii or mati he 22 wet pe Fi | ri B A Yarn. TO phe you the totus 153 23 nillionmie wh vas heavily voived in fnanast H m2 a an es 8. mwa lama Tater wren shee vith [arn 25 A ana ar Toh compsievmuhst TSE [ar 25 tr Dabo, andthe 01 ree Ptw——— FR ————— rep do ae ram : B i xs 1 ther. So metinmd the pam Mesch Pot patent [vw {1 comet working rom amory 36 wa vou ware Hori 3 ove 2 wonderin shut thre wes o mat that wr 3 he net ha Tat a masta the {eins 3 He. Dons we a lpn ath outa anes 4 une Doc 102 comps, 1 Autor 200, 860 Tm i va tt i rt vt tre: § otanbarg = abot fur tet undead avery isin seeing Me Gershon on 5 a0 AE 2am ir 6 asain yr bnin horn 0 0, mre {3 he sos sn nr, many arn ane Jit 7 that was solctnd by th Und tates Gcvesunancia | 5 7 Un sexes rvs o somethin som hose ies wh Jon epraent mambo otha tho ic oat ad an [vB 1. Seta, wh hr. Sti. 1+ wo echo ret 9 veal bse ey Ein Woes aves | vv Bond wth sn female which sem 10 lo ban tert 22 AD. ars ath prc tht wn i the Suva 10 cate tor vein eral sx atin. 30 ei 11 nansrssscusareimen gf ay i In Arto 300%, he es compton [ars 12 [Pepi e—— os 13 beat ot Vim Ropers. Tat compiant ndeatsd | wm 13. hoki fd cts. Darekar suins rot 18. to Vii Rabe at been sev abused ea 18 cine ne Lets ses. hms int Wis Rotate aut 15. Florin, Now Yok, a ath pices, vs 1 215 vad bon rend a dn sort of ai 16 rel. ting Sst hat pct ral 18 th HAT rs tha i. eats mat so, Wis Raper wss[v 17 A: eres | Th RM IN SG A ro i ory eed, Luh, bine pote, He [wa 19 ana Jr 20 mentonsaoyat, at ms mrioned sarin, An |r 20 fe ——— EE pA ——-——— pe Jp ——— I rR AU re i +523 tena, thot scoring to. ver, vey cron we mess. mr. 5 sou cr 20 arog Deve lorie bc a found Vig Sobers oie 24 Lota sas. Sr emer ot hr Lr 25 1280 cod, nd ld et 23k hoy i jr | Foun serv SoM I SS 2 —— EEE Va i EEE fa pe 7 ; ae E£] Jp — —_ vs. mca ver PN Sr — 2 VR. SCaR0LA: ~ ahokrs eeang up od mw 3 A No. X'm just trying to remember What Twas (aoa 3 down ad ©'acting evtirhady nthe mei Cas 4 lain boc with wih regan to | i nasa fod ws tents | tear 6 MR. SCAROLA: Do you mead the resporas oad one § ised sare. [ mesn, we juss eve ba selle : bn NE VNESS: Yoh, (akon dais, own ToL stan cut, Lc 8 pets Tp py} MR STSON- <a0%, 1 recon, tie sar thing a? We SCaROLA: tout sic ss ws asroguenng ar to ree i wo THE TIES: en, 160% it er int [Lars 10 WR. SCARE Ho. ; bi p— [I A | naan 12. M3, SCRROUA: Just red tbe lat cause of eas 12 sie <f the tabi. H rk 3 hence bc, on te ova evens [ieH ius: vo To wanes rt THE PRES. Gn, sms. Now varie: he 18 sve bv imped nS da Sr wee 15 ancy what ve toning in dS dug We cnt th al om dors. he ay er 18 nd un a ds lr Elen pn 15 GIS rs Tn 3 on raha THAT walang waren wi bom dita {rs 7 Ho se soo a Son net, yo el Vw Cason en ups fue pe Vo A8 vk moti eg lamin do mms ak yor Lars 19 SR SION: 1 oll cps od et stan [read chmatraation, stot me oy he woes 21 ani 50 what 1 diszavered when { started te. [omen 20 siquimerzation WB User mn fpn vs sana |1an 23 oss he smart 24 ton Darts, Sng rhea, wel rn, | ore 28 AR SHPSON: Ko Trai. wi 35 bower vvet maw ote et ig Pi ScaroLs it someon nis <a SORE DEPORIION SOLINENS ESQUIRE DESGETON SOILS retry i530 35ras00 a er Tom 2 he yokes to to me ree, He 2 VE, SOWSON, Fa. 0a, ot. ps Ss NA oo i. Scirus oko. Toa smn on 4 brated eet bev pip vr, strstr Jon 8 Iced too. sis bo vr og reprrtzd [wn § SIPEG wT yeney expenarens lege murach How tereras [mon 7 VE. SCAROIA: Art sou dc simone it oon 8 ovatus sn rand ck lean [os B90 Inara os epee been poping am won 8 ome ema tl ir So mao wetveany, curt? oe 10 a ty Es sa phn ve | ana 10 pri ai—— 1b Ars crcor te thas eat snl [ans 1 camecrarta me. Tis he any 3 En snare wo 12 aig brn aed i, put bran, t V2 abasic Ti ir eck st wns, oa 13 igo ard simi Figen in sive ont 19 othe 8a sto thot ns wll prs rots mt ee, mat oe stv es arr s |e te wowxgeton Wri eto he ous Duc nw indi A, SCAKOLA, Oy. te ily Wate preset fod hry whe haan ond | ies 16 VE, SION. Li rl aka ke re vom EST op A SR J wn T8 an adem orn, Yous centr [vor 18 SCANS wl il forthe FT FL apy Td wane ia 20 ha dhre Ba on ile Gr Cue 2 EB is cifesemteen wen T1 hares; mrd ectety whet mgm an yn our chet zs Lv — FQURE BEPOBTON SIMONE LSQUKE DEPOSITION SOLUTIONS 00934003 eyes J iiss cam Se as Pr] sing oe Fan wlaese, Ft Bune Soty 1 TE Tes 1 iaviaw, in which ha took the Ffth whan naked quastions ni 2 Sc of IB 100m Fs Beer GITECISS 3 tons 2 abou Dersovez. pt arin (ng msn | oer 4 kom tether ets at tid 1 ip on 3 wvamm——————e eam [oh [Hr ee § over Smvon ve Soviet fran acterization. Tha Is anomar attarmey wm § Epstein is at the top, 5a You 70 to the next. rato preigien irs wan mwionsiaatmtian wonton | Fre Prapissi— roe 11 0200 tn ray sue, oi | at mi——————— ron? w—spmarr—at ot e—r——. | ms veimvemarens tres von T8 hot soveolr eset stat beon east ste con 14 vou rund einer 14. victims, bat thay conlinuad to -« what they would do le ra 17 ure Pat uervbody nas qilat = ernss 17 Andl 3 whist — 3 the Ak person 1 wanted to ' 1 HK. SEWSCH: Anger. cies 18 talk to, you Kio, and got information from wes Soak | pista —— or 15 atin, Son etins ona seston | [I J—— [725178 et ewan hee oleh er wamaront wth zn ss: Ang Le me ck [rt 21 Epstein an others, and so wanted to nk to Soh Ty fez alm va le mats 1230 Sra etn wat sh tt ln Ger, he ok erm TR ew cous conn Ire Z8 erie siete verve Sone POSTON SAUTION | [pt onan sn TT wu i C] - mss atmo, cade becom fe 1 Town mae oink i ek Fn ww 3 aon Lean 3 Ana thom there was Merci — Miss Marcinkore. hip pose—— [ve 4 hse tks. Set ae Ahad wae 7 By MR SINEON {3oex 7 both tha ton Mngoin of the sex trafficking wow BQ Guay. Cony stun er? [i= 8 crpaniention and the net scheion ha tke the Fifth, wn ® 8 Sun Avnet te vee tetond Yo st anos en Ao bri. J J Gy ie PU vt R Swbmesbemtvgte devant ond ER ven Tz ems anaemia 4 |mat 12 ot ten emerges in ra 18. Ancram at taht, wt | oe 13. sreered rsh erring carmen sof VoL 38. caves wt send owt tn oho haat | eu $4 wich enemy ibd nt, [7x 18. scr teste i Fi ets oe 18 aren et aa. ct rt 172018. meme th mo siamo vt Kewrs |e 16. bead ti ames res ht vas in Foi? wet woe bu wet stg ah Saves I or iarevp er teamed taiwer st rt vea10 Tarsenet aki sarin t= tatty Lor? 18. Draesraarton pram. Anenonroeson Len 20 internation sex trafficker vio taking We Fil naw. 10a 20 auraament vas bighty umusual. 1m 21 sehen askin ious Mr. Deshantz. tow 2t 3-1 had been 3 feders) prosecotor for Lien And wa Tvme stymalad In brying to get ran 22 about four years, I hind been o federal jude for shoot VENT matin rom eth wl, Xie vc 23. anit, 0d een bo pod Vee 2 rs ere or epuins,§rcactet ofl {130 4 br, srprtacain pie f amare. on 8 Tra 28 ptr vote ts ved reerantt 5. oe 25 tn teat wet veo a rer ve 58 esas sercamAS yon ] [A om rsa pry te 1 he rte 3th Bch ity ris 1 chs i hee ut esi es fr. Dont wn 2 room (is 2 th ea of hi tema oo ving ve Tae wt vio tn snore [ase 3 evga. ue atn Hii ld for ve unin € amccnan rt ca, ts ase wll reverses [ner in os, 0 GE 50 ve voor 5 soetesantor rte at esse rs § Jarmo ent vw § wala. tt of is pin tot ony | pe ——— 7 of fot omen bo worn Heed ik ats [1s Tat ee pin, a tari 300 a my Te 8 162 nt star a ibs potatstcrconmty coc 8 lok wad mfr, Ad Aa mi, mo mk ws | me § close auote. vo 8 noting = ina tawyeryient capacty; isi in i wax 10 Ana 5 that wes unum brodise what it = 1000 10 tena capacity. : Jan 11 shot #8 seemed 1 bs doing win that amici thin eran 1 nd 0 os vm Ass putin im hare | Sn 12 seman nse auf the sort ad rn {on £2 ie ne hi gout ic wre. Ang one ie 13 dein to aves 1 ine Beas tat might coe 3 fh he the Ee ok kd, ! wer 14. Savt mm sree wh Soin [ies 8. Ake you Know 1 abe to furs et ho ths x 15 arte ot sweep bunt the van 18 ae erer as 18. people tha were veld Inmagine may coe 16 Aohutogra or Via Tovar x svmte | Ct 7 ml pion hut, Seats, wha had son |r 17 J ben depo, 313 ED 0 : Te 18 hei ened, not st in of he oem 18. homes a8 yout. Ybor ad os 12218 agreement, but ha i been invodend restarkablyin ran 15 Kacw, out ovo and tw touche an 20 tacit crt of tae ie 3d sig foes 20 a Cin Tr i rm 21 sim Mo om rt ems « Sil oe 21 the wim arbors on oni a Ton EZ tpn wt wn rs rb Xoo 22 toss vain, yom Sr ores sphere | leona 23 weds — 1 dont want to uze a technicel term, ev 23 and doing this four or five times s yew. Tex 38 somermachd ht dfeee srry wh magn [vs 28 ow Ale wi oe nt on. Thar 36 Cn 75 enim ath wo mab cn rnrcsiaton [ok 25 Ard Runt ht va Ur 50 2004 005, i EQUINE CPS 0% SOLUTIONS FEOUISE DEPLISTION SOLUTIONS ues 1 hath Etta ws na acti minor is when |r er th in nod sf Wigs Robet, bt prt [72x 2 we Peimasen paves Beparmenchedesteco ros nem 2 otto common shee or he hte en cussion C3 kom 331 the hk sa ant oe 3 Ltr & mrtg soi bout vs hy hat ake verte [cn A an 2005, ARs soe veh ver 5 ares vo kno he mann tive amet wd [1 +S 55,0 Svs ronte hes. ms hem ten ers ara en a——r lun © wo——m———r wr. Foes 7 when ome 7 eeamigors same rvmesetens Spee | nd J ——— ore 6 shor my o's te ot ts sm mh sins far 10 So the next stop was to say, okay, let's see if we can 11710 Department reports showing that mazsnges are of n sesual | rer 11 na samenac, vou know owes etn he oa knows, | ves 1 maar san tae pt wd stn, | era 13a benebold splot or svviing Bh tat arta [rn 12 oreo te hve ht wo pce 1 oo 13. ween srt tration ba Yo oe, wives 13 rant abot Radi iat acs ho Rd ra 14 cia ovat dn. va 18. Vt on tas 9 was bn ats aie mock 16 ave te pana of ho of tha imi a EO SY mi 11 sewn 1 nt conmicnt tak bys conn | ves 7 here nek lates sumbirs o. we TE. web erat sat com anc | vee 18 ot Rg ad 0 yu Yo 3 ra 15. aes on cause Hy ante 2 een Sn 19 que hot a ts weld be woth tf move wn 0 amar o cot you ow iid 1220 vacate wa vou Know, wld ity at pg iit. pes re SremmoRp a bere O8 pes a WAL afb vpn. ts ve ria sl, Th POE Soa 23 deposi ra nam sla cn Aba Tne 33 tm or ht Torn 28 ko dnt kro. Mopar mee 28 RE wre 5 tater, Swart tha lhe args Se re Cre 25 ebook. Ando ebook mt Ale, Caan otposmon som: [se woes nee EE mE Fw Te — ol fp it [ot rt. | oi DE RE rs: Lt cm ra = Sa ere 13 mo, hun the — the Using that wae circhid ur the Alan eau 13 loge. tore 15 Indicating, you knew, somcbody i bemped «you know, + =us 15 10, you kmow, oct Inte this, hat, you know, 1 was. a I mas rh Er EE smarts | 5238 were nore FE wer A ER SS a rs ay BE Esc EECA mt, [apa — i new 2 und wir, you wee I Haat aiticta Is, you wa 2 interesting ls. Darshovile has had access to these. 1 [a tS RRR kobe ol SI i wan | a | rer Hr I i I a we spain 6 CE rors 15 Guteida my Inimedinte [avy with wives 16h drafls, ram 18 rand Might og thal wees Producsd by Sr. DarshowitE to. il ra i ied Tifosi TON Ft TT evaveetes ns bbe nin I rs Ln EE Et i 5 rt em——— ina wr omm—" je 2 There was ala anather similar quote in thi cun23 So hat I tu 4 mpicion thal N.S SO. ...... w = wom 1 for tht produion ha bay Crk xbnd np {vn 1 Rp sees 2 nick out of it; ih OERAF word, 20 hat bl aduca the freee 2 make near Fiake clearing ie ads 3lel Le 3 Ortoser 2005 verstn ux 3 rtorrstnite mes vers nie ng eu The omar tng E— Kbpn to soer Tvs 4 Choe 1, el an, a cs eter rcs stars gong thou sams oe los, deve oper, who | 72a § seein. Som eon hs sft vers 8 a ane o thnk shou tres pcs het — (hat ee om van 7 Evie reouaiyoeiond on tay i = you knew, be. {ce T ges shone st te he ss at 8 dese ones = t wi he sara emo. Fon 8 Foti hamden 1» Deacive ty rn © There wr about the were bout thee plata there, | ves § mes MCATANE ATAU. 1030S a 10 ‘ne othe od som ight lpm and hut | van 10 comcast van vedsed | oe 11 th em it Bowe Rogers, FT recalinahi son, [vo 18 9200g0 vt arts th eis, i oc 12 coms, Aud sn ota on in th Ngoton che sex | ver 12 eo nn et riders ner, | ren 13 shu gation sgn Epa, Pint gs were JR | vn 14 obranca from Deve Koges, wad ws posal nto | wen 18 tne in nes ce sre mesons | i 15 compare Emre dost masta Fuanto mas | wera 15 1 i cc 16. sur Lat you no, te anton as Howmoch cont | vere 16 he we seco nw Tbs | wn TT remeber and Fo fgg make cor Tet GEL | um 17 ave gr. rd iu one THEIR oer 18 In. nar: 18. shoved += Ts fF, #26 Balk AI bout 1 ca 19 Ache igh fogs wre rodcmd from [win 18 ho pram a an ren 20 Gave Roem. Arvo Devs Roger picid oma ght | uc 20 hr etesson ts ts see aes ee 21 ge rd som of On tighte at ha oodecealogs tor | num 21 tome sed rcs Barbados eri 22 corsa oc the ak 1h i. OckEht provided |v Z2 To AABN ABtowy 1260 C1223 tothe Pam Busca Pokn Deparment, snd thu ware | macs 23s os Sor. ie Foss ice el. ree 28. inconstences, And zo tat, xan, browind ny nde ctmewmoeemenommeeriam | wees 25 suspicion that mayb Mr. Dardhowits whan he had ~ ns 25 reauler ducusaen hn. thet office. 1 Lt 04VUSI 100 U IONS fr — i mote, _ mone = El worn 1 MAL SCATT: Cjuikgat 2 ier s lawyer wa 1 And Bien 1: bad gone 0 vv her some 4nd of H ae 2 tne, tee shine » ee, ow 2 2. tr po em : en 3 Ents on, Gara ie ow 3 rte stn ko, ais bs, A nt Plpshph mon & sev bw ences | ve 8 8 SOLA Gynt streak ln [wns 6 yb, geen, 8 ity as ste rw 8 asec wn § to Tomine batoue ae, weer og i aH; a, yo i, hs ome 7 mantiom. i TB sus ton en seer pi P——" 9 Pp — wa 8 gio des og onsen moana | pn WSC veoh, ais doth, “ave [on A Sup aves 11 abt. a 11 Rab 220 = meen, sou kro, £ nek ne. i os 82 WSCA to Vay tokc aoe wan 12 pak me hun, sesh { — i wre: 1. 7, Tran, 8 wT com, Toon tate, SE { —t queen JOR FE aS A —s Wr season: vem Balers ne 16 ne ne mga or sai. svomely er 16 [rprsreen SO SR a | po WL SCAROLY Shey Vi re man |wu 17 aber med, win eset 2 er i Es and fink, wean 18 Epnien. Oe 0 thew Fd one Pomale, wiih, H 9 J ep — wo 1S ail he car ke rg oh, | oe 21 Ap ttre, i pig TESS Ou, Sewn 2 rr —— { ne FEL SROT. carta a rs bn Crd aah, dees dato arte | vm vor Boa OI Bo, ——ts semis the, veers ern ! EGURE LEPC so: UCAS ConuRCorasmoN soucN 3 wan LE RSE Sire oad as = ono 1 Attar tig sl Thad, anc 2 5l cak foes 1. going to ary conttantil communications or ou 2 est a Prive CIO hare GA uss 2 TW 100A 30 wy, kn tt Da a3 sanded vermin, bron December 206, 1 11s 3 ores nad nrc tn repront Vii ROSS mua 4 was aware that one of the pricminent mye: in san 4 wich gave me additional confidence In the fact et 5. tho United Sats, David Boi, od saree to {ave 5 UNLT mas is rpreseing young woman im we © Treat Vina Rober, Ange twas | Low 8 her sir to ring sex aekers to ote, Sonn 7 io F aking hat — as, 4 Kn, iss | an 1 30d hose wha had sexual abusod er o tice. wo 10 tin the door ee 8 a 50 thus on tings, Bak sm to id re 8 MI SIMPSON: Colt Liners? [mean || vaa 5 immediacy oi-- 6 m fst ake second and ot 10. thio ars iy towords 3 svar ere. Taro son there ws cher things regains men 11 MG. KeCAMISN. Yosh. Nor nos oy 1 do 61 | wee 11 Darshomts tat «tht come lnmistatls = ores 12 MR. STMPEON: We can't have Lastmony sn 12 immediately to mind, we 13 about -- ror 13 Oh. one of the things was in 12 Jane oe 102 a NS MeCAMLEY: Yeoh. “oie 1a eimpint whih sheged scadamicans that nad vais MR SIMISON- ~ Uri one theo | 15 oathad shused- soxuol abused ane Doc, 718 respected poopie nh county, Gf Be In| aio 16 hare «har wre s0 tht mis quis eo 17 the country, and hen yo wont answer De. | 7 obvious, of ha mcr Uh mcdicion tht Ba Si questons vee 18. Sonat ho nine? rte THEWITSS: Oy. Tis Liane, scab. Let me the TEE MR SINPRON: you id nt lu snar. | io 20 record shoud be dear, cont rod UTE MS WCAWIEY: Oh vie, desing Gavid [owes 21 Imaciatly whether 4 ms ial o pre. ez acts gener — Seat T2 TE may Sse hn ral, ul % gr, men 23 MRL SIMPSON {agree with oc dscristion, | vem 33 don] ant 1 Soggest tt hee vere ctr MS. CAWLEY: - dost consis a [vi 28 cadena, stot est one scadmicon hd ons eer i025 senusly sbuscd Jone Doe 3, accor a 125 ESQUIRE DEPOSITION SOLUTIONS SQUARE DEPOSITION SOLUTIONS 195) 3314400 JE Vy ov Tes 100 ow 1 NR SINPSON: esa detmuished myer, [mess 1 complaint that Fad toes ted by ob seit Ti 3 NR CHOU And Tort Cin re [ne 2 Tare wer oa tongs that wee of ntrset 753 ein yor ling hat 5 nator or i or 4 pk ret 25 4 Sat tet get mfr fo bso | cs ssn: ce 1 mom 5 ss in th it, nad raced or dcinad eo 6 NSMCCAWLSN Butlsperudatoyou= |own 8 tole an ance to that complain. ea 7 MR, SIMPSON: Bo waver eee 7 Mather thm damp the llegtins, ho od, im 8 MS MCAS. ~ ation me kno that. |oim § sltmately, sms understonin — 1 nt she Was THEWITHESS. Ainge {wilbe— Iw [ws 8 sie infouration snd Fm nol tying fo wae ev 10. not waive anything, ondif {Stato do hat, 1 [ava 10 omy formato, ty destanding i that 11 voi crn rest 1 Soper 10-10 wa 11 <a than ase the compl, he etic the oot 12. Tlrat U Qogs Ut 1 St nine — ach | oun 12. <8 thE e poYET of some kid of ee 13 a oe ty eh, alas the public reo, ma 13 compensnton thot Jan Po 107 fod deiable ee 14 a2 aan aL, you iow, prEbatly th most | uns 8 or dmptany “orca Tes 15 Sanfican nied Sates SURGE Cou csc. [wn 18 Tolbert that Foun narestng ls LCt 16 aroun he ot 20 yom st Bh vor Gore, | ne 18 Shat snare pare, bakers oes 17 wtih ms coc tt sacar Genin ha |» 7 iss Exch, hd brn to some of oe dass oe 8. Wat ig ob Prodan cf tha moss pment | wn 9. of for compl, 1 bilo ua, lst an ea 18. cing in the word. Ls Bie Rdnguer. hd {bebe stent one TI 20 There ware ors Starnes wh arg ha as |v 30 thos, Ad parhaps bo of hose. And 3 had Tere in ron of the Unt Sec Supra Coty and [ow 2 35a Qusstons abut Alen Parson bc "ree 32 orang for the Decca Pree iow 22. Acpaskions, but ho not we audios shoud aon 28 He had put is rd onthe hc in va 34 So tat td me 1 concloce tht Sot L102 aroun the bush seis Gore css, 3nd hod |v 25 Jetberg and i ito fv fem hd ESGURE DZFOSITION SOLUTIONS ESQUIRE DEPOSITION SOLUTIONS. (5541 331.4400 esgmiaws | we 1 a raat sd RSA er von 18 MK. SCAROLA: Sure. Tee a brask, oer 18 my underssanding wes that Tee wi nu = Wu | rte THE VIDEOGRAPHER: Wo at 90 1 of vid | sua 18 ki, 1 Cucumbers stolid sm 0. | nna: 20 rend, 3:27 gan. ae 20 Ard Su ise + Thad MRL Informerton. 1 SQUIRE BERS TION SOLUTIONS. ESQUIRE DEPOSITION SOLLTIONS | ips _ pe BETS [3 Ty fo a em Fy [2 wna awe 22 was: ultpie witosses wave plzone you in the. {as 22 yo 56 0a 15 another subi, Vrofeaor Cell Caen 23 presence of lottery + stein and unereqe alll; 1 oem 23 15 eran to refresh hus recollection ws give. n ESQUIRE DEMOS! TIGN SOLUTIONS i ESQUIRE DRPOSITIGN SOLUTIONS : prio re H Gl or 3 1 tow 1 FET —— i wn 2 Te Sworn Tn 1 meant ks os 2 entrant i Tamm 3 tens, ot asi oc are om 2 NTE: As, SE ; fm 8 A ea we 8 ome NDI ve 7 BHR, SPO iv 7 ori sn H fone 8 Qe Sosa, yn ~ yew Tertierad at you in 8 OQ Could 1 just sa Tor Gow smn? wenn 8 hed samctiro bast yu se srevsrsd = orin 9 A. Sua Adilutoly. } wn hm er 10 6 oo. van. tne carn [LEE — oe 1 sams ozo to, one 12 A might evs 12 A vein, i JESS — a Lt wae 1d A Risk foane18 atnce es cou mes se semen vo covld H lanes Gwar cad ean Vom 15 rr mot ma eu epee 2 oi H [18 moti. cd rn vic ot sn lr Tain 16 sons Kemer der ant, wm tte | [IS [I t—— i ts A vem. [ST Ev NE — fae t8 Gemma eran 15 as or thre 2 comma = whe. what hme 2 WSUS oF ire 20 rte to. common scheme 7 hn Ehint ais wt a. san Teron 22 THE WITNESS: Rant, Naw, there — ters are law 22 A. oe a crimina) comspacy for Intemational fun 23 tao pets 0 bi = ima0 23 trafficking that involved not fust a single irl, bit pees ISAC Co ne vik vraes 28. oni gr, 5 he seme was — ee vith rent wr dd ia toto mip ge, { SU 5 80, TRS. i Sanur bsp ON SOREN sw tans a pn oo - A rs re foie 2 mandates mor org ~ ews + fram 2 agnor et PRE EO for 3 Tn ad ueana eto, tha te I ov 8 Sonn Lum vara oft Yee § stn yovon eng oes ee rte, St Gn 6 avon ses even Brot row ras tant $e bez — fan 7 tetasiemtona pateuns brain | rn BA thn nde RMA ¥Su aun © ss tbed sRr so an? i furin 3 vave questions shout unat happened ser Dscember 0th [an 3 A You. i wae 10 QE yours = you se prewaned 5 odes the fren 10 ©. kay. Se ther. pw, taka 3 feck t wt and i Loca smarsrens Se vade duos fesre wt ren 31. tot 7. hres mtn se ha ee on [JS Ear era 12 eben ac maria. aie oh 1 2 i ta ep ik HE" rn 15 Kallen. 3 tk eter oro hs heen, pl ewan vu ve ig ae eu 18 sara Klemen we frst mar Lol ire oa 1r atin trina, ov ft va | om 18 THE VTARSS: Thal wed be great. cues 18 Ghee. Adriann Mucinha as tha toll mame of thase— © JOA £19. hat the scons chek of the — oth ofthe ] 20 Sans wi fm 0h ae 0 caminat conan. ! Cat moos 0 ised Bm, Cy Ohi retesbes my reli od | RnB eres mers ewes ue Wes i A A ER | wraT beotston ve, Wa vast tis, hos sme ERNE a ——— as ree, +n 28. com pute who were Iveves, toe ok re Fits BO rT wnt bates herent weer EAE PEROSTION SLITS CGE PGATON SOLITON onan ewan _ Fw FER TERT wisi TR fan 1 pense who wouls have ceva irormatonin tec [cc 1 steps tsar of salt escstionta ca es 2 coon, bt when askin depen she ca 2 Veh wo wil gt you Ete; wa car mc oes. rm 3 He Derbonrt, hi tak the 203 he lg 1 mn = hn 3 rs rd JT — oon & J —— cine 5 peop, a as Hag ar questions, EARS {iru ates ht Fi, D henner Epi’ ses, [sue © ropord to ir. Dersnowits, be took his — be Invoked vs | cen © never uimately produced Epstein for s mesding will sen 7 Foon Amcrcinens roe gait compet [FORME A — ta 8 aetnaimestionpresensbly ca reebeg what he {ove [Spee ———— Cie 3 Vm lanl 1, DOOM Wolh, you cn CoS | ews © Gr Tmasn, 1650 ou Kw ne knw whet JR —————— ot 10 th commanicalion a fort nd Mame [Ep rp——— $a $1 ty 2 gt rman wl bi 0.00 ha, Tht oa 12 here vos common chee a ha, md Un 121 od erst tse. Tae Tt shitting erent bet payeviet om | |v 18 Jot — Cree 10 teas nbc pont. Tmastcneatist toate | cua 14 1 thot ti ws sti i, Orit, ad [RE —— on 15 in my vie, potent mena ve uk 1 ec 16 i esha by vey of 200 drusion rests | 5 16. do hin we nud 10 gt tm hs JT ep — ren 17 gaan Cron 18 sumtin ro ont thot, and 2053 dct | 1 18 What sow vs ei sc ai oy Coin 15 Isat propo or. Derchowa watnagnat | at 19. aso he reunion al cli RE Jt 20. se ie ar nf, whet Occhi of 2013, -— ean, end ni ws = es Kom sory hi Ti 21 a. pai ns bc ling arses i ck 22 sipped my id st thet bt he — hn | 14 2 qn 3b Ws scutes i. | Cn ZS Dah nt responaeg to hese seri os | eves 23 prot NT | “ave 20 mo, mye th ra cla et cere ta ro wot 24 Loins rc be 2005, 2008, you ba roma | Lr 25 camping Be ht 1 dat — supp ne ou a2 drat sy , DeenTE nk rat me sp | Fun oeommoN snow Sots be SOLITONS N ase rs seman i mr 1 boom thera easily ern 1 mie Ard then ist over nagpene and give he hig uke bt in eso cd cu rt we 2 myer pte hn — hot deel we ——— Jest 3 shake back, To soy. Let moves paver, | Srct 4 thre ens peter on i's cies ni [wvie 4 ess go nc to ecemees 300 2038. 59 TS deity ot amin om thon JRO — bin a st must go acct ne caret we 6 oftime during which, esti bd card omen | Lion Tinta a. Accor oth Cert Police i i 7 any auntons sou i acts of gs soa vt. | eB th ptm enc ofthe el Brach plc Deptt, | <1o1 8 bh, Dac cd, on, Es uta scents | Fim Se, Dehn ve tht he wl mabe avalabh | o3 5 3h 30 i oH st hPa ec Oger | Zi 10 Mi, Eoin fo asians south tse you 27210. =o vou kw, 0 me and — and fn i BE po “ie the thi th Eh Vn snave | “in 12, Dera nd id the Pam Desc oe Cra 12 hue, 0 a ht ar Omoziag | Tora 13 upset, yesh we i os el gs wt 90 | +s 13. bw soca in concksan Gc foe to pon | Sn 14 to eschew, tn Sh ie, JRO VR WP] Tin 15 chad eter tine. And 30 ti wre ate =| vr 15. Gone slr sor o tio. | us 16 secon tne ct pbc, here i bn pat Snare othe wo «china | Sn 11 mitt You non rea tr i He, Epin | w 17 tcl Gh nel. rk Es Wn Sic 18 amd. Deron hd eget sa, Oh w|i 18 of th ikname unaestans se acs. re 15 hdl 1,306 i Ea Pogpanad rats Sa len Haswell - remember she nshe | em Wow, tviusy tere cocks ove beens oes 20. ithe one, yuk, hh he recor | re 21 ston hare wher, wouter en merpeoc dime | es 21 fn RG tt 0 i, i SES i ur 22 upto, rin ad hen sl ake scale | eres 2. bac 1308 Hat hank he cra st rt root | i 20 or someting lhe tht, WELT ins was |e 23 Vrs Rast nto 1 ne se msi, i | Ua 25 nai soemes 1 i tae 2 cers ccs | xe 25 no athe gh, boo my ft ts with ! “SOU uCroSmIN SUITES SQUIRE SERN S01 TONS i postr oe sain | EET eh TH EE orem Ww 0 Gr 1 ely Epstein hr hoc rn ging [70 1 ASE in was 0k Yo kno, cack the tn 2 ome hry to GA, Mn th in | 171 2 dSBEEION 30, I 3 a mtn came ht Lian 3 ovat 27s 3 maw won cu i, vu know, he ion of Jom 8 J wi 8 youbon Eom spe — ne topere--yoskoow, [as § doposin. se © ene inom af ene contin, env wens be you [20 © ROR —— 10 7 how close second rer , You ke, Oo oma 7 rc, wes tre were tees attompts fo cba wr 8 parton, ire 8 woman tom bi rns tbat pune at | —e So obvious, somone wh woe ve, You [55 9 wuld hove bee one tig Rl hn had seam wei AD. ke very scat erration soa, yoshi, the | cm 10. of pol os wars sete ti sox mOKnG Cok 11 sex trios, ha ee he rope that he |r 11 og vc queso, You know, aunslavicson of | C214 12 th ik a nig rc 15, aha i fabs [uo 12 cout neers am enon od ngs 1 hoki BE Cy Sori 41 beg en aha he, becuse Rhus ber corn 4 neon hk wer bing ska apart ba md, | BE i ine 35 the diced cere oto, ot he ki se 12a. 16 Ans trcn santo het hod nso | J, Jone 17 i= wot yo in nt ou rm ters in et 4 a commen ts ch cases Hic 18. sexraickinn vou om ring ing dn? I suns Lo 49 tratsome orth gs ad ists in, Fon, coc 19. Mino vic 6 20 ber depuiion wes 54 noc, by my foram [I ——— 720 21 1 nei, wd then thre ok som Misia Guess 1 21 Sala a ncn ember om nes potagach nt Tr 22 conn sare you ow, RS 1S evn 22. was nay sete onthe erm sd at Ton 23 gues — na tt i tn werk out sad then she Lun 23 hctgroph dep me pee so 24 sesso destin and fino avec, you how, | von 24 fr — oR Hi SR dn bom “haus ops saTIONS | Canc oEros mon sons osm ! Opis 1 0 -— An st tort, you ow, Eek scaupte | a 1 ke Vii Roberts ses an erg i Shaws ct “ia 2 on tay etre thet depot, chs cance And wall, | ne 2 deste rm) se. Ar inca Anke baie sen Tos 3 she cance, Hr ir tory Alton |v 3 around hc unc memory seven, sad ght st + rn 4 th donon i rr ht ia ors | ce srutnp ine chords wos ene and “v5 oui the Unites Sots of America ana adn pins to | wi 5 spp ted hk ot al aan, esas “ol 6 return sackto me eas ster, re 8 in Londo, dose Ln Bria Pace wher ~ VIE ws 7 “dr tte i option as [eT Poe Andon i EATON JUoru—— re 3 Na hn Uo Stas fo aad pica of | ves © uRaerop or wih ison eel the — Lb hand £210 tin. stn vas seta icr ata wesngar prominent | xe 10 il i née tho igh pron = psy avn 11 person mew var. er 11 ho ay tr an hrs a we 12 0 hat me Hews ling iho rn 12 atm ot wt sein — tt vere ers and somebody hd Wt 13 pater fy hen, Ein i ing you Ge 13 tonto: mere. ive 18 ko tb Br Pll Smpustent bina tty | se 14 the err stan T0015 Carhousts at Epi ances your auton, and | wi 5 thght prhpe i, Enel 1 3ken he GoD. Leis 16 then vou nsw, nc toning fermion, Maral | vn 65a aE mocks Nav Ao Vegan Rovers’ seus nase ws AT vat the deonion. rein 17 was vt conta Florida oe contre othe re 18 ee Lo Ree st ne prion ho seam | ve 18. Nes York mansion; wou ve rid eve Tr 13 Lae very much moh - tam gs, | 60 19. presi cite tk Laon rane a. ou Fn, L120 ad itua tn same satin. Adaposbon ws ettn | rn 20 th RAS, oct poser pros I ts goverment «21 rv comers, you kno whois old Ahh {> 21 Suchet th ns in apenas ne [ie 22 gets meat, hot rm the nme, rc [Jp ——— laze 23 whats geingon? Laue 23 4 30 that crane re corms about, hot. ees [LOST fi —————— Tien 25 nam hatiapts out ot koe. dont reel ently {nn 25. somerset wars hee Sic a ncn, ye CORRE OCTOTTON STON: i suit DEPCSTON SOLITONS ssn snes ghia wersicn in or se 21d THT TEE r — EA agen Tare 1 know, tos nforcment geacisn in thse countion, you | oun 1 nos yng 550 re ann. 2 Kiow, in England, or law snorcamant agencies in this Tum 2 ihng anc iis E dT sitnton. nic 3 com, rath (gh Power tht, You knoe, 3A Ao rr 8 menagy ttt eve, Ein Mn 2h ei 8 8 fotusmumie eta Sonn 8 eh Torones td hove ou ww sraseay seces | on © Serene ors os (re © tolevers of power that ots ole ght mute [wir © A. KIghL. Ti ins sexual shu wn 7 ooh, ews 7 @ Tircaamainn wad Anse otis the tbkiova tha rtbe fare 8 A = crmatpte si (ne 3 action hat hod esp to me an December 30th [re 9 Q. uncentara li. iu 1 HcuTAC en 10 invoiog nt st Vga overt, but etree |r 10. ahs tat ve 2a re pet pa ———— FE EAs —— fren 12 Q Oh dndtit peta cany agin, in 12 That san 0 emationt for me. | we TE abs oe RAH STR cu 8G tnt ten a be LT 0k i UAE pe i {iia 15. bout san. ves, rd tc ne ata shat. ant A. Toles tt partic true. fronn 18. ter or: ht 2 or 1a mE nse toss be, love 17 a cont. ud? rn HOH iu EN — ote Ih vuEOGnER: We weg oF deve | [ern 19 ever lor ts moan, : [a 20 A thecsishe Mo, sd Y pave pou nhanisnp, oer 20 pLannigS— : res 1 thet ws ing o be Tong austen. fone 21 mE CLE: we seta on vides © [eon 22 @ Vou wat Mr. Destoally nok He an aster. xe 22 roca, 4:04 sm. fon 8 cna fone cpm, Kees &. Soe re n+ [oon 24 HR. SCROLA: Srasns. Uke 3 ola? mu 24 M. Deeso are Carelyn Coben et the. i a 28 fh SOS on, Pe OM ISR oenZS fcercnges | i f———— ; SS0URE SCrOSTION SOLUTIONS | sc Js. ssa TEI wm] a 1 a was: we srg i jx SEARO: Toe nb G3 sammy, ate res [EE wre eT Quen wie ro ea Vos 4 va sin: cures, 8 coping Batak vara mDome on 3 a. ScArcLs: Trea se, MO MR een © oro soso Tame Traore bene Ke ym FP Sg ——— oun 8 Letra ub, and wet ne fon 8 seusiegmname pi Jeean 8 NE HLS OF, Fr, Upst Hn PS ——— fn 10 rena au sent ae em, | wontt eta kts me srr vss, mt = un 1 ron. To se, sc Gt nr aha oly meu? proio— Tent Oi Ca, jms fe——— Town 12 my rn sweoson: ean #4 NR SCRROLA: Ws of righ. forts con kar atematng me {ann 16 HR. Sina. Tones ci 47 : fore 18 inten sss. aan 18 ie wom: Sue. | pu A— [ontt. wove. spam | pen A fom 180. sok you same th me et xara i nat A Teck et-tisnstsomengatt nr 19 faamofe an egy neo aire ean 20 tnarunny. fans 20 3 srins scvsatiser $ UT frnn2t A sare i kn 2 opr ow, Ooi, on Poa SIs [HS Se ———— rin 23a, th i vse poor, Toure: Cons 23 vet ws md sb tre i oni 28 ura tary we bog tosrosr wr ten, [cows 24 sha, of wu hime I ana 25 mn: recs re 25 A swe i EsauRE cerosTON SOLER Cos coro SLL IONS i sno 1 nt sen H ET on 47 EE Ere | i 1 4 vgn ta x sears . 6 BRMELY J. ANGER wd A EL ESL, S08 connutun aveind poe Fn : EI | 2 ww a Aerie paaiar “ SUVARI rans we WELD IRR hl os. cent od a: sees x ve rma 2 " mn eae bos : BS Wn eM HE = Tiras Toaan'li, BR i ES H £ i [Er — H EL p—— TT LS ea me fo TY PO ¥ Wnnioe wee STIR SLANE ve; S36hine 4 TomTwuco pac CAammA TIN ee H A i g ; i DF SERIE Vu CW Beka, + Hruey kREERI TION nes: Tow EAR A evar wu Ea Ta ance esate PM ansenreime peranar Wma eater aamaeres ate seas " Prin EAL ey en rom " = SL EA w eseunie gn SEUmERLY 0 BHR pe 2 Pom lr Sm ce ara HE ; EAR Sse eps EE Ee Cs es Fr i 1 DEPOSITION OF 221 G. CASSFLI femin 1 Never thought to record it, Sut that's fine. ev 2 MK, SINPSON: vie dan we don need fa 2 Saray, Quon 17, 2075 ur 2 Ta HRI SCAROLA: Wo dont neo discs hat Lam 8 record. Todays Saturn, the 17m asyar |7ot § PR-SIMPSON: hal youre sig dors — IL a a am Wee [Fm 7 HL SOMO re ya gong proce he bond Bi cma 8 reconting thous th necesito ne rocuest lB pr RIE voll psn Sk {iver 8 the videotsped daposcan of Pou , Case az 10 fie ne requis bo producer hoc Rpt dl pd coat 1. SIPSON: As ir Scot indicated | 22111 Cail vera lon, Dershon. 12. yostorday, we wi respons a you to he 12 The cout reporer Tomy Tomasalh and [en covery raved, We wil comer of a break and TI 13. Lh iotraphet s Don Savoy, Lakh 0m EXIGHE {es 4. IAAP 0 GF quello. 1 G01 Sa a Take Tinta Depastion Sontions, ar 15. hime onthe record desatea . Anerti Scot | Ts ou ase ance “oii 16 and Ihave conferred sta resk, us wil rend | sam 46 appearances far bi rence. wan 17 further to vour question. i woe AT MR. SCARGLA: Jack Searcls on behaol the |, 43 MR. SCAROIS: All ight. So that the record. Lads amis amen 19. i clear, it 1s ur posta HE the recording ON chard Span of Wied RAIN. | esc 20 sel, any evidence of any communication between SUL20 an soho or the Detendart and Countarciin fanias ne 21 bi, Garson and Rebates andr Mekal, sry Etta | mor 28 1s ih respect 1 3m such communion on T2. langue, Hosts Kehardeth, 70 THES GUI. |e 0 or evacentts watt oo os afcnats pvioss an Che Tin 28 100.38 to averting thts bang wind S038 MR, SCAMOLA defor ne beuis the deposinan, | ian 25 responsive t th cafe request to roduc, and ESQUIRE REPOSITION SOLUTIONS ESQUIRE EROSION SOLUTIONS (55 3074200 se mre I 3 oun 1 we cre mes or Wh ist Un yecterday a 4 Ao th obigaton 3 0 has prov 145 Vee 2 morning arth evktence of a vacring of » eee 2 rviously ans 1 Yo pavide I Yun oa. ome 3 Tekiohane commuricaion between Aan Darshaniz [an 3 We understand that vote conaderng tha fons 8 ado vioman anied oly a Rebeca. un 4 aot vou vt respon, 30 cn races th Tom 8 Seat inforaln vos omeyed ta us om 3 depaition. me 8 cubsequent 0 Proviso DershOTLES wort: ren 8 PR SapsOn: os. Anan asagree avout | ve 7 testimony tat no recordin exe, thon ths [ew 7 tot and 35 vou kna, we have.» malo to compel | fans 8 we xno thal the recording existed and that it wre 8 regarding your inadequate priviseoe loa. ¥ ve 3 mat obvious ate accorting ta ths larm 8 HE. WCAWLEY, ust efoe ne besin fm | Laan 10 representations given to us, prior to the inex 1D sory, 1 GIL AMouUNce my appearance for the. i [372 1 comlagon or he responses tow earer oa 11 recor. Sia cca nom Ble, Snir | [eon 12 discovery requests, § would dike to know whether jax 12 Flexner, and I have 5 standing objection that I'd C12 His tre Defendants poston tht 1s {ies 13 ustis a repest on ne record. H on 18 csr for nto progount a new dhsencry on 98 MR, SCOTT. Fo bese hat yu got tof 18 AS GR ormaln egy Shoudd ee 15. you cht? | iirc 18 Fave been discosed In ecparse ta the earlier urax 16 V5. MECNALEY. With respacttn excuse me. | eT daconTy recuse. Don 17 Vi respect tomy cle, vrgina Kobars, | ath 1a thot th poston thik vou'e akin? an 10. she is sssrting ur stiomeviclent prvdonc IIS VR SHRED: Fas, tr. Scarln, Tbe {om 19 wi forneys and mk sod rou wu 20 youu have mischaracherized Professor Desshowit2's wea 20 NY testimony here: today, and hat 1 object to we 21 Sesmony. You FG aek the question sheer [men 21 any Taster shoe? har woud be used 2 2 rie 22 he made s resorting. Nesordaymoming, he | ae 22. subject of weer fo hs attomey/ciens wre T8. precited hat oman in reapers 404 and riicge, “iz aieren question, PP ev2s URL SCARDLA: Hi mat tctimony vac: 1 15 please? ‘ZS0UIRE DEPOSITION SOLUTIONS ESQUIRE DEPOSITION SOLUTIONS 954) 331-4400 (954) 331-4400 wo i 1 Twa an tO snd vey hc kms md Poe sa cass sion 2 wae eka or FT seni i by mtn wi mie arias ve 3 A soptozon 4 som a 5 ems: 1c. CoS ht et neh sb bn, 0 5 connuco ae covers EN | 7 we sms ce 7 A veh rememsor wa wera working vey bord | wn 8G Coma cris 8 on-—on ts 201 think me hd 3 recal correct, ro? A contmamim. Freie 5 had fh rt md ord righ Erg th, © arf Qe camel fare AD Q. snake: mectoungeion uth : on 14 J mn, S000 baton arma uma 1 hz Bors ars Bear 20 018 Ry Fe — jo iz Ae, nts A ve Fon 13 on tether vo td andro any tried osm wn er re 18h vey ns Soman 6, 391 ca 16 ser J SC ————— fovicts A omen sn 18 stephens ale fen 7 8 Wrst JO Np — lon d8 A apeniay Hay 018. was 18 A Letunnt. Moughly Sapam 2048. Give or wats 0 wea ra 18 kn 3 mani. roan, you kn smite fer May 3d fo 20 A ven [RE ——— BR er — wa 2 Qe. toe rs ae toner ls even lor 2 A td puasing for second hacia er 22. ts i 4 Wo Bes, vat sree 5 {in 20 cont 1 tetra en23 ner 2 @ temen a2 A mo seuss tones or mt H fons A desry ron ring to getints php —— LORS SEPOETON STIG ESAUIRE DRRCSITION SOIUMONS. : ean ns ven [OTIS pn — fms 1 0 ta taco ates astm ue H FOIE TR Fon 2 sete yorum os us rte icoere cs i vex 3 pur. ra kr su wha ma pram. gor lowe 3 A I-1tiktoewmsthaensorti | wren 8 Wenham we, to nd of aves. foucs 4 col. ink Shera may have boen ue, but # i we 5A Sa Vash, Thala partan who wat prazent {vee 5 vi ol 1200 bun nr an eu rt 1 can ml. save © war racy 3. Cows, my Co PISO in 3E0. {ee BQ fn How 60g 55 12a pre JO TT TR ——— in 7 lb wrasse bin BA Les then ve rumen, ws A ve mow 8G Tinga ek ra cst, bs C10 Gann mney me 0 Le ae Fie Luce fl A Youkmow, ere were «this waza the RTE ws 12. Farmer, fis cfc here, sna so persons who were [xin 12 A. okor, wea 13. masaines with the lav rm were ast bot these [xin 13 Qu su arses hic we Fraze 0 cree 14 meni pepe ven 14 beri ara 15 QL aan. Oa ya rea sg hi thr OS ama AB. sess sted wh 1 om oh vers ses? PP — a 7 A. presenc ta, you kno, coming in nd wn 17 [A —————— coe 18. mining, 8 bekiew Urs sitar arin, was there, [xan A8 dsc sions Dera ern 15 20 hap axa 1h Gy te wk nt HS. HHE: To gt at 0 cu 20 boa trva nat. en ders owt mp ere gos casey ami 2B. a hears ha whe src rhe con 21 samen hr yo mere ress er 30 cr 22 sve rng cr saben nn of the mesa? EE —— ER pr WL SION 82-1 me ve a1 Ld an BE a etc so el so cs cn 25 A Apmomotaly al or. 28 curr rent on ar sone. 6 va SSOURE PEAR OL IOHG SS0URE JERUSITION SOLU KS tm 4090 wate Sar FER TEA AEST iw Io ERP SRR Oo FEO ————— awn 3 onl arti on bf 2 germ mre tlie, oy in Ve SCHRDLA Ih. Satin mine | ams 3 add bie sho. jor § emction vig Tobe oom 55 [aon 4 [SE —— fae 8 bie to rsvect ci dition coming fom [ # acrcuncn, 5 900 the ecartvss ced © Fen 7 Yndota Robes crest or 7 yon per) sao B MAL SIESORL Yes, i -- IV: shal, ens 8 ME, RCAWLLY: Ard | vaukd 3k 1a Sarify H es 8 Mr. Sears, makag my cond Et the witress ors 9 whit cae as well EL you're ehating bu. H pr 1 SCRA, | drone ho. [I a Smeson: Sra. Lem ak hs at YR. MESON: Rh. ech Toon asc ant and boa err eed pli VR SCHR Ted, bay 81 {ones 2 hak yer, the we rf on wre 18 asaume the seme way J have suthorized you to. Lorn 13 foul Ural Mr. Boies mas represen Vizg tis arora ett Cont wih ol ey a nets vas genre aim, Sarre not on 15 ications, Pfs Col il i oll Wr 15 boing wat ener cad suede, ot 18 rabucons concn te ssn of S16 ama atk mgs. 13 ony. a V7 mc stage pened o Ga tnd | ive 17 A. SCROLL Wo emt i yr ent yo cooley cn tev orvioma res. [mn 18 Jl — forte on. SLs ra oa 0 acm. sho ow svar sat niu lon 20 stim spoon: NE J deed 5,0 Cool Landmine | oo 21 80. SVB i TNs aiuto rl tre dhcusdoniog [ew 22 Bu nn so, corns: Howe you er 23 atm mam ar. ch 41 phon cl on 33 spon tore canoe: 3 € 2014, ot yeu phen | jee ve 28 reg Foto om i i aR DEFOSTION SOLUTIONS SS0URE CEPosTION soLTONT CI w wc ws peck: ves os 4 [rp Tax 3 BrvR. msn fon 3 tot gue a 4 Q. okay. ones 4 THE WITNESS: Fy revatiaction is uo. we SA Xmen thoes du to my olen whieh Fo | me 5 HR. SCOT. Tir pete tu on cre wrcx 8 gang sorespoct. ar wr son or 7 Ag Soweto writ whee i ————— ne Ber the cg. 8 shen iit ns Aol eran 30, 204. bay wuker [vas § Ae 0 recotiection Lt 10 tothe wen ow ks, ATO SEE [wo 10 VIL SCARDLA Jd Sec snc 8 ot MCh: Otc iz Wi SEPT ren ser spor cn £3 511 SSN pris ean 18 nt hte dun td [per —— rom 18 mame. Gpstin, 570 pa HE TESS: Lot vg bu wra1S amma maar pogo, wr 16 LOI ———— | axe: 17 BY HR. SIMPSON: oma 17 lawyers, 1 Gan 8 QT skid ones disor iw [aves 46 Be Tr —— oun 48 substance at so. st, wos tang a dacussion™ nie 19. “NCLe Ery OpNOrS Ci Lat One ine [nas & H en 20 os eA: Imgarg mY | @ Mage. rer br. dent i 2 eve 21 rah. my ener ss bron pe) STE: lay. Yo erg re RO SE WA Ape lias SL PICAIET, Ve as YET aR [sa 26 YA, TSO t [aen28 ym momiendetmrg ronnie, |arw25 |G. bios, Kot ya so Bacar ol 014, i GORE SEPGSTION 50. LICKS. CoQUIRE LEPGA TION SOLUTIONS £50 14400 mss TST To AE Tide wl wm EL ———_—r—. ie 1 rea 37am. xow 2 A Hy recollection is no. os 2 MR. SCARGUA: fo i rat ut, whl we nay Tre 3 OL Anita kre JOMUI OM, Uva rd wn 3 oleh soneisie of il ls Soke in wren 4 spoken wel Mr. Roos DDI Vga AEDASS jr ths clszaseion, the answer Fo your pening wr 8 MS. MCAWLEY: Again, i'r anng 1 ahve. [on 8 MR. SOPSON: all rig. T= TT ask oe 7 Evi son J Con 8. pores Ssh? or 5, Soro: we. [ons wae sow. Tea ton. [ven ® SR, hr = ho sa. 0 0 Cm aueing 11h. (ik ges aoa 10 more Tir she in Vaart the mores shcmmerssorsunderie pu [Er — Ham 12 comaastoesl widest, mon ar isa | ue 12 STIR SIPSON: Ln dS conersnaon byte act oto wou t3 Ge ty meme: § seeveyou bo aby Vou 18. tart oh hs everson an shih ar vu 18. acne put 1 Sern Corin 30, 34 pu en 18 Prtaior brs, rca sa ns airs | tt Wi. SEAROLE Amit A TCon diy [17 RL SEARO: vk Fol, i [eB ou poston rec, | kta an | 18 a. Sse: i ds. say. fone 1s ony ta gereal nes matin cera [oan 10 TIC WETNESS Seo bce 30, 0 Foe 20 cuprent au pin sat os whine ie 20 huaors te can ect eB Bn, Go 2 Commits igs, Sa wms'e Alo eon 2 BY ME, SINS. one 22 SuIEr the QUESTER SLOUL PC Dene SLL low 22 Q. Arr December 49, 7114, dic you Agee ney al rman pile get ot mn Ae GIn ; pex8 substan of re sommeuriaions broad ast, anne 25 MR SCART You ananone yes am, | ESQURE DEFCTION SOLUIICNS y RGU Hs 0 201 TINS 21-4 } (5561300 add a = — OR: aden treme one 1 Th wT: Yor FOR A pO Se a 4 ru sine, Tu iain Wht, — A ve an § sive vacember Yih 01d subnet [wna § BL sav he subst fone TB shegmmey Wna et tn [vos © caren 1 ie or 7 5. BENE: Fora obi A th ar 8 THE WITNESS: usd cori win [se 8 You 3 urd commons mess ar 3 cous tat ausion 2h Mn 3 ant Ks ies miko 9 sae, ont 3s Crt compan a se om sot ne) ban J dig PO tt SEG: Ole. iz J os 12 Aa wom $3 pr us sn rh” Hi 4 THESIS: vit 0 es ot Tat mcs ver 15 foment bit answer Wot queen nest, | wee 18 Te, SIS. Alri rd hat = that al we. SMS: vt want ee C16 wll tet wile ted esol eg WRLC: Gl red A 17 Quesons shout Une stance o de csissons pat VR. SHPSOn, 11 Alora 35 25 PIR I Cat npn pm yume todo |e 19 [esp — — zm Ni SISO, Al, (ere ack jo wir: Gla il wont pong THE CISEOGUAPIEK: he ac of he vids | wos 22 5. SCAROUA Av may sh Botan. Ve2 mt yon ot rote eet. un, ot FE — VAT8 chat, tho a an so pu srs po HOCH: vier ck onthe dn | von 26 we rr ni gure arm. Fe SS0UIRE DEPOSITION SOUITNS ESGURE DEFUSTION SOLUTIONS sy 3a prepay EB I town 1 mmr cates wats ret consadered i he wr 4 MR SEAMD! 8: Wacause of sare ana 3 wan 2 poet on oe tebat epee |e 2 norton pond valor of oe wn 3 nt vowtr, Tn |v 3 eke vig le Blam jn § viedo oe eed Sea le fp wet [ase 4 ons 4 bate wiles te Lowe 5 made, vacant nsner sions. i 8 oreen cmounicons, ry tat joe 8 59 150 te you DIAL IRE’ 4 blanket wan € ora: Te SUDICL METS Of CO TANIA In. [rue 7 Aassrion. Ws nsec 1 hess the queston. xr: 7 the quesaans tat you asied will ea re thas we fk TE VIINESS: noms he tanith, [een 8 sr wena ides olf ep ia [rap ae 8 Se recon. J 10 [Lr ep— we $1 Q. wank did you discuss wits SI, iiies about the ome 11 an thes pretan. i 12. sein spree [pH [i ra— —-— WR SEARO fd fa cartes oon 18 RL SHPO: S01 ih dons Sat wero de stats [omit cnstons ssa wisss ¥hainms svi ge Sid ts em j eta wo sso jogs SOUR: ogo: “Sree | S18 Sounder utd win Ptr Gata? [on 18 hia. py i. AWEY: orien te fr —— ze WC SLOSS Santon. Sos re WALA Ae Shot Fier ct SHO 1% ek he si Sz rns sw zz sven. sowson: an Z) |G. Did vou dsc mil. cus Gorman | nou 23 G. Did yor obs th Boe ry astngs aa 38 roth: 305 rod etna? Noor 24. AY 8305 70 ow ote es Count boRGE mon Son su cepoamon somos Essa swe } i RN FI CHOU Sion. Sine aston, lah 2 monomers soso arene [van 2 vom sureon Toa @ amacrine Jann 8 Ge Oly secies oh be, ib wns 1 TR A een © tone adit Vogels Sines SE np] i. SCAROLA, Sars cost Ts ems; oar om vs. pam ev: ogee fon 7 TL J Ve SCARS San svat | Ty Be——r ne tt— oo 5 weun saesson: i wn 8 he answerer muy be yes, you cent rezosd. erin. 9 Q. Did yu Isms wilh Mr. Bina any i eto SIMSON: 1-1 hs ve cds [cm 1D 8800 dc ses coro br es Wess? © je F wt. ScaaLR Some oiectn. i (wnt ae Toark i te vi [eH Ho. UeChEY- Orscnon. i Loan 13 exauen i have en nigerten. fonts Wh. SCAROLA: See stration. Loree NEWITCS: 3 hae tos wetter, ar 16 MI SISESO, Tia oe obs tio vu Te 5 Tula, to soi aba sR rer on 18 Slseede be snes Olson me 2613 wn 16 Fl. SISO: Ad, Va METRE WE ne 18 Meany hg i 3S: Tot FG Si — fone 19 SHOU Cormega rend? bomen 10 He Boks? fp i avpsons ve. fou 20 I hi OGTR Gog cthoa 21 Neca: te ! hen tre —a2 Me SLAROLA! Same [he carn aH ole MR SSO: i rd losin | ann 24 THE VIDEOGRAMHER : We are Geck 1 he widen : sams: 26 wwe hat wri was discissed? {] a acounss2am. 28 Scans vs ] i [PE Coane orrosmon sumone | in wo aa 1 FS. CHEN: ves. cor 1 dicussad Vhciia Robars sequins of sexe {IE ER SINSOR: Say, av 2 riscnauc agains Frcasscs ershonts wth 550 Tn wea swan Town 3 seis? } wm 4 QL Oy dhs fer re Sor 0s Jee § A. Ma perconally? i wan 5 wit te Go? 8 Q You you posal. oe IR, SCARDLA Same scan, fe A Wm ——¥ HS. HCAWLES: Objection, se 7 Qu ir Decerie 300 of 204, had you id oe SEARO: Sen erst, ru 8 you discuss wth AY, setnerg Ns, Roser allgetss com 9 SYR SISSON: BE un l0 Q Yestacer, umenconse Ustove (the | 1m 10 A. Nok personify no. er 1 120520 th UDOT V0uE COSUSTI IAL 00 [ssa 1 You sy 0k panama, foe ou ava 7 vasa 12. bora acne cos 1 age In he oncer motos |r 12. someone sls who Sad hose cuss of - WE Hr. — Jami 13 thn he lone agains cessor shat ws | ears 13. 1 ary cusp an 3st sa wh Mr Mmehers? foes 19 tht, Soi wes representing Vina bets yes, [crs 14 MR, SCARGLI Tote eet tod tial. ron 16 rg Robes; do ou recall hat ttm? coc 18 queion nculd al fr sry norman tht was lam A ves owe 16 cornmuscated you nth content of he i un d7 Qu Aodymw saison oousoot how highly {wm 17 comon terest pre, 10u should sot ar swe, emi 18 rend ir Sis, § tokyo menos sh ren 18 iB WATS: ight, (ranet garg a 18 4. Gove case: ts hac vgn? fats VR, SEARO: a yo = yo on wens iE | a2 A Ves Foe 20 op sah Sige came you cide the or BQ Gia Sookor Surat NEARY Duan 21 COO the Conmenalcest lege, ba 15u vas 72 Gur ce. They am bk vey son. warZ2 ay notin In our span any orton war 23 A Tm trying — wos trying ta remember. Ym |s 23 dood fran he copter eviese win 24. Soy to ake tie, But who vss he other vives? | snus 24 GY SK. SUPSON: EY I A wred5 Qu nd my aueston oh now so he SQUIRE DERGSITION SOLUTIONS ESQUIRE DEPOSITION SCX UTIONS - 19503514450 sea 4400 vr = wre 1A Ted, shove ight. have. ne 1 subarea, wile har. at your wou 2 OL Buia +s nc kw 2 mat ull re ern pi Sy question ie; Given your ha resare for |e 3 Sid mens al vou that thy ac Gisssed om 4 Hes, vould you uk is vows 25 the com 4 wk. woes seisters, Sve lecatiors mare xoer 5 csdiolly of Gaia bors bombing ut wud | se 8 by Ws Rouen rl isha? PET — on © SR. SCHRALY You way uy sonar thal amo 7 9S. SCCAVLEY: Dtjecton. ces 7 questions the extent that yo had any i ns KL STOEON. yon Insti i nots [cas B cormmicatos regarding tat sect rte ah | DO ma 8 aor usin thr comms nce: ping, © im 10 I ECAMEY: (moan, iia byretheteal? [una 10 he stares ivi for tol mato: os 11 FIR SOPSON: No. Tm fst asking lr fue 11 BY MR. SOHPSCI | p12 nas tose IMIR (ase dQ. $1 Smol- mook asking tsar, Femn13 shoves am, cm amie ssng wader tose {owe 13. 105 the nam if v0 0. | Lean 18 ies would bn prone thi bonne hi. Scam: 97, 1 nastand hat, it Jats Pi. SCARCLS: You rey rer hol cussion, seve 16 fll sng Hes sc fn 2 eke, ya en [res 18 THE WITNESS! Vis. fuer 18 SING U8 2 I2GATy Ure Subject ater 5 0 i Lon 7M, SIREN oan 17 communieton thats eieged. vie was an 18 GQ. and 1- may ove asked tk shea, fms 18 cnswer nuestinss rezaring te suaject matter of conn 18 Out id yo diss 0, Bas eo zi he aoe 10 ivieged aumrucators, bu on 20 coed of Was Boles? 2D Piemsor Cesena 3 stmematin lh Sora on 21 5. vechLEr: hscion ee 29 SAY stain on re tee cords 2000 Gob lnm 22 ok, SCARGLA! Same Scan. Same wan22 sesh, Ne can ans hat question, a nz wr cms fou 24 OYHR. SIHSN sore 28 OQ Gid yor hove n conversion we saya: (naen 28 Qu Prior ta Dscuribir 3001 of 2014, ed ys an 25 jus narrow cuestion: Sid sou leva ¢ ciwersalicn ith i ESGUIRE DEFCSITION SOLUIICNS ESGUIRE DEPOSITION SOLL IONS. ' 3 tei on SYS 1954) 331-440 prp— TR TRAE RARE LA —— or 1 vel Sa pens pet a ver en 2 sted esl en of i Rr’ vimi 2 erm anove, or ws wiles thal ds. Foe 3 esas ssi rote ort i as “ Scasiak: welt aon ey rs PEE ——— ren & Aa ve xa ands so wt el wn re wow 7 MI SIHESOE Oka. lesa 7 Informatian. : ond TT veo hte TB ses or a ease Tor 8 line. 30 Ell inl uc rn Tori comer wit ave motte [ac AD Coen ne soto cast pred wo $8 tamohlnt or wore ics hats su $1 Wynd srw a capoeton sto bos (eR. vinta wT Ameren —————— en ns tn, ini nth ummm pay ta a pon, Tank, Tot vs Hed Ste Tote avy ar rnd [ae 18 bear oar ete wo. oe 16 PANG en 17 vin on: PE — raf GL Sakti Rua Dudas [asa BO. bare vs vl ets ca has ve pa Sing vo 20 at ao comments crf ra ie Rm ———— on 21 ant ern a dmc oh bs [eves 2 maar sr fo id an 22 ipa hers’ asain saves mer ian 23 commanictorest priloge. carrer? jen 23 resiouitz? | elgg [ey [LEP ——— i scum senseon SeLTON ! esauReoERosON SouTcHS THE HT 3 Fora - — w W sey og RR at SE ve tayo i ts whthr sb we 4 A Uh or 3 rc SIs @ pmsmeen nS 0c as ed vo ik od dts om BA ght Thar sige ron 8 chery to testes seat orgs wm © ayes dee ato dd sane ere 7 Satara isnot rte mmr ro 3 youth ha Ged i up nnn Hl Sos sa sen, ot som 3 Fotos aegions so bts embouki th [ao 8 arin. at vb ata vie, srs —t [AE —— FE A eon 2 comin mie tat de curtis rei 12 5th re om, nr shige iS mme—————— or tetas sameeren | res 8 cman. Settle na 14 Ae Nor tomy Mnawiadon. ou 15 etn eects common res ne WE WEA, Caso. Taso. San 18 midcom dameest loos nnd bon ame 17 privibzged communicenonz, that's & Giese re Teme 17 MR. SCAROLR: az 8 mmewnkatar with antes | one 19 E prepare lo emer. oxen 18 ‘else Ir. Ue Jesafobeng -- Bub Jeeefudorn's fim, fae 18 tis, nc vc so Som aniat3 Ton 19 paso comnts snes hr Gs 22 SHON: abe ad he jr aT) omit sleet aro Ha PE ls en3e amie, mt Ak meu 28 A Not Tory knowledge. Ldn know i the Hans ose er prt at nly fo 25 membre of ia nm, kT crit have no ESOL DERG SLUMS ; CALNE DrsCaTON Glens a1 to i saws 18 T i) ain 1 recolctona ang to, you ko, aryena von ws 1 GYM SHS i wane 2 who ves io hie fun. foun 2 Q Mew yess =H nase the ution H 3a omy po Hew yo dove eH, Bo Pt A — Se set tro is oS ene I Lon ep J A —————"—— een & Gi, oh, sod ry rsa, he's snttorey fre | con § a Seni: ome. re 7 Flas, 50 dart och tend ith - $2 SONG. Som chi. Seve lake 8 wen, you mow, swcmeye in Fores, tv than ths |e 8 ssrici cn anes tae Tm crecting with on — 4m th core. os 5 ava soon: ps UR SEARO St woes a [wi 0G. sworts ss doh out, yes J ey cia 11 sere esd of eos re ed nn 12 arom. sveson, con 12 stoves i oi man 13 @ Pr Ces ara 15 A. Alrighty H jn [ApS hi SE ht —— son 15 BY HR, SISO: foun 15 eaenetten. wow 16 0. AG we he 0 testy peste thet fate A vas. LEAT soe os, waeroeags trarcn ae fer ATG ow a ne sure hors wie $8 soralaar age Mas Ractrts. wha is 320 year cent, joan 1B you dosaibe emi. i Ep ———— PN A PR —— A ve re 20 tor ers yee. Gina menses Tn 2 GT Thee tne me ERM ont arn sours Arve hy reat maton [own 22 7 20 aml tt th sores 1 lords? Gombe nd A ou nie 24 enn hore ve eset we hi? FY rv PE Sn 2s A mam pra — Secu esosicn sau ane vec rusnIcns a sa tae ts ra Ea GE PR TT Sm —— I TT r— 1 2 push es ho wun mks [ws 2 fogs Td amined previous. ean 3 capt ptt? avi 3 0 on Sues bis ness | fmm & A asres oa reposts of Hgts |as 4 vw as sore ton stare! fo Wobers tht ved be the cere, bot nk vote [un § A. That my rection yor. ve § comes ewer ne ave cnet on cx and [nr 8 0 Gu. 4h vanessa ; ue 7 nant a th repo ar lm poping Lo TA. Somat therein nan tay 2014, Thre Tove 3 samara rea 8 may ho ti hear ale pin 1.20 str ne ® fT — [on © arte tm, ut doy mem evn thm | en 10 teres ison vor, might oto sang thc {ser 0. in ay ~ sppensmatety ey 2016. i ig Vt OA {ne 12. thes wit aig nt work prosct snd ats ene | mas 12 07 mage Fone Desks mtr Tra crmounsing mis Rare ressanton. ram 13 wn ir 503 rar is Rou? rw a tw tee te tes Lor th A Ho. i 15. 1h uaa rete ve cairo son war S 0 degen tht wren ar 16 Auten De viata? ares 16 corn fe vor chain int cr? tr RL SCADA: Sa ct, are oan 17 A igh, ie eves hort thi yester, so ts wan wen 18 Export 1 nd ings up oof hs. Yt J —— Sr 19 tesimony ha gave yes. i TENTHS: Fe Laer were es 20 “Wht te fia logs named vast a vind, TB mia meio sins moh aver 21 evidence of poten doctor ince off a7 an te i Sie 22 totes aarti of daa .DarShoite 130 — Vera. Zon st on Toeu 23 posta 5 fw anttcemantac, at tnt tne — cman im 23. Spry wt ondersoea t 0 te tha 1 —n Wh Stes: Metre. wo 25 waderton tht he hed been ewes by fe “SURE oEroSmaN SOURS ESOL GErCSON SLES Bn A JO Vidas FE Ee J Binion om 2 movers mane ns pro STR ol osiiaiisinmeiiobindi | ns Ions ug Wo mime i eS pia ope er ary 988th 8 sein we rodeo ht oe i cs Jon § Soma smrereemermmammteier [m 3 een: sain’ dain ! Guin 7 October I may be off by na MOAT has ~ bit 6a an. wise 7 Wr. Dershowitz that, wok these reco prove [pt Gonalumiony ers 8 coda cnt ov ave ht, Ants re te bn i ot ned he ove 5 esheets serie wove 10 Prufassor Dui Showits vies Proeidind huluction iafortetion | couse 10 InCotatetanl ud inaccurnlos aid for sombody who hag | TTS mitment. Tom on io nen 1 pany cael Bre ess nd i a m——— Tie 12 momentos a oct rs ET wone 13 The other problem wns that the flight bos. {ms 13 on the dights, seemed v2 me bs be inaccurate Te Wt svb———————— ru orn TIS. th Tt got Sov ert ove Boies | we 15 ot wo = wi Babin hens wr Te. twtr sem ner | 1216 vivo" ry THB. ve esi on ri ed re | we 10 neon wh oath proms rE Imam weSighiogte mt ewes san St B1 teeters td rt ot LE vata tet arma rae 81 [138 A. or tt Pron usta Coane oro on S500 06 Conc beposon san: ay mes = El SE) SAAR SAI ao 1 proved ps acs i ore | Teo 2 lic emo wemct mt zs |e 2 open ot 3 sme ope drmtatiemsmedetn: [oe © Gesteta ental meester 45 Ten 7 copa, km big var A. pean tht rmdir Bo rm [52 1 inmimmi— 1 ioe 3 marae ere ere sersn ive © tenets te semester axes 10 In 3qiton tm that, when § started to. cones 10. Pea, et us preci ly wits his shale of mind ! J a A 8 CH A ats smearme renzo 11212 maton. ok ats he vou ew, WE nin aa 08 SAE | us 12 va art those aE shave orn ora $4. sv. 13h ning ar, axe 14. coveain othe deiions erin et i Do Ba tt 12237 ants cam a went eg wists |r 7 1 iv wt ne ems 1x10 vn out ht rd ere erin [ies 8. mene ese cere exe 18. nism nd on src mm sob snt here Jnr, 18 ren i tio son ro 20 er hee morse Hh oe, ire 20 atta, Arsh 1 sor 1 ct om eae wpa fot! ili PAVESI ose wiping SO HS A pide [EPPS si J 4 | FECUIRE SEROSTION SOLUTE. i £30URE DEMIS HEN SOLINGNS | TI Th } a Sis iis EEE sn ES w eZ mmo cen 2 cncoutian ana wit not repeat hat vas ssa tne Wn 3 commas over om ev 3 deposition nacmace thre wa madly an coction | a Sool: ke ober (ev. § rom es. come, nt the wes So oie mth iE CT cn 5 depuston ers. ershove made repressors: i Lap—— facia 6 about ese York torre Hentai moses, | we 1 Pre — Iman 7 ana Font gong an H wire 8 be ores PE J SRT an 9 SCOR: pds. he vee + fos 8 shes com 18 capvearearbiaes bee Ate ey fan 10 A B= cts co $1 eo ld ht hi 0 18 hi, wet wees RE rz sac mo gents PRE er 15 acorn ene sn svn own 14. caret atest pores posto sss’ — Ano, hk ee ok an 18 on sete sem arts nly nn 15 aban det— Pu sens, Fumie een 16 natn Epa S00 nis von 46 mtu rect sme. tee n aT? enteantmanss TT new mes shan etn [oeid8 A Sovscacestine mrmatont veto? [non 16 crimes on met cr ove ants a ets SOHO Jha red 1 fen A ve cn satiny sn, on wl QM iee so 4h vt on 21 reo a tts on pare Tiae 22 tot oncom ts ort th ott en 22 coma. Gea Zl A Aight So, obaeudy hen ee SIRS ane ne 28. Smead earn. ee 28 vate Deas 25 QT joel vse the quan, pee, 36 eee 28 he pce. oe H H EGOUIRE DEPULIH SCLINS SSOUIRE DEPUS ION SOLUIIONS ] i oss shane CT swam : - w mp — | —_ [rr ue 2A Sum, Moh, well lt meat i Se See 3 HBA ot— turd of shin ol nt an fee 3 re resuin novsin, pepe pr tots sth the vente itn foes § To cota 1k vd or cond et. : Linin © der, the depasion ofr rsh, which ing ming nex 8 rk ele aan form 7 devon sopra eee somes thi een i by | mo, 7 [A TE Fawr 8 #r. Dassiowits. fae Byam ao alan cies i pis ART i isdn H JOT E———— fs 10 Pape i so 11 pracsicing low — kaw since about 1988, A #4 my. wae 11 A WITHERS: There mas a menses Lt | rin 12 sprees Rive mee ana iors esha Tort bas 12 NEA 5 Ft Wades asep ThA ! Sra T3 Sold Sing GUAR, 00 vanoBy NOU | au 13 promot mri, thc sv be, es Your 14 tno tht acta auctions coma nat boasnes [wu Mac mac cet ersetntons, a1 Deut 15. oy torn, ana wimeszeaovecthe on ovo ders, [uss 13 respec es buses vessaper ro hy we 10. te, Devore acts. avin of ar gle Mo 18 rape du Fed eos ho i, tot ian seve AT ution; vse wart yo on ts doy owe [scan $7 oe tse. an 18 nama; or hake, gs Wha het, ad tend ct, | am 8 J cv 19 ya know, ahi 3 — sn cmc Sewer, he nde up [wine 19 cnt Use on ak ine 20. ging very exert anes commonly puncte with | nove 20 tt ant tel ig bs wer 21 digaenging varie tat sewer abavt oti nd | own 22 Span ht creas a TE wilh seri to tons wz sae nd ar, nm £08 rw tna era fom tht st eB mo sscatn eon Gerona i 24. Nr Dorshowts canok wart 0 snes tons or the | pag 24 lira a esse adn «vor a an 25 ime vader. wre B retain bbe, deletes EsauRe cerosmon sau ous JS ————— son swan da smi ie es EET TRETSAT Ma [Re ——— ce 2 och my rcsbscton ant Pearl en AY foc de ri & tamton, an ho 0 tw 3 fc 4 [Ee —— coi 5 ee atanor 1 nverargs wr 8 renbitonon nin vos vt 1 re EATERS: 0g. TA a ch xm 7 tt eed be ne ae san 7 yeeros bow 3 wo oniwntcwn goog deewmmim nts [wens 8 or SPSON. Ful, it or lowe 8 axninancrne nape Heer Cane cow 8 ovr os momesromion. Torus 04710 sex tating ta v2 va San md cen 10 aang st rrioasons, cnt nc dont, ers cane er 41 SEAR: vec cern, i an f2 camo Tinea he ud, i, cn 12 ET fen 13 comand deer 1 le rs wr 13 totam. wir a mes ut or 5, Cee tat NE Ps BO wn t8 bad shied veh cea saan, he: Ln 18 A Yeah Late mark az an cabbie youd nan 17 as en Thustar. ons VT kes This 5.2 memory aid to me. pov Ane ue ay, Pan, ee hat [RT py wien 18 I Cesar int Sn 19 A Yer Ta. ANKE Late sea A page EO SE Sry PON TRON ——— ro 21 red; eminem, a snake ard ant 21 Thy’ estmony, hr, Dershowitz wes si. Que: ONE SE Sa ST a 22 You hove thr Virgil Roberts ot th oy eran PROT “i223 ia hac cm ander ost (it you ere present st win 24 eter areca y Depot hn a 24 Sete Eostirs Pain Beach har ith young ai, | cm 25 am woo twa or be hese JOT —— i [re — SQUIRE DEFCSMON SOLUTIENS | nara wwe = E) on 1 meg er ve wgwevdenbe tas on 1 hut amend no be flor st te very | ace 2 bnisiton on 2 beast rising tectimany give tar br. Doshi | oes 3 oe oe test or easly ages a 3 tne tht usm Alea, among patty ives pecs [mas & satmarts ontnun, suse, sows in care 4 ha enced i os havi been nthe presence of lacs 5 cannes marerot nen. Te ey aie cr 6 Sut Epon mud yours i th Flora arin jou 8 gwen. ic a0, tndose, hag tied = potageaph of Virgina town 7 Ore of er wtb sec repsdec 1 feos 1 Roberts fom 8 inerarranstign bes or fa B tps 104 o ths transcrip, Me. Dersnowtex fon 8 peru stents Be Vai akotets vor 8 wes asked quot All ofthe mens ha hava been JOSIE Ha fe) on 10 prodwed ts Wigatia, the anes he you say int onanssme ton sre had so nt ak {avin 11 comatorate your tasty 3 exons Yu, JR —— Jirce 12 demons tht you nvr fl sey Essie re 13 Goria tus bes, ich vi es2 13. piancin the company of your vik, cones Anew: foe tt aaron ea 84 Nath’ not rvs, %dan'ehn thet foi 18 Satin my ot, tan 2a 2 ats Aud, again, I to coma of hs igtian lou 16 save. tratten ioames awn rs espn ai 16 wher the Hight ops Nave been, a he question that ES TT a —— Sc 7m smavering tends show, ace 20 cera for 1B ive ore ta Se stan the. wiv AB Derahonit u ety under at tht he didn move J ey Siro 15 mete is ir vo deck Eh gt 10, stick wn) rmnesnd reason oh 358 se 20m 32,4 Rn Very es, TUGGING fortin,but 1 nan ?l te en 2 conclude my option waz acu debertshy Toke jon That wesc proand ay ue dren, | xan 22 information pai, given ti Wigston whece wae moh nic bas ber oval Jo Re —— aT re ace re ih Tian 28. record wt 0a i Stave ecards or the an 25 ames ve pe wr. acu 25 relevant period of time. | CHOURC BCS TEN SOON COURS CROTON SLUMS i _ wc) 500391 sat 1 ERT Fore Tr Ta CEE an Satta tha wes, asi » dembernte Fave 1 1ogn ANST contd inves wy sacntcton here by IE SI sep me RH J vn 3 fumes imeem ne tat set | en 3 pesmamers esses onary ste oon 3 tcinarion en 3 sete seca wre wt ome see ements Toor 8 avis pontine wr bets [co 5 of conic eee the Ome Koen fhm rs Pena wet “re ni ssi 1 cal the A rhe | lca 7 chal round ony strmstwntea TEINS | sen T ttt, och nt sora reat HO fran 8 never traveled eutslde the presen of my wc, dices «a 8 toa information. ! sur 8 quote, represwting thd thece would be nu such erie 8 And when you sec those Inconsistencres, it i 1210 tra tor by tS rae of 4 Acne 10 bocsmes ve otc ee tet fo rnin es 1 tones mrsiomatncoaio wt rv 43. [wes 11 Matos ovina men to mae acncin 50. § ve 12 201, sett va ean erator manor 28 |cu 12 when Teak aor bot rato, pot topes ware 13 years, She goes with me everywhere, close quote, And, {cain 13 beheve thot there's sufficicat -- hove a sutficient ws 14. eeprom eteniontseeetmesieeris ir 8. lair bebe on ened Toa T5 orga am hi itr Akar on 15. 1 esd os. to edn To vet nemo Son Tor sangeet Dima imermmtoear ve pmeaTant semen or 4 wot TF Wah, ev ou eum ote tr seve shout ies | a 7 im hs erie-- es soda mevrrs “oes 18 mins whee you inh ov eecend wht Viiin | i 8 irs seous comers bern stl, pul Sigua Wd eters county epi ot PS —— wo 20. tevin ams nd arnt on mb at prspemme— lt EY py “Tra so std sent: ovotvaravs | oer 23 scsi er. ae ! CEE UEP SLUTS cou IC oCPoGToN Salons i . Pry . _mnmen — ! in Fa Yaar 1 somerset gu simp trsmmot. [wins 1 sennsnn songhig | en # har scberaeae mrmatn eco on 2 amma: § nie 7 with ls 26m around Viegiola Roberts, standing next 03 wien 7 vas [ove 3 weep Grammmwin ra er———— J BB, Tiny yn {wre 10 Aad in the croumsenwes of that photograph, © ox 10 dep wl Ure pe ed aterm? i Renita tonTpt dr Sn i Yo—T—rotl bi mid wen 12 tte wn ot dof te tit 56 2212 tava dre rr. Dos mt CTE emer sro pL aro en movi | I I A ZEU16 beets le rmation benim brats the |x 15. be th seme wer wm prered tv wer 16. stare or floes vt aren brates | ee 16. int ses tery a ol we 11 memati tose ovr rt 1s | on 7 praise "ta 18 mir tommenkatons wlth cht abt whet bvss |e 18 ah su ran BAR won 18. og with fe Sra. BS rh Getter — ot ete bo it 0 oe Bs wh TB i bi, wn Zh ppt ta moe mm——— [oe 20 plegeisigin nT weve de tat ata bu sn [nea 22 tara. Fn +- wT wera a ite ort 1 siraerwemeree sate Seo LVI the youkim tur remus abet [oon 35 bemant, Fv DERORTO So TO pr —— CANORA BR il NI i r= SET SATE EZR ES coe HY SIHESON: win 1 purty de. wo 2D. Weore Womestay or chs meek, you taduse Lures 2 BYR, SIMPSON: care 3 a8 momar hae at cee apt frome 30 wy cwestun, on cost ie: You reversal cm 8 Professor ershaite's esr, career fous 4 tho hght os, amos ara § A Comet we 5 A come axe § Q Tuga Wiosketmy mies erzofyar |x 6 Q You reviewed dren in some deat cones fiver 7 tong maser, ut one tg ou edt sasche [xe 7 A Comect Foie 8 fact thot Prosser Dsbontz gave log ansare aor BQ Tstheroms ante on those Bras ferns 8 someln wdicseun cf take sneserzor sonny i Lamm 10 HR. SOROLA: Tht ier in 10 ti bokerts on ce sc staves ! fo 11 fr SSR: watt A We imerf2 Q -svate comet2 @ Andso vou testimony about stions shone fan 13 SCAR A: 1 natant vn 13. the cematctences an carey cr shee ah fogs oes wie 14 ohisacheiaion of the sal ant tek 20018 instr he tg arb eps that. H ene 15 PrfesorCenml ade. Hedi mle ote [uns 15 The ence Uhl you gece el your sion | man 6 lrgihor coarser, bet rather hoi 1616 55 your cows 3 to ene com iteness ne ge NE — Yeme 17 teas and rene they may hws boon charges n some. sa 18 TH spp: fevam 16. wy, resto wheres oc ge ae vce, rat a1 Qn Lele me snk s fet question. laces 18. whether thay, fc, ups Frfesso Dera = wn 20 Go back Lo the MIL fags Lhen:subves. fumes, 20 testirvony Gi he wes at 1 8 sine wth Vira 2 A OK Tans 21 Raden c2 Op naa tot got song dunn | wen 22 MR SCROLS: i 30 to chet te en Lae 23 sven Bt re Hm a at gs fon 28 cre question coun ed shane, 1 dent cout 24 Uses spon Profi Derstomesteiany st | seca 24 undentend wes 25 hema roveran a sian th digina Rabat, he face | ave 25 THE WITNESS: Aad wore ghe a org ans, RSQUIRE DEPOSITION SOIATONS ESSE OPPOSITION San VTIONS tory 1cdz0 65031 det El EQ ao 1 of hf og pa tot sro sa 1 Y= thnk, a6 proc inane, yu wis 2 A. The face ofthe fight logs for the celevont | nem 2 canis bok ee fe of hase covanments cen 3 porto of ta, we can cal he NOE parca of a o | xis 3 AIOE 31 Ko, a6HSL the Cones «xs 4 whatever you want, dla not reveal he prasance of |mc 4 ofan namo) sn efi rg cite co & Mr Dershowite on thase flights, yes. A ! won 8 Q Glen. So curing the pur el, wn § jostosk and dosent and sure et they wre { ss 7 acolyte’ no Mah fog Ut shaw Vicia wma 7 100 percent scauots mht Ul teing hak a 8 ona 20 ur Daron on ta soma Wpiate, [cows 8 ome mune, i oe 8 omer arcs 3 10m, Sypson i we 10 A Thats my understanding, es. ome 10 Qn am na, halon fc of te wall @ awe ane 1 fights, eres ori shows iia Raber um 12 FIR SCAROUA! Brame, Youie-youfie = [vines 12. 2a rofessa Darshwi o the seme lane” H un 13 5, eA A xn t3 A Thats conact. i oe 18 SCALA: vi hth ress thors [own 16 Q, ane goon i wads deiot by mane? va 18 fd so unsertand comely in yr | a 18 5H SIHPSON: cruz 16. pasion a Uns he att log ney cot be comple | Jowe 17 Qu Toyour nomsecae, fn c caret tt imc 17 my hae boen cemoad, bet ou da at dau, haton | own 8 S102 10 ich og ats been rosie ns ssa cow 18. har ac, i spp of asce Descote's Funan 18 tay ny purty that raflocts Profesor Dershowitz ard rune 18 tectiteanyi Huan 20 Voi Raber sth sae plane, a vou red he cam 20 HR SCAROLR: Objection foun 21 Agr toa? on 21 WE, MCAnLEN: Cbjectin. foun 22 HR SCHROLA: Tsay. re vou asking ons 22 HR SCAROLR Camp fone 23 wnctrar those am names sspeor ca tho gly [um 28 TIO VAITHSS: Oni et spgrage rat EO ron 26 17145. sn5ON wa 28 HR. SINFSCH: My euatan, | buck, i in 25 Q. You oon Ure objections vey wet. i 'CSQUIEDEROBITION SOLUTIONS | ESQUINE DEFOSITON SOLUTIONS Eo 33100 ! 550 3314100 TE EE Taw 2 Sto sven PSA a AT mth we en & A. monte andeceantng vem fore 5 times mi 8G habla ents | wa 6 A. = tollawing their newer. we 6 CeposTIon, he descides She Lider oath 200 Sips ONAT H 00 temas mon PR H nt weno eos 3. don't nave sccoloctin ot clint Sona sum Than, Pg A TAG Townsman stone ori 0B GA wh a niet, 3 LEXY gt, st on qo a ect 730 [orn 11 Women io or soto tm wm 13 A Correct. Lae 13 ariptoyeri TMQ meters day don foe $4 SC Eyre ie te S016. razr hea comment ea T8 mim wesa many ceveer eve 17 i Act, coven pg JUHA sr 18 Byte sovtson. C18 ummm ht the em de, on 1S B. -tutbovasetor ve whl Vig 18 mc rl i D2 A Thee youbnaw thacthe sor tsticking | use 21 314% sms: S722 ina un by ete Come ba produced ost ight nm 2M) remo tba Me de | en 23. 10g hh oped sho that hat Bert md | vs 20 ey, eh 3 ol mb Sid | | Cains cerca ion soLiMoE SSOUREOEPOSMON SLTIONS | H oo @sti 1-08 1 wn staan 1 I Ee En j— HR schious: wi. oat 1 the hon fsa ee ree [oer 2 fe — foe 2 ve apoio, rs a oc FC I imei GR No BU own § for bot, St Tor fon 8 Q termes. vs 8 8. SCARRLA Ye fon € Gn Yoon 8 summten, Avett roi emer ww 3 A imeem ttheugiw = fran 8 mom boss bree na nt po HR SCHOU: ards mms, fear 10 Seok tht 4 ln lis st tt “ur vues: Tm sony an pos wan 12 av IR. SATSON; leew tz ‘Boon amnsted a0 chaged WI Sing fram har A far cpap, Wik A Cove bout to my thtibe records other {1 14 EAS: Wh se emits ke rs 16 Brodaced =r ~ Timor fomn 15 ase acon, en teh ctl TR eres te th pe Jon 8 oemmctt as anes oo on ec prop LAT pre Lim mses att, sate yo Ye 19 ito thet hn Vriin Rebere an Alm Dershois |1n 16 Mi Ri 19d iil? fo Vow 20 sling nen och ther, ve. Tend arene dette eee oo TH PO ie 1 pasa GT Wt SP AA an 28 1nd Ct src sg co youre do [ven eve inaone. edhe? ad + ctmston scan oon son ncn ERC EVO oN Gena, Seria Cap OE EGER 2 El ar 1 ns pice te anes so an 6s kn ene 1 He. es hd sh cht sity in 04 mn eons to loge, RS IRAE [on 2 amet of His Busi or sash fen snake con 3m gemanenrm Saws wns 3 A. Tolar recs tat. Ithute i there, few & hee thats sone have. wo 4 youre you'ta making eproseataton, and Know free 3 A, SWS, mae mo tee 3s [ware 3 vou fins avpes, so XW accept your as 6 convene, oe 6 representation: H wor 7 YR ssn: ov Lait recall thst he he was testing ws BG. Wynne ehh KLRCUE [cna Bea day or two ogo on that subject. eB up Ie fF unees | mrt a Lis ae. SCaRA: we ave br ga for abut an § rato VR, SCARCLN: Tina om: Db an d0 hor, hit omota eke brvald foohnt H wer recat lhe contents Joan tt csavenient for you? tt Sos: Tr 0g the esson. fiat SON: ean ke 2 rc ne, nt BAER: on le dessin, | an 13 THE VIGEOURAPAER: We oi ote io rr 14 rsp Cul YR I An 15 sat ction in 15 seipa a esa wes tos) rn 18 WR SCALA: Oke. Thank ou. pana THE \ICEQGRAPMER: We 4 back on tr Vika sa 17 pr sian, wT an, aren, 1G. tacts you our tho ko wr [wn 18 Th ASS, 1 nc tote Eves, Crt 19 thal you So a abe ais tore ha Profs [vce 19 Lina, ut spsiement th ov secur that eon 20 Bertoni he ce sii fl eo mia Gave stout the ser of ns. ome 21 ore rlcant afin ur Khe wis iso 6 | ows 20 Ty oki ut oy ech, Lia hl HZ Scotian, hoot MSA St OE SGM [aw 22 TS Sth 1 Hm mi 5 he rg — A Vem cn23 wermomy. re HOEY wr UT — a2 O11 cs Sow 28 Sees dpesion nus cate that oft parts co 28 G1 cont = Tr roti to skate 5. ESQUIRE JEPOS: ION SOLU ONG ESQUIRE DEPUSITION SOLITONS i Jp 90a 321ca00 ) Fo Eg FO — fomen 1 2 ten ve apt gout — ye = your H oni 2 MR. SCAKOLA: Mir. Sunpoor, there was an LI | A. Iwould like to just supplement -- i Pres 3 exons reference to ar srw 12 interogetory. jean 3 MR SCARGLA: Thal's ine. Thel's fre. If [oan 8 anche amos amp erica anasto Jun § dors he, ars on wn § elt in gardens oom savers Po § HE WOCSS: £3 br J ha ig We SCALA: hk 1220 12 td tak x 7 [rE — ie 7 Urea an nebveten nisin. — CANOLA cat wt tory [ce 8 “Te vamess. Yoh. pO eS BrI SERS to [rE pe SN FOUTS ——— vo 11 slant tert bo or, Cink a tt ae rd tose awn watz A Swe —t 2 SCADA: oes + wn 13 QL teu ves sire, One auestin ta Wa: +o covey regan | vos 18 Ahan gH gs an, on 15 HA SARA: 1 abetto yor wets a ola. wi fh Waser of dasiar timers. 0 |r 16 G.I tks Roh, thet yn bei wen 47 sc Howes ro arom are Us wr Tm | was 17 26867 koowhdgs 451 hh Persr Dushonz wn 88 Cort pr con SOIT 130 | we 18 sore other ember of JEANS Ean cen: £m PA ren 13 regan hos log fo rah the gos ent oe 20 WA SISO: Tr mt guig an ay st wn 2 A. 1 dome have personal knowkedge of - of Wn 20 ah To ety obfon ti foun So 21 thal thats right. aR pee, we 2 GL A vou et, 04 OL ECS an 2 BY SAH ra 28 OF vr nat RSI. Er 2G quent ahehor su es aware thy | wane 8 rio wet tabs o hs, cir? er 25 Um tn Por Gebers pled i fe, |wwe25 A. Careet, CsoURE DEROSMON SOLUTIONS Cou pErosimoN sou TONS 1954) S31ML0. 954) 331-4400 Em RATS CEE om 1 Que de mrad yer fom 1 [prep — JES SRR SA A He ess: Th eon, rcs [ging wm 3 pumas oahers blancs, re nie dA mater. nA meet ahve Sek ant in SQ nso mrss ese ores | wae 5 59 SHO Cea § rere erty Exe, te itt steer we 8 Q eno sin Sm ean ca 7 some rac isnt a ee on ore 7 reveveatnae san of me pce san aoe or com 8 secmduton eso rt eco aster PS Ry cre 8 wn; sm conc a 8 A Netgear. rnd A Bight. Candiuion vith the ov, yes. IEE EP A | cmt Game cvs 1 terry ystere tov na ses coms ncon nT A Smo, etme pest - conmnt ai [cv 12 tangs yo ladon = apn makmatne TE hater a with the lice obltins of scram. [15 13 scars aa ssa stan bse Carita tc cannot ke, for ramp, ex 18 roti su por mons } [own marermeters whemsoet an seen ese nds ot hon 18 Ae Tere y fen e186 things. oun 18 GIs ws ur, kf ack be het police. H re AT Qu Wahi The dun os e deferse coun, Fuss AT reper. indudes wn interne wth ae sd wee whe wey wien $0 Fut DOR. ety mia er aban cam Baie 0 aed nd Me IS Soe 19 ret recat old Vey vein nse ase 98. ions tn gas, sag ors erm Tain 20 wth te aw seg acs, wt bee2 A Xveterstnars comet al A Them [REE — CEEOL facie tow hen sone he aT alin 0 reno arcs spo ppg 23 mace coe wot rr sing ne shy wth Tasca. —s SEARO osm, Ao Ye a 14 wmaZ5 Gantt yn wre ts ovat 5 JH —— SRIRE DZROSTION SOLITONS EsauRE QETDSON S3MONS WE... OMNI WPS... ........ I Ed En EET ————— sr 4 SHON Cec tans JRUNPI wn 2 agen, ws. yon yen tame om, vn 3 rane re eset ne rt wes 3 chatty atom ae surors rr war 4 A. sustthe tact of epessatetion sons? is & oman we 8 re & HL SEATCLAL Fast 3 fot to are § A aan marc gne. sur, arcane, rn 6 cmon, pence, de go sca wot i war 7 evervon 1s snitedtoa defense. rs 7 ae | Ene BA Aue DPT [rE i sam 8 revit ery Sit Peles rent? er 9 rp —"— «10 A Portions oft, yes. me 10 FR. SHERL: 11am ascrga questa ! I ran bps de, Fn well A Ttkriowed motor bTdont (uw obfcacnsti. ken onl se i cc: 13 Shik ve ons Brough pe by sage. ee 13 VR SCARS: 1m so amine H ont din de ole fe Labial aemderticsn, an18 A Wa tl ae Selma Pocambor 300, 000, rien 15 kes ete wae ng fo [irae 16 8120 sn 3 the cave in shout uy 2008, was ums 16 WS, pve cons sa tae | foc 17 about a sxcyeor period ot time, 3nd 1 remember Ta boen fcocx 17 i SCAROUA = tc acle ta alate i {owns 18 to Florida x wouple of times on this case, once ia 2016 can 18. fui ou tt sire peer 0° wv dere. i farm 13 amd think wmochr 3 enor te, Ai jen ts wi sw, ae atm rer 20 remember, tous an on of those oe, eesdng he [en 2D ness i eo 21 cepa re ih Got ow cor att evn soso: | re 22 [re ——— [NC JRE, Jomn TB corwdane vk the ov ene re fen THR NTTIESS: Toe, Sade rams BB ale ara sop Ak re aon fen2 cherub [Ep 1 ENCUIRE DGPOSI IGN SOLUTICNS CECE DEPOSITION SOLUTINS : on 2 on 240 ra EEreray TERETE ura 2 tosthe wenn rod wha nag bregta vs Him 2 Hove, ye, she doc ound Hk she would ths wri 3 sages, id tthe, to seve tocshed myn foie 3 ype. wr 4 apse? Trae 4 Qu ard zo 0 ou saree wen re then — rT —— ED A ee pra mi itosmtion in thos ins the police rape us. | wre 8 ances reno why uk isp 0. oe TG one. anaes oo ve sknemlcasrat ne me TO mosses ts hae Np — ice 8 aman tht 0 sce roar cm war ov fine 3 ewes Pi bet Won: hcl izes 3 ee oer te pe 20, bs rds go peecty cre AD coset ons anc et pera oats? ce 10. ethos ages, ont? leant A ves, out not inthe sme sraperion ie 11 A ven. Tost was cone or vo examen, | a2 GL yer vest sparen, Th - an ars 12 thot waz omg on. ! +m 8 spr fo cso, rele tore ac 18 Qu Ger. sous raw com he kee fomn 10. nam aca ghen 1, pone sadeoncn tie nate [ons 1€ spec “cams cons fen 18 psec sanmmer ee 15 A Tastuoe= [rs 16 A somone ums basicaly a few tolstes i160. verre cormaseat +2217 examples fom what could sc, faa T A Tht vs my concuson vhen review the. | PS LE Sr r——————y ET i mire 19 HAE BENS rape 35 im Sclala papas” frame Q. Okiy. So yo Incision i hat inZ0 A cl gun the ackop St bio 18d — coon 2D Hered a IE to come var Qe wpa Fone 24 oot cote J fex:22 A. occember suthof 214, knowing wht we kau we 28 MR. SCANDIA: Faken ae. THe winess k aot Prue now yes EN SA war B QS yossseer vows ey wepcons [TR —— 25 paron? SORE DEDSTION SoLUTIONS ES0URC OF 0SITION SOLUTIRS ee aera smn w w@ sain 4 pron. sums: wr Ae ame 2 tren ama pn mat kes ie TQ Dap wars rss ne [SO ome 3s sl vat une 4 A men twas ping to give one aon 4 A Absolutely wi 5 Susance, anche ove sentnacn weld bein the cor [re 8 Qing come urself a rd? re. 6 of st who pc rap sir hy hd 29, ie 6 AL Wel css fo Sutin Fad 2, yo. wan aporomatal. mar gs whowere - whawerebelng [nvr TQ X--kt met dias. for vi sor 8 serusty stud, the etree: to legate massages T |v © 15 ame it pron, Sry Fern, ay sd | cin 3 would view a lta vie 8 1, Crt in ma ama, aces ht rs : mn 10 Sayers wn oh codec, I cour 10 poser sume 21st somata | on 11 S10 pt Fa, ot hy Et NS oes 1 evs, cea er ae nn nase? i sn 12 ow a2 A vows reve to aokst the coment. i cd A ve on 3 Qo cnmom, = tev snes - cert ie 14 Rando ro tink ference ter te oo 14 ensues eo view ree 18 abo ret re ma he ache? nr 16 A Work sore evden ee, dS A Ausolta. A woo 17 QL nd wers os are eon kc ep coe 17 recs sealers sa egonse meses? H caus 18 gw ¢ rors za, eect =a wim abo ves Jn te A The cepore an is tne, tes be ear, SF Ee Hr SS —— rk 20 pS Gnd Astye, Bo GEE ELCHS {ovat 20 Spore kad, Sou r,t kg. 50 | ies 21 nthe inn te set ran 21 hea tt som ote a mage tet cote, | win22 A Something slong those ees, ves. xu 22 ToTtncis spaces vou aw, re concern | [28 0 ndobesso tata sot he {nr 23 we have ben ing bot i foros 24 ams tse as ney Eos rp se Cnet Qt, bos omer JN, i Haran 25 mas i, aoc, dL pe Lean ZS ser petty, eon hat {ek one 3 | i FOUR CRCITON SOLOS. i HOLME DESOSIIION SOLU NE: it 303712080 : JE TEE TT DYER Tr Pm = [FR ERR vr ep————. ] i edi res 2 soi samsticklurane oan ot pl Sa ra 3h. Boe ts Uso at Wk tt naka ia & 8 amaamen tos rms Tove tectum 19:0 oes on er af i wn A Ne. [ETE ! wim 6 Q 0d 1 anoestend yormrday that vou tema B A. Mo, because ne waz not talking to the Press. | vite 7 tebed— cto creme ema veer, Ok Toe 7 its ulin to am 03 nen wha od Busted Ho fo wen 8 seated doe et hrc wre rd Jee 8 cimiat sive, Aad so rvs arin hak ott bn wm Butera ot hse esas Ht goad AWE ve ©. seo Serve tot 35 ean Sats 9s when they St wa 10 cont cart mes? ers 10. sspechendeds was avs ormaton bee ercemact wn 18 A oy my imprsecante sho names hat were | soem 1 anc thet woud oe nll a0 et hey cor nich 20s 12 dircled wor red by Alfredo Rceigus when he was | 7 12. str Hier shor br he phrases somtimes oe 13. busted by Uh 10 fo eur 1 he ek 6knt0 | 11a $3. 13k 0 ak Te i Ach ond wud Get of a1 wo 18. entey hoe wha watt Rove faa sou the 3 | nos V4 26% sper dt oer he Fv ere S4ETCH 15 sacking orgaskoion. And vy bcd oni tne | om, £5 evs king et’ be clo, He ws wscs 16. cvidance 3 nave, believe he amet hat warn cred | wows 16. tuking ie somebody hu erstond te FRE 1g 4 rn 17 sere hace she riould Bava he nd of nformaon. | 40 17 the li, 4 4 a he cont of oe ar 18 GS kk gor tesinany 13 tm oar ane 18 comvtaton. hee 18 doze, Wis ot hy ne aro, HS Su — Je I nos 20 nto ort of ir ate oe moins. Crm 21 A. Tho they would have information shout the |v 21 ced hes ames? ee 22. sex rthcking oimnicaion, nd hot Bd probably [un 22 A. Tove reicwed know) col rtesh my [ve 23 aaa ha hay wera porto ha srgonzaton, may | oe 23 cecolltion hare, ut here's a PRL 303 report of Furs 28 can ths the ware wliassos ta wns oe arpenieeon [vom 2 interest ths Srumatanec suroundig Lins 25 vas doing. cme 26 Mr. Rodrigues arrast, fd 1 brim 3 inva wad thid 1 ESQUIRE DEMIS TION SOI UTIGNG RARE 2 POSITION SULHIONS H mg sian petri = ow 1 at hy ort Ws ton tna B, |e 1 0 [ree 2 ven ther entstement sence tthe. [vam 2G Goveuaananatber ie i shar so vs 3 tollowing up en, Hf they are trying ta pisce together cae 3 wortecte) ofits Du shoni2 1 ciscuns ay seer Te 4 what the sen ufickin seperation ea doi rn 4 Faraate ue she spr vs Span re BQ vay en Guta csv sn an 5 comer wea 6 WIRY HEAR Bkrand HEA Sea SIT ASKIN, wtAd nat toms 6 A 1doathave personal inewladpe of whst the PR aN — Sema 7 roto fol wp aor thet. Cae § curled diane dak Fi peo es GO 1 foun 8 0. okey, Coeodhe res pats dria me i Hn Rui [eon 3 boueis rm coms Poveatmur a 6760 i a0 A They uaa wed ndiste matty ee 1D A hoon on tapot my nest, na } [uca 1 naaintormatin chant to cmt acti, Now, Lene G. 5 iwerton tyoso fi mast te: i Tras 12 would they on the = fust ra motets mame eas con 12 $0» fe ens, oy “Se9 out TAR? H {rm 13 ide tani hon, rench tht concuon? fais A We i fron 14 ‘oll hats wpa aon suse {run 4 Q. Toyoue ses, ons Carmo bv inchs wn 15 alo I hi cont thors os of sth fait sem [Sr Spo T—————— TUG Tamu vem vas Covey i amr [in 18 vr. ene cr mb Ten sexi an 19 A That bev, feats A. I--is there 3 way = aie You representing. DE I TR Joa. sermememrasten vl ar sottre a et Co nam PS, —E A Temenos reel ere Tn 23 exacty whe was cheind, nt knoe tht sume nous (cae ZD A otay. ves 10m 20 guage wc clad sd some homous poke wer ot cxw 20 OTs crassor pats. [ens antes. jwxe25 A Okay. Sure. Yooh, Tmean,m = my ! CHOU 0GEOION SOLUTIONS ESTURE DEFOSMON SOLITONS | ot 2100 ashen rE Lp seiais oes an wm ont | understanding woul pe vist nee snake = aes 1 all ows 2 could loka question spout hecicing —oryoue ars 2 0. Take asking se you ment ck #0 or 3 epreseatation” wine 3 dare nan 4 55 Uh circling the sama type of circling ee 4 A super. Thank you. eas St 16 done for Hr. DaishamIo, for sample? the | snes S Okay. Yash, ¥ thai Fm = ¥on arieniesd Linas 6 same, you know, handvritig, cama ink, cama = soma | wove 6 naw. BX nave looked ot the Love ery. foxes 7 appearance? Youknow I's consistent with the men TQ ne cons 8 dirting — are you resreseating I's consistent with mem 8 A want to look nthe Lowe i coe 9 the sing? EE cand QM Cas, 02 we a deruemen: ured ns 40. scares some trasyu ehorod on arta Conn 11 seavany oak has arcu seme lic. Loong at sett A ves Fema 12 the ecumenism ry dizer the cact2 QC Ali vod abe bak ee Fenn 13 cents, rae vou ames or docu ows 13 Cre av £17 sles or Comte Low, Tok i wea 4 MR. SCARGLA: Court hws 3 ok - col ves 14 ot thot sos. i wan 15 vane tne decumarey was 15 A Adrgn seer vi 16 PR SSN Tees cas term ke cae 16 O Sle. fed thendveu lek a et wal? enemenen. Coen Tera, thes en or ruts Debunic Ute wn 8 THE AEDS: an 0g off he sies Fenn 18 abo cite, shen bs an tro i. 10 PS jen 10 mmosteca. ws 2 Mheaspon, = ev mesma) vw 20 A onyeen we 2 WE ACTER. Weawbad onthe die raw 2B Deva theo a2 ree, 100 an. wae ® A dseeit ae 23 MR SHISON: Catv. Backonthenmore fr win 23 Q. And hen ato hs otoer one marke is wn 28 gong sake penta = wank ss asset a as 25 CEs rutkpegs deeumere 1508 iy of wax 25 Au Yen Goth ase thase enries icinis ‘EB0UIR= DEPOBITION S9.UTOND FRGLIRE GRFOSTION 57 mas, ENE oa aan a El do 1 heats book ne have been Sseskn mal 200 [wos 1 Q San rote Um gee an os mat wa 2 ARCANE Dec Mr Cag ake 3 0K is 2 aman bz caern ize are: Cuma, Gove mise 3 Di eT gain ak stout cana ot wae 3 Teas, and en Deshonts, amet? | wet 4 eames wrz 4 A Corre, meng the othe, ye i wo S$ CoSES S0 BLNG -ca f ame SQ Ardley amau cist ans ms eg am H eB css bak ns waked: ston rd | ans ¥ RSE and) Sct, ps te one 7A Yawn. xa kind ote =u boxiswhecT i cor 8 Tags on re vo 8 would say. Some, pes. 1 ame © wns: Sure. vos 8 Qs tania anne ost 90 H aime 10 HO SIVSON: 16 Be va attr sore 10 Goma th ats 0 ONE 13 ching a 11 THE wes: conver yen. ran 11 the sqincance a 52s ana ts say manta i saa 12 KR. SINFSON: ~ aren wo 51 = Slee vw 12 cna pioon hr archers ant epee ie he record us 0 wr have har. aw 13 A ton H rut rms EL nei 15 THE GITHESS: Ora. uss oar 105118 Coste |e vas nord in os Hrd sew vi: cnt8 zines mies se [EN | can. 47 ovr sWrsON: ceo 17 A 3 would infer thet i were rnning ors 18 Q veh Toke oko meen ek a 10s 18. «rim investigmion though the FUT and I'm eying 1 18 A. Okig. Twrank to make » ows noe, if aS | rier 19 ind peopla whe would hava relevant Inarmatian, she. rues 20 SH Fight Jt 0 Gok them 1 112020 woula be ons o the peopl a viant totalk to. X mean. is 2l @ mam corns iu 21 the names tna are cieted ners, Glenn Haxwely, one of aw22 A Wo, noton the exit. Tm ust soi to live 22. he isin traffickers, epstnin s sired, he ocr 23 mabe notes to refresh my recolection zu we dont have {cto 23. pifol = ove of 08 pilots 8 Girled, Sis (hese a0 2310 take ime. Tim se Xn just making soles of thi {var 26 ponte that i seared ta bo comactod ae 315 SH Fun 25 comet Hore. Thin Wil just [ake another minute 15 |-an 25 being marked hare, 3nd — and the number of peosie that GGQURE FPO6 ION SOLUTIONS i ‘COGUIRE CCSGSMON SOLUIIONS (50 25140 } 2 sor. TE GTR EERE ETT EI = 1 ar diced onze vou know, bn percent 1 Sie et 2 ther otha ln ark ont 3G. ok kd st ny ean, Yo en 30, Damron behets ow 3 So hf te 4 GA WE ti Tres A hey re, you know, crm hing hats avi 8h snot ceri cacty hose bok kis X | son vd nant noo 3 Cm 7 scuay thought tw ld Rods miming» [os 7 fe fen 8 copy of records in case he was worried hit Eystain wae 8 A WT were running an —- we wers in the rine 3 wight mae owe ts pl, masa | em 3 sant, Ek 1 yout acon, oar TO en i rane sl, i uh ssn 438 | ve 10 samenady a rio a eset te fms 11 happening. isi 11 orgenization, 20... thing SISO, Cutie [a2 Do 0 eof atti i wae 13. oie obo ay of ot oe on cree yo AON RRS NN a Sl To i AR Late oto wn 17 adios 00k? can 17 MR, EDUARDS: T would 11st cbt ta Sis H J TORI ans sa : Ng NNwusudonbiiiull oe AC d r ee 20 her of hr td emer heart a2) Jes nmammirdin ! weet 21 Actually, 1 ink t's » third possibilty, J think lems 2t WR. SOMFSO: Okay, i V3 T2 Wate inet Rndigues's mss vy St {vo 22 FARES: osc at 8 132 gag mace a unr Sp UE omg emit on tae Von 20 antenee of sda’ ba stron: vay SsoamEcerosmen sou ons [EE prio es = = woe 1A Yes Toyar mean, ther sr tir — vers mg Ann vn 3 ras are cried i appan a eve reese 2 eat oi et, wn 4 idomaion on aie Esti’ mil miss [ves Ee —— Yi eho be JS wr 8 thao men wn § mime e— mn 7A trey dot oyna ven [ves 7 kat mo wi bed weet] "a 8 bak dont eve ot offers abet Tm. [ves 8 dr, en 3G Taser wanna [aes 3 Cir armies. naw eit Ke una thos bie oun 38 [etl terns $2 devherea ot rely test Toure ph Tews: an 13 G Andi Sdn bs 1 pa HR SN Xa. Ys, nits A none I ps ini SRNR ict ok ERAGE: Yeu Tots mime ot BT orto, tin mm, re ado [oo T7 be a, Sin 0 pct oe 0 nuns mint wd mbearaatetetotenet aor pg var; (mpeg acide [ener 3t Svan: Sr [OUST SR ii pa MO SEP nT hdd ve eng 0. tw con, armas arte, CSOURE CEPGSTION SOLUTIONS S30URE DEMOTION SOLUTONS i 654) 331 4400 54 1314400 i HOUSE_OVERSIGHT_0108681 B wT Frvee 1 Wesumsan of hs arsed, simon sth ari ae 1 se of enzana emma suse a wr end who i tome 2 mobs con 2 veel, his excoued intra vies soe, wiry | we 3 A Tm sary, Which residence? Which Epstein Lenn 3 izaranschiren osha tre for a weed? en 4 restgencer [res 4 A Twa depend on the decumstanco, wom 5 @ mum pen JE TE —— mone BA Conyou— cn yourenaer {oom Broan gi the ronson, a tre vm Sea oss, wo TQ ve ora 7 ee lt sate fernaos we BA Ten thet’ kind of a compvund question. { [sone 8 yered ster rans bers ha oh er Toso? wen 9 oan. wae 8 A Ne weer f0 Qe tre ropes Tas boca, wes ADO. br yo ame oa vin le me hack we A vem oe 11 anu afd Qu Vier you vars se Duceriber SOT 2M + [wes 12 seeder tre send thes ie ese 31 0 Sack up a ra. eee 13 20k corns sb es seal 9 sec, OME © etd A sum rees 18. ingirsane tas ets of 1950 te rte 208 15 18 Qe ded easy io ast od ae ovvie 15 ha corset stn sur vnc once font 16 ase or ven codon hac plas wa avs 16 A Approsimotel, ves. i foots 17 aptomiete une Us seeding sous Foren: oes 17 Quin tvs Freon Desbnte Trion 18 Taran f riscn ut 5s bpm BE copa 18 0 Un Pte Baa nn dn Sl poker cova 19 am zt Pouas, camer? eu A My understanding 1s 1n the nlpnbornond of = Lnn20 A No. Twas more man that. Hews 3 vr 20 what ums et Toree to tive times » year, zraing wo to even 21 remand puest, » frequent avernisht vest. conic 21 three iohis etn ime. : Can Wastes: Aef Secente: 30k, 20, len Qa vas at sun vocestening 2507 i cn 3 Ate 3 AN TO DR FA HSS LL] i fun 20 seat be maim beech Fosse wth fom memes, Lonze A ves i [ens 28 dud he aramichieren? Dma25 DL Whee ve bis or ar desl, i S3OVIRS DEPOSITION SOLUTNS i ESQUIRE DEFGSTCN SoUmONS i 060 5040 ! 4 1rasn wo = wal Awe Ep cur 2 Q flan Doyeutrik vs cama seul cae 2 A Rint Thaintormation, you know, Loaves Loma 3 be esoubi to elev hat sere wv 2 rie 3 long presentation yesterday. 30 wes tnt bas § carvnieg nied sw: vase of me ot ie rae 4 information, ETT ——— was BQ. Venton sa sarees om nue 8 reomeren und ag Fa sana fo sy fora Jee Bani ra ll anges 0 va crore an ue 7 vk wee TA Yeah right vw 8 A woud dependon the circumstances, 1 [saz 8G. —uitheuse sas 9 icon you hows, 50 vou knows it would depend onthe [ss $A Xapprediate he. ron 30 dreontances. os 10 QL tat tre say, vows testo hat 0) ner 11 VR SCA0UA: 47 os eserang dat cs 11 undermn 23o Gesemser 0, 2016, ha reer wan §2 Jefe amon ws tre sib tne? mamn 12 Darshan 22 le Gases as 13 FI SIEON: Lon 30 sei esto. smn 13 enon sare ee es dari 1 eens sod seth Toki estos. Sn 1499910 Ae oF 193510 Us 15k 1 2000. wor 15 WR, SCARDIA: a, sat. nt 15 FASE RG R20 Dicer 0 6, Pr i en 16 Brn Sen rien 18 trom wnt 7G. So ver we, yas 2 ree ve om 17 A Right Lion, Twill ake shout s minus. ia 18 rape hat 102 13 er because there us fev things Tank was 19 Pope p—— oe 18 Q Okay. An far fo mess sieiny asin is wen 20 distances — nn 20 ss wee2t A sore swe ent A ure. m2 OL hat ar cvsmer? ea 22 Ginna: ssi vou shout i of our wan2d A ve oro 20. res bout embing ok. Js, wats Je ass mod Q. Glas. Some sa dort Aad nchaais ane 28. or sou sce a vo wees 10 hs Frees ara 25 a somo wn ke ses 23 paris home Te a ESOUINE UEFCSTION SOLUTIONS (C50UE SCFOSTION SOUTICHS so 351. cat0 wn eas TSR TER TORE EEF PU EL i he SEARO: Coo fy 3 am 1 tent, ter sl tant ass wd ——————— fue 3 button ah endatta mt 4 irene? Trt oy Bw 4 aden, mate em mae et ster vB —— [ee 5 bal fe mrhenytak an com eed on [rep RRR fol Sn beer a 7 ver. Eo EA SA ny oe & wom, sve J Te ES: Ri Ou. 3 sn sears oh Sli pp eTRE— i GE) on 10 tude rhe nd mm rr [vn decison rev ais Cer 11 ox eta th, Pn. Drbn vted eT mehr thn. | er 12. nbc 5 to th cient psn 12 roveest sete en Ein nd ! ta Pps wats vom: Crm 18 sls an cimsson ont snr, nse ie 14 rete aa en (wr 8 ot ema ear vas me 18 thet hr ee es cetots i en TE ours wet om Rn wl eet mck | oot 17 mesa sna ors st sie ort? chest trees adie rath te mart eae tim un | As: oes, eb Samia [oma 18 or Sobson Fon intense bute warmers car 20 cone te ev es Hn en 21 cos ut ht es ere name — fave rae. swoson: lowzz a 2000 SEQ Mya sk statta et fan vention an 26 crient yore coma reve to re er 24 odo st 2000 A ———— | Eola, LeAGSH ION aul oN pS ost . iS Sa ia a1 mnie: Guy. Sass 0m, enn 1 0. Ande Rater vsciahec re wed jon fevmegeents wram—————re. Ten 2 oni fb he eas Coin pon-B A [aA ve 4 [HPSEIVUIRTPRORI Ii Jo nr § ssavhomsdsrn, Tht Kabob nn 8 A Soleo thie th eh Trenstrying x 6 vere mvt awe drs, Ln 6 to spend nis seer othe vio, abot we Po Tae 7 aackigipetatind ok sami sorarim chm eB come nts Or cova 1 Tuva Banden that i continuing on Unt va erates lowe B erathn ror aa pemiesdrancas Lars. 8 by le anorcement abou 2008 an 206. wien d0 maton ron sam ber sea pn PA —— HEEL] resyunze 10 Lisl excent, A Les 3 vei. wean 1 doing in 2004, unbess ¥ have son significant wiidenos a “i SS Sone Vora 12k fen am we io a 10 3003, Po wre 3 3004, 000, 1999.1 thi 5 csanabl to concude FH ira 10 10 he sa sr of rte mci a a on ats A me one 15. tae, Dawts Qo amen you 16 Sas if you Ant wf jou want mao ok Cow? A we an TT 1 0 «tll Sn oth ctl xganistion. pg SAI aie TB wa can tnt. Bt thc that samen in 208 Loa t0 A ean mavsaan. io 18 cso tie ging on ants me 0 onclod thi HS Rw sn 20 gronmbly the sar vi ein on thes fair Cok 21 ceri 63, S015 wk bdr esr, [nen 20 onmtion 001. iz A ola WBE QS Soba tev aos arat mm WOR We renee. rw | wun 3 wan uns an oat sp ds sr ee, CB besa shmt rs osketn, hasnt on TR whens even ee of tvs okt P+ A — as 25 Denheit ie. To Com aEpoSTIORGITONS FUE CON SOLON sae Fo ORE Ea war 1 A mee — arson. see eet me orm : A ee — ow 2 ate assess hat yrs vine 3 boa seers es 0, 210, 52 cin 3 three os comton. H ws 4 To Van eed ag se 23 £5 oom 4 a sna nan, ser 5 mits of P40 opt 202 hen 8 [pp — ee 8 A Taarecyme. routsnae jeu 8 [Ep —— oe 7 pola 2c conc of Ba common achama ra plan, 3nd vo 7 BYVL SUENE JU So ——— [Or SR ———— is 9 buluanen people oe somebndy becom, rou knw more | sav Vr, Kkgedy ean a20u clan Te ss ves 15. axcouieder ov este wih cai TheDrake re CHIR be 88, eve 11 gant. Sma, WF varvan og ts te sian TH 15 mt nr Pr dvr 12 crcumsoetat eve 02000 teres sn SURIEOn | un TE vate rater veo str dr a? +e 13. which you kn Derbi eis mas wun TS Anthems ot thscens, C18 Gers Wt vowhacuse Tn big a 18. achat. forts A aor ads Qwest ks eh ram Tan 16 QL atte mont custionts ss mae 16 or tc mat Bona ru vals Bs is: ses i [Pin Ee, oe 7 octet ites a aves east H core 18. tance ante she mane ves ce MO al — en 18 og pt rs 15. tog Tru Ho wars enchant wat cm + A a eum or mars on srr ren 2m pt SCORES cs, ca, THE [vas 21 Eos ores etn Sef are: es foam 22 recs hoe woe dot cto vs con 22 Fncn el = sere pers oh tev. H eZ at obs dhe het res 23 mt tn ke ata, Vs, To i leaws fc of nine cing fan 28 wma ngs toc kom 1 + ving 3. [ram arate sits bem es Hivos, on 28 Gastar tr Kove, TeioRY, 256 we ale OREO TON SULTS Counc sesso so. mins JOY i cw wT = wor 1 secnimb sens rade, § {ome 1 dnb foes 95: Heibes wr 2 comin of Ste on we I bende 128 ch anny ta 00 ng SURES ly Ene cn. Lian 3 So gman ae, fos 3 ey coNTRG — 1 Swi memoria on 4 seem pi er vo sre eta pg [p——— vw 5 dante 0, ue ie WotR chm crows Wyte [wan BA. Sued. aan tht soumdewguily dra Tas cangetng woe me cre ota J SY wei 8 a vane Lx 8 oe ped much ston ton this coe. -s Plea wn 8B Geen ddnena, ape wr 10 Sm Se, Sr 10 md 0 0, 1 mb — 7. 60H — the censor aia 1 hv nd oF chr Fm HS i wma i 11 sto Sh ve cnn os 43 sw sears sare Jos ri —— ae 44 i sn tas sat os 14 ALT: 0 9 pH Jepson J A Ay Wath saps art even Te ats, lh etter wn 11 [EAS py hi TESS ge a i pg Sa wis t8 cormt runes tase, 0. tt csmmeaston rr 18 ees he amet Fas 1 nee 20 SP here's end neous. ww 20 RYN. SHPSOA: ! wt “R.SEA0LA. yi ane dt ET i won 22 saan evil a ewe st evens ion 22 clei ho seb Pe ooo | wes 23 1 yn wnt a Rul and Garret arom, IE3 1200 23 wished rden, <n be ws okt ox saving Unt 321 as i Trl teeta ete er, ea 28 <p ect we a mesures | nn J a 28 Tac son soca H Fou EPPO TON SONS Sou BLES oN SoLUONS i 30 We) 4) 1 4) 1 TET To TA ETE Eo £ ont Ih miei [re ¥ wei, [va 4 ring on Ot motto a sented ew 4 omni erent es te ; bn Rserimemephipinnnsc lil ol a en ha TRIER | J Sui tupubminiinfeb me Wot Si — i ats pwa—— [rn a apartrveorman: we 13 sbwoet 3a mug 321 35 Mysse,” az ta that re. ana 13 A. Factust. Wall, there are — thers are -- wie marine nly — pis ne BE URS el De mms cet shin mesh, Taare ete pt Sis we — m— + Todt Sit ren TRI ese rat ian | SOU KE UEFORITION SOLUTIONS SURE DEFOSITICN SOLUTIONS i pros ens } 5 a red wd ows 8 TE nT 3 Gg Bo EO, Yor wave 8 hast ta, ! Ct mie we STs hs be ots ! tt a wearisome Ie. i enter 15. hot do vou man by “sn Tine adenine [no 15 pm oat 18 seek sms i arenes rab ia ih [tn 18 EI psi Eula or pam wi Bsssinsmiion nave UIE wat JEEP ES ros nro. s— rt AY vn i anper to vee sects matt edt ot veo iis Re i TR eR ve Sora ot nee 23 mart vee tt ee nds rend 0m 25 A rei fw notion [cua 25 tea my sin Sr Var EE TE 252 a8 re To: 100 wits 1 GER Aas ro Tk mar: Werabak ovis fen 3 irre ever 5 BY NR. SINPSOT four Qa canasol of raced; Is He reer? pete Wp ev 8B Toate thats my recast open. on 7 Math man St avarbmenenotion fun 7 yooh i sR po a A watt Ban em conmaeton Ter 1 de been ress. S12 A Glen Wikre the VR con tats | wan 12 Ghent ley et sen, 80 rk em 3. proven ma on har. Weve (oh at | 1s 13. re 3 tr on ei, ot 0 18 cass, 1 tha a smear your quiatlon Bot ducta [oun 18 A. Cowreet | fora ¥8 contrat ssuaions aes ve cn tmescd wren [1 18 @ bos al methane | 61 16 me by Jefivey Epstein, in the course of negotisting aie 16 thai ol oun of hose cases, you -eseives 2 asl lene 17 those cases, I'm not permitted to answer (hat question. [a 22217 fin? lente To Seis Woe sco ents A Tk thet cet se queen on13 xn asec me com an owe 8. aston sonst og werner soe. ; a J nts Broan H en 22 alhigatins dil ne wie onier, won 22 Ac just want Lo. i ns va Shs zm ESAS, ie sry robe 38 we comers amen nen rr J AY ESE SHGSMON SOUUTONS en IAC = = wen 1 cate on Bonin, te Gl om es ae 1 PTT ——— 3A Tm sem, 2 t understand. fae 3G Om. trator ets i To AK SCRA: Tot <tc mi foun 7 Qo the cerdsatianty ise. wun 7 sttzmeyiciart sraleged matters, The bens = on 8 Smeets To ® STON, Yee ti 103 re 10 A. Connsat of record? [p—" KP SCARULA: Tamms ere [ore #1 @ aay, vo nh rT arm————— iene 12 thet, souren or rez. an 12 tact he mot tz aevwer. tA Toetevethes. an [i wn 18. You seseon carvn ume apn Syme 16 G Tncaintotbom bur cas tthe wn 16 ceunee a recent 1 cosas ing armen a3 Mr Lan ses 16 seen casovee, ars 15a representing ey Sher sivas 18 A Tele there's me ther cms shin | wn 18 hey us snd Fr ——ly Wish ra Toad © B seanat ming am [ER enh Tem renwetnstoedecimend, [mao uted streets ve remem ists Cine 22 Thisis an sppeaximate best recollection. ex 22 Virgivie Reberts tet 20d U3 deerie privileyad. za aan Cann arcmin wnBQ Toman oom or im EETURE CERO SOLUTIONS esau oeros mon o.urons JE asus i 26 ES or 1 manson oir 1 A eon i bs een mt thE ee i 7 Vemma fa 7 vases th wait org § A Ge foment =k nt becad am, © eB cet es it ty Be a nv in ER a ——————r—ret oan 1D matt nt es, at tn pir Ein i set J— — Th —— ! ete ors rt 18. rode esentutl vn oats weaves JS S——— nd warren ewes an am is niin rm 21 A aa Korman Tot = iO RA p— rom 3% htm sowie emp yawn Sori im am ever 3%. warn ademiese Ememowears dare Feshe or $3 A vk No SALAM GREE aan 20 wa rerio bases toon panel ore (ow 25 sori. ea vv mast tome sh | wos 36. aan, tht a aoe foe Sion person some, prion seg ee pling = £2] oe 3 sian rs hr a oe 3 smart wire net event evs 4 a abr ren was sh venir ve in 5A trae mado or 5 eur whens wi come rv sae [ne & Em———8 20 6 com bt tt be te vt ee {ore 7 ert. vs 7 atomic aditenes, Te en i eve 8 pit, ah. ran kn mas foorr 3 soveswetesapenmns amos? rer 8 ou uain a e mty t yc iow, Tle Tweamespeese ve 11 somsanty, vox know, or vou Ko, eh rvs sho formes 12 spacabithe, xnav res nevons shout 4212.31. yo vow moved wey to map Eppa an {Gain 13 to fru ame Cott con mami © evn 10 seta orcas on euros aes 14 beech she vo ks wher, hive | rv 14. ri Enos te, sk sop aro [ar 16 cod sumo tov ot. arse hr | 17075 amnion oan | rec 18 Su om sv, sot th i ge hc [3 16. 10u Ke sr rl ot ese Jom 17 ote soe semis eet, vot een 17 dt cae hi as oie 8. ao be semi hn, ou gon hor 8 cin ron, 1 pute Ratwoty era 20 © Thats rales ve. ! past Sp ahybbicronis tsi PUR I aR hese ua cea 24 cht mil cham (31 Povey Jared sins: JW 130014 28 pecsar wits the clloats? dad If i fever as ] LEOURE UekOINGH BASTION SOLE CEOS ON SOLITONS y prey . om | 250 fi E23 ont A ven sve 4 Goma bean sone din eben | mn 2D tosis parm cunte set ie 2 soshadne, es evo abl of Virgie kit foe 3 A sodmeaothetovn, on 3 cis con, med ren ere ww 4 satan asa he ie sh ei @ Ses Aen svt ow re ced PL iis vn SA youve ling shot dec ategatin, | pr Ba Bp — 4 Po ir 7 wept el sts Lome 8 A oun Fes coumed of raed om crm 8 hae vomit oe ffs [irae 3 three otha. Sou hova ts Smaak, $400k [rrr 8 Deenrbos ov, 306,958 tl sn semamR ch a 10 wen coupe ot esto he totem rn, hated [oo 1D. te ers st sepse uty, reer x 11 tamara crs, Chive, Smt wrt po Mein [ara 71 Au Pole srort, te four ns mi qarretng 12 acon, re 12 ubbic. OFamrmms aren su open Bh ne 13 Q. Oley. Tama ask pou Fa ares, bt In Fe. Teron 13 that, thers cortatnly wou 158 boon» we wold Cor th for cams, rs ot rc ems anbclots there vd ave en put, sbzoksch was 45 A. Oly. Sothe-- the — San 18 Q. Ard tefors Gece zr 20 of 2014, 10 Ure bet. 16 Gti beers om ter end an TB brent, se owt rere ht, 0 pop SA Journ 17 tbe vhs ot bs was lsat C18 A, Wal a he tse tk wa ied on wore TB toe paseaty hot Ard sen En Ci 18 was anew to its Si. Tere ts A ume wa 20 nS resrday. That wae the ne Gos camin | um 20 ns. Ac: ng coma ot “res 21 ore Get infor oan re, a2 dn fice ot moe oz eres we come dm, 10-1 pote pre I | C2 dent th lant a EW. nL. mB nme dn, J 2G mathe eter 24 [rp a d5 A Thafoarihore bee hei. ST rete bebe mE nero 0 U-S [rot | priiy sys = = wan 1 ann th et Id vs, Wik nay be wih 4 Fp —" ios 2 rena sbactias. Fret mast, HA SE EO reeg QE i 4 e———— fo § SAS to Peay een, | sR ve ee wm sms i 8 -mwehass aun tecsnber ma wr 8G Wynton: omer ke vw 7 20, ukerae Baran Pen neon acnl wes | 7 enn ett ste are eg a Er rin 8 add, sl, i se cis oh i? on SR Aen eb tc wot mrton, [un 8 A. Ket posonstr, TAO Yen mean, “sii wa cou sate, a, 206, [nc 10 Q. os vo var atm. ctr vi 18 1 mc hot se va ing saa omavon [seme 11 saree ore sry havent rte aca 12 stot empath tert ot tis cit sce, Lars 12 Gest Pr. bee rome et ve bod rer 13 coh there wore ig nb of ie or 18. aan cada ings rv ese {onr18 inert yer eds A Wal hao aan, Ee hati | DINED OA — 15 urs moto react in 3068. There sa oe 16. onntontiomnts set ube (15 acpi est e203, The ws ccm [ama t7 A all when youso “mominaenaafthe nar 7 ahnamel conrsimbaa int with for vrei [ivan 18. thio you ot 0 dorsi sth evs re fevers 18. mares sits have plac ui te pron of from 18 alrondy in 1h cate, Both Prine Andra aed Akan. fuss 18 Jom cy Epctain and ungeraged girs. It clot than go. [ian 20 cermonsts. Wa has entog discovery reqests or eas 20 cn tw, nd vou were commiting sexu shu of them, kc 21 tomtom south ofthe Sn hen ou my “aang |< 21 out mid rmmrovs when hams te, Jam 22 tam vmab,Wey eee sirentymmelin ere. xr 22 od Ek rooms fe mac ot {awa s ows wosk re dod ogi hover 3. 1ht on, rv Su ht ln ad [ren 28 roctnt cations station? Sue {17a 28 th hot at ric the pass of vc, fora 6 an cont mn nr, te rae 25 man ink Profeses Deron yey, | CORE DCPOSMON SOLOS | CEBU NEPoaTON SOURS | IT" SS SS =. NA ETE rer EC esau 1 NSIT youre tn the prescios of a convichd six ere 1 HL STMISON. (im Sears. Vous mae righ, Sore 2 weer i—tti [oy Joan 3 veswatarmesttestons or eote, sommes foe 3 scm mm eninnes | Jaen © wepmeshs, mares ton sss wr ees sro iat penn be ; To a na i SON A ol we 8 yeu, youre, ee asus of ergavig n comin Finns i Dashes deed Asst 23°, 034, (oe mend aes $0 piso Loom 18 sxe sors = oll, 7 pany 0 com the whe: o_o soso th atunciie [rent op oe 12 lr swans. Dusen aes. mala [von 12 [r— on 13 serach, dom ove wha. rn 1 J g—— SAA wa ed ois mtmattaimpuapseote namic iA ona 16. mitra names fe Sc mest | 16 chad avn shen vn ena? ata trea: mareareempomstom ron eros ! nT a — } Tn Sn wi—————— rs evi | ew 0 acres. tan oS ren vd oatatme——— lana 22 surrounding context. ns 22 that you Fave pe sonal sozemed Fray Laster jp erent than th. (of pment —— i pA pros be a vn fi RX H 28 H Ed TE ————— TY — fr 3 avn lems a jon 8 8 weeks, wn 7 A. 1 baliau that's iy reeotioation. Numa ous oer 7 A Great Thanks. Okay. J Fiemme tnandivsn pull Wl Gn ide pre 2X28 tse sl, mod sane ey | eon 3 ec uot esd eee oe 1D. Semin ho wa comic fom inp nina | + 10 arin eb ore). ate Tet rs m—————— Litt sem TR tata i A pi vrais tm et seen ita, | on 13 7. SH AW wet tt mes mt som reer et HER Gr S218 rected wen vin ston fret sone me [son 15 A. Smatiot don te rn eh ah eat r—Tra— re a—————— LITE menmessmnin cue ot emer tess | oon 17 at, Tek wht vet, tan shes pi nit ses ro oT nesta | EE rvs 20 We Torso in Ph, Sevola, Asus 8h, 30, ll rt ™ a ow nat Sri —— | an A oe ret RR usm Tt eerste ematm hen # | Fe — — carmiasn py Ss TR ERR re 1 bo, ese co - [Te —— vm 2 Gmenentor sme ree i Se pr Ss jon 3 mam mim a m— pA NER TS — Veen § snde nd mbrege ars eon § svn a Buta ystor po ov £20k rin 6 That coum out ats ye ne 8 bere me ern ont 10 Sow cao 33 ree [ae J a FE i Be a on 8 Ae 3 ik thai TS akbar b en a0 Q sragaanet on Tn 8 ooy cee sor, mato SE DSTI Sy Sumer —— weit rem. co 12 sho yea, were’ tr ann tr sng owinsses | vies 12 race oe mbar si Hare 13 apo eer ihe A forts TG tein us amiss eats ona scene ose - orogens i Tonk A8 pram Tip wetins omsetetins Toc wou reds omg oreng pasate stipes tor 2 can 16. mrs sams sms eon he eso cviets tov ome coved reac m PORE-uinpurisioi Aa SSP i A ream 18 Catone th ces i ote he, 18 ea a ings ve ig eg ; aa 18 la sf ins coma ns ens mse son H 20 a an20 Qn, tr, ee ro } FE [Ne i ium 22 potenti cious wis tin and han hertore [ani 22 rin eas abort fy rh 0 fore 23. reacaabevs pot ecto re 38. oct araget mis ov Fo 26 Lito detour omen, 1 [oan26 A Const [ime 25 he shout 20 cons. somatvsere | CBE OTToS TON sou | [Ec —— LI LE A JE i wm El foes 1 © wal mm acon smi, arr 1 var be in i a od sr wan 2 Ah ah, Fp ae ans th GES, Loew 2 ain 3 UR SCHRA Tm. Teaml e 3 A thor warts do rot oper here, bt come Tie 4 oman gas, Sr fain & an = nem he in hcp fi Tro 8 dete meio erro, [im ate when somabody dn ks adaption sent a [Er — Td — [Oia A —— waa 8 WR SIEPSON: me fsa B talking sbout sexual shuse of children. pe J a JS bg S—y Tw 10 sk sh. And dn nt ake tk Tn [ETRE REN TRE MOS ————— ate ano, nt ayes nan Li 12 youl, here ton econ ama aes res, Vint? oon Lene 13 heehee poe en. nt oy ha RS me 16 tn ams ac ts ed oe PARSE Hore si sn oon t6 azn. atl ince vey da: seme. oa #1 well Fm thors tote vou. Tm te 18 becuse snare an cod [uss 8 Vt oaevnd tht ony wevkd by thet er War 19 comm meses aren von sb he 7 19 dort on cto fl yo gun a Tv 20 tain mit acy. Xeon om on. Te ra rs no mars PE I Ee sh Bamana an pe vas vt 22 inavanette. eevee Co i it mB rate meet tote th 3e THE meri —" Treat A olay. Tomer mec — i a2 dsc oot owas som umm Sou [reperssyinpe— sams tia am EEC RT Ta PS ™ ere 1 A Iowckamrvmonmscemmoostt [aro 1 weceimim smeites vers dong. And be hough thot wre 2 of a county wn reared soap to repatine [con 2 a, Doahowt woud hve fram ante ig 0 fire 3 sont shure of cntarn, ved somebody wiz ats [ces 3 colette, {rare 8 yout your chbersbtions of Convicted ses lerler | cars 4 [RS re — [ire 5 om udoraas ge. ht Loc gnats bana Se +11 haart nas cred 2a ts ey repost Cure 6 sublet hats goo to Be cus, yes. Faves 6 ssoundti,Dasbowt Mech, guess whe the rbinct PER (acu 7 that that i, Sart marvin ee ping wn 8 ees. 42th tess 2 he ta us ener oxi B exloce, Wut Wi. Basement Ut opportunity. J Sa fran BR AM. Come. hac, 8 355m on 11 etc ot sence. se 241, tt vs, fret A come oi 12 sae, 381 veo eg var TAR TZ 0 selsakan, anes ant ny G1 A. Wel fn tin in whet ort? You on TD le tr BO, 13 co uk eee 46 mom. i fe tics hat ket gto 1 90 aa 14. Sty mvc ana £0 earn Jp Car 15 A. Wocout tnt, and the kta mrs oe 16 [REET — nc 16 we ace nc ging 2k yor shout amy ormmicaons We “ox 11 shone they arn otc vou know — £m ih | ct 17a eg to ack yo shou obsllnt fsx ab Som AB. that puts you or etch tat there wr sci ee 18. cock sex ofandar, anit ov pesos! made af “hea 19 AMeitloa o0k ud 1 oda ne ous SOR RESR | ec 19S. Tas wou ot hove rasa im and ZI 20 you naa dane anthng 22 shove ui, ainda in 20 si Scam very ead olor, sd Tears It Cov. 28 asaouton, ot 2 acts come cut so tt evesbogy | a 21 is auton: thet we th nt cop of gaan | a Ey ees T2 fv nvr sy Tums n iasrvation soot | nn BG naga sane sein ore Com 23 wnat ts cent argc ion wa do. i er Bh Sr sien Per cs Pn ng S20 @ tntammerota os tht vor ves: | Sone 25. corner abet aE a 8 5 Tra 78 me saree, onl AER, 21, CQ: DPSS TN SUITES Fae GEPOSIIIN ENON H eer ee BED maar san E- = Fa wat A ve wr 1 ests, tn Seo, ants i ZO Abr aaa [au 2 tres tons scases or og snc anan de i Sims 3 ces, sv aan ot tr — PDR —— cx 8 A Wan wn argon ovr ge. 1 tnt pt wo 5 saul xb, su ve, vt, ut sie sue? eon 5 Ninentit nota tit tarewre ress westons. | oe 8A ayn rev 6 Seingrsons shout wht he knew she th rit pa SEAVER: SSG [an 7 orpmastion, whe the potential cmv rine | ob cena win § befor ns 0 rept mel hn 13 cl, 56 9 PATER RRP—— vm 8 nll tht sushi. i i ue 10 Vs, tmome wanes J watt vrais, i ES Sh A va 12. v1 ain cri 13 A Itaaveyseomcoums age Thats [nactd GQ wastinoci anassm sac i wt 18. why reser roger, eae 18. iene, esr on, een, rt 50. Oka. Ade Femi nS Me ane Ea cn pee tre st i Sen 16 serene on ta tc I nc 2 ERSTE aia 16. essence snamraunens. i il Sogn ttn ata. aaa 17 A Agen tas nen urton, Te i rn 8 ce, ose rm ttt cn 18 1asivn thn bm roe Eom. Tost wascinsityn | Con 18 A. hate speruetive msi bac at | 4213 potas arcs f quectioing. Tt tot puizman | emia 20 later vans designed ba Gry ba collect infnimation about. 35020 netics that it would have ben in his best interast to. i “on 2 an motors sox Gaming vgancaten, Anse | xu 21 angen anaes thas cursors. fren 2 528 you Row Tm ot gong te spscate se tony [wn 22 EN [cory ne oe ROT —— I Dot Se Sim 24 the pub sri tt be wen yin In 36 ah |e 28 RY IUESON { ru 25 inform cho could abt whet Icy Epi 308 [wen 25 QV arco sre are { eons ION 5010 sau Dero Sa mions { PEE ssn era] Soe [CE weit iE BE - Toen 1 Sos ht ell pu. ars on Fs cass 1 soto somes? Con pe srs: Tos vr? fan 2 pois tet a's scuned of be sex fencer ae 2 A No. think a yearn newer would be “on 3 nen cs 3 misiading, ven the concent of is cave furre 4 Wh scams: Checien. Rept. 13 ev 8 Q sour yr scr vem G8 tectum a impreups then, [ee § ke tistoramomere. | fone 8 on pro can hess, if euca re 8 fared ur see errr en | [nav 7 dieses de sop ines Ti Tene bet aren ce regen —e TARTS Tse [ER Ser — rn 8 canon, Darran espa. fon 8 A teertomc. “as 10 G01 sturgOn: [eed Q or ar ped pink ax QL Leila eons 11 vs is Henle wares oi i wT A to yom melon, maz Doo sc me bg ears ta serf3 Qasr ee quosin an 15. moming a 3 tts en putes ste woe MA dom onek tsa yesor no qeston | so 4 ptr shoves ere! 510218 becouse of - of you's including veg tr be ee | won 15 HE. ScCHIREY: Oh, iar, Kova, © Con 16 otis and = and tho sorts of hime, So bute | num 16 oleic lo heen ony ent k oc 17 cad one nek or GUERIN and FI Tein, 60 | vom 17 GRC SMI FC 0 ar en A “en 18 shes. etd poe ws 18 © eure fre eid ke? cca 19 wv son: ced A Ram. Sed Q Okey, mei eal a wen21 Qu Aur Spang Cone fal? com 2l A. Yea, J oval the objection, 1 ink wen A ver an 2 thas so atic that came out poses or 5 Gea Grats sw solt 23 communication, 1-1 you know, 1 cont remember 2 Ave 24 te cuncly where knew tht seceived uoZ8 Qn Renda as reachg engine ot is coe 25 carumuricato, oar reougi pbiction on sore ERAN DEFOGION SGV IONS SHORE DFO IG 5 ION. i (2043 1 2400 50 sv adis : = vr cn 1 let our opinion, ds rs gang eck pt ov 1 mor way tram the — from the — ya new, became fons 2 tract on nee thse ren sca A uns 2 ware dha thers was a stamens he the what he Ton 3 ating iors inser? air 3 ewe of the oi 0 the Business voor = [rer dA Wpwshimonnotke tat tatisgeingte nan & HL SEARO Daly irs 2c. : won 5 bes potential bjectot inqiey atthe — tthe — uo § 12 WOTACSS: oly Smee tt mas | on 6 he deposition fon 8 soto Cod bo assy rte | {win TQ Soyo wsnerthen, us. patie [ot 7 resend neck by W. Dasa ce i em 8 Une he parson pce: yt ag? fons 8 an, on 8A Youre Thnk yon WM WOrds my coon HI. SEARO 1S oe oe ns ac 10 men Youre — youre ying to ack yeuknow,s {oun 10 apdogie. war 11 question that enh one hand you's suppestionis | ce. 11 12 VEIRESS: Yeah. ded, Emacs, oor ne 12. narra and on te other oad fo broad. Ti~Tmean, [rons 12 Ube rare a le, so. BE on 18 question. [oaite @ angyen on yun coir cman, voc wo 15 502m goren nat cto, Kola bave | se 15. “Hem ts my tr th mar, ra 16 aid, schedule te deposition in th nest 24 ours, amd | 18 eed 36 are Gr 17 chon on dora ere now, amd Till aeaible fora [ons AT A Thats igh. room 18 tek, Thar what woud hae dE bod gota [wee 18 Qu peat a1 totter, rn1 A Tesesigat mts theone we see iking po WA SHUTS: Me task 20 tev ae. wn? morose ConZi DL Rol Adin esde sans: won 22 GYM. SiS nant A BH ren 28 tne vc, a, pot tr pert Cai2 ing been to mors ct Us JO Je ——— in hhh Seon ere exresly prised LSQURE SEPOSTION SOLUTIONS ESQUIRE DEPOSITION SOLITIONS. wens [ry FE — -_— [pa p—— ve 2 ae rime, dese shat we ey 2 rpm ae 3 said. llewesenr, (fr. Soles dues rane that een 3 HS. CCAWLEY: Whe cisaaree with i foe 4H Dosen ttn orbit a i [am €or sharin ofUs £52 eee, © [Dt cin 5 kes men To os ncn maces van § A Thacataons en & he otvers ot ie. Boson wareng ts foe TQ Tran ee 7 copie, stv ett a hates i mr 8 A Yeh A-Tiamedeff-ymn Edt woe 8 varsrantme slot shovsre asin H Suen © remember whether I eador bow got but yesh, |r § tsp Voie oma picotins. i {mew 1D hats the ona, fount MR, SIPSON: GRTy. 1 disagrees with tie fon MQ i ors mses by, ans, tonal poco sth charms, bu et PH EAN An TE ih SE A Tween for 1B ahve wastes si, aos [ponent wr sanans gu JD I —— en 18 [Rape PC TT ets [rape p—— Sra 17 hats starr cai «ssrent suet by in TT ht baat vee baer Bd sin 18s Wane ad tte es ai, San th sendy been oled. eter Zi i 1B, Daren spt ot m3 5151 sua dS atopntor hac bce wan, wEnE ri 20 re, somars un sotereat y Rk ag rm ed ein 2152, Core tmnt 2 zr 5° eer Jp — on 22 evo it pe HSN. Le ave a eto, SZ A Mo, And thet would rire Fsth =| vi 23 TRS: Ci 3 3k ne 4 Ti Jus puting vou on notes, king about naten, [ceva 24m 3 ote, nce te rent hashese SS You war Sy Leo ion Tater pterses | eva 28 chara, bane vectors ‘ESQUIRE DEPOSITION SOLUTIONS ESOURE DEPOSI SOLON #9 1-0 IT SR—G— » = Sica 1 amen ns 0 vy thts mot svar, OF the spofmy | 1 Uh end, 4 5: dont ne 1 Dt in 2 oud Te SE lim WOR 1 ven 3 naman ma nama rosin | wen 3B Me dented goat aman thar. ove 3 confderza setierent prozssegs, have H bead A GRE Thatswhyikmumaidtoletyen [neo § somebody da vat sud toy, de, Sevrers von 5 oso, iva 5 ge cotter seb procctage, con GST oanacte ony snd wat oe 8 rae | [RE on 3 SISO: ths ro bon bend. © © wn 8A Tdanot—tetme just be cea zoths Can 8 move mit ce sommes : cre 3 recondizclan, Aabuoluely da not belive thatsa [sewn § TE WITNESS: Rul. yadda ve core 10 iver an 1 oud give you an exon swe tT [reco 10 Comms 0. Arc hack coun i car 11 Jaw tie 1 dvi short = PU 1 va sem ra 12 wre suarson A se ON RS pT BS YR vc 16. paladas rot. Tod od so st oe cv 15 tang aL sem, yl oi 0 re 15. rors yest a ssl Ev ama: soln act 18 se ty autos 3 os sean. of ran 16. th ind maton, at ah hve en unk of 117 tens win, foes sen tng et hi Rin eve 18 anes youre cman casts A Gai na 19 Sm va cent GO ojos dtm entero a 38 Pp pry — oem A tan ana we vecumer, thos A H oan 22 VR. SLARGLA: = contin 18 1 Sasvar. rove 22 it = if you nid Wann 2 aos = Ssttom of pave 3, i — v6. SCL mar. nt 28 pari ori ee: 0 on Fae Bt? H in 20 SOW: Ym. ant A oan pe VL SCHL: Corin sat sans. anZ5 GQ arch manag sd hme H ESN PINON S01 CS CSUR CoS TON SOULTIONS i priv, [ i Ft TEE Fe —————— wwe 1 eed ems. cist 1 spe words. They oth have hs som phystat soar | cox 2 A oman cae 2 vo speak the Enis argues os. sum 3 O “Enso sonal rain e fans 30 avi teas bere, st hme yews Sow 4 tn: Jane Doc and aS Wi bats, Toe bo once Sm, 23:2, Sh hod te bs Ces oma fom 5 cated man amis, math sn arte, the BA ven (con Baty adie Libr shu bor epee cove ine TR sens he aisle for te wie TA Tatsconea. ame B pobclicometed sod a caly-avtiel boss me BQ sadam cove hs x of heember S00, oie 8 FRE Duress na FAG C08 FOr MINCE | iss © 2015, fou dt kao Ahern wage ar hl Be FT tr) Po emi 12 frac ain, 4 well oats terial ach 12 A Octane SA, 701404 Races Jeera —" J hp pe fp — vine 14 memati, ne i ns? 1S A vue. iw 1 A. Ohew, Which -- veo Tmeon, na genet rv on 16 ane, coud ask vich liogatons, hu ts nt 17 Shh fomaton’? we 17 allcgations gone putty, coin. wn d0 A Ok Lane sk doubh-chock, cnn 13. Yer Ta stcqmions in your er rt ve 18 Onc the crimina organization had putthe | ee 9 hat pine Aire nd profs Drs ed aise 20. bit ou, 20 se to various people ad they took | 415 20. ait bets, Ue ace J em, ns 21 the it hat you Know, Yen — 11m speaking Ss 24 gah 2 Pim of OMERY; CRE? 0 22. cobauilly are. Theos are — thas are yong girs | cu ZZ A. Itgocsted nto or push yeu rect 25 Wo eng Seva buted. Once the minal | 23 Gand wth der dk ou mr re i138. organization nay gore peuple a sexvally buss | rvs 24 parca aut serge an rion wh | (ice 26 hese — thse young il a he pi, they had | 26 45 News, Av na i ES3URE DERCENON SOLITONS FSUUIRE OEROSIHIGN SCLITIONS i amie sa 53: aa i 3 Eg cu 1 inforraton Ot they cou uo 10 MAUR [om TA. That within aay of — the chronology is ur 2 pape nd nd them et avons bn exchange. oi 2 important heres The sllpatons wero lean tio | oe # na thats Epstein a ne hed af the sri 3 pleading on Decumbor 3001, Sevors ays smev tat, | us 4 ornicstion would be the one wht would bene ast | cry 4 Kr, Dorshowi 1h fork 0 ne itvaves te denounce, | an 8 Geely om th back hs Dk rian. |e. $n only Brad 0d me but but prtclaly of cancer wn § GQ nd by Diack vomzson, oyu mein | owes § So me eas Virginia Robart, this viet of sex ne 7 hove mn md nem ha Fs ot oe 7 wltickins. me 8 dusean odode th wher psn STL da lt oo 8 A, 51058 pos, 5 one 1 smear FE xe 5 ner storeys, 1 wos oaktng tora vay tn respond ta | wa t0 A Pree. err 10 thst mess saci on er by. echo. i ord] asorbesse San 00 Hw Rebans | ane 1 Hh. SFO: Hove ostibe as es 12 diz pbc, oh ns casey esr cro t2 pomesansue. i ria 13 stir te lke bcp; rt hat te? a3 vem. soon: ! wath A Awake not ABMiomsce es fae more [wun td OG ten 4 be ois eninge cum 15 aon than iti of ht sx shuse, parteany |< 1 16, har ns pubs abou nc luis ain: vt 16. ons tha hos cen enced ota ming in Avett to [vec 18 rive ni and 1, Crhnic Froksol i 17 escape the criminal mania. cv 17 Dorsontz; on rt ome? i re 18 0 or yas te mes he Vina Roberts [xn 18 A. Kars enew tne xt me ame het 7219. had he Sain oA LO bacon Somebody 54 Jetey |v 13 Bho yo nw, roughly hate frame seus shout na 20. Emon Tine prepastorows. Co 20 rie ee ee an 21 Ohne Dahon | rn 22. sbi a fey Cor ors icy te anes cam 22 sac nog, mot yo mes et oes AL 20 thera woes scaly dont, E06 |e 23 Shopens ss rc Anca, in gaurd a 24. Eps i dk ue? ec 24. roe ese lds stants publi? TenZS A Your tolang smack physicst ay on28 A Toere was there wes } OUT DROSITION SOLITICHS ‘SoU DEFGSIION SOLLTONS 50 ra sa 14420 TE CET S1riinm E23 = 0 —_ PRR AC (RET ——— rw 2 autos te sozcon Saxo ituppuaie is priming RS pit — I | ass 4 of mel when ve Med thes dscument. uta 4 yore. i pry TEWITIESS: Tomes vo det ht vom 3G. Adhesions parser nea | 8 He SEARGUAS Sth isons KT on 3 Heine H va 7 tvatmetis ve 7 A mateo mwsina-whetwewere | [I ML SIMPSON: Peace «= pleas dart tech wwe 8 what we were starting to document and allege here was azn 8 the wires, ics 9 What terrible things tht Epsovin’s etiminal 1 to BENGE” 80, ok cuT Wn Ts 10 wrptztion had dons. et startet meson. Yor oan tet mare son muse. : four f2 shoei mns a tbsnzet [ocd A On H —t im HEC pr MR, SIMPSON: Lid he = «due atic date = we 14 eragrenn tt SONA Roc ete Mustor ust [nan t8 A Yep 16 NR nr ants oar ar, feces Q Emacs rene tmanan tt Sse. t,t, ey. eran 11 tikes in orbs 30 somal sess rs tt Sao mt tt wrt eax 18 ste mame” we18 rim, Sa Ener hc fants A olor yore EN ——— pp rr a ARE rata, Lue 20 sce, cet ura ss, vim areata evn 2 rite + nlbn ne nite, wt es lt i Wh SDSDL Loser 560 Fe 23 bis, Pra FT oa he TAME mew chetonta gor of tho usson. mes 28. doko on vert sve wi mms ht i {1225 x seaport ischrt em” Eo0uRE ceva ion somes | Cs2URE pomamon SouToN 950 551440) ; ET mE ET wi 1 brow spn ee 4 [TT T— mr G wae cen 2 A Yeas, 3 vi, Seascn tn a eq ra we 3G mga bekre, hesa od cot orsn amigas erie. Tors 4 Shacknews s30t 0 - Wi SURFS fe cong harms rn 8 rth ge ee oom? i 8 ByvR, sven nor poni h 7B pwn Ce ® A vb Zdewtnccdsny concing means [sis 8 A Roush, yesh, even, if theres someting Wie 3 Qtech qe, irk 8 that vou want cared, po shoud and cri to eo mar 20 thats 53 E10 Tak TRE meen] —t ore ri 11 wrormin eres wen se me to ir A me wre T2 tte eur og itr go dts hese bi ES —— vee Y8 cea 5. ne sot ear’ Saori hel ath A oumatmet crching, ThAtIEt | ak 16 pubis Ep ante kn wk Lia 15 conching, sa the eugenion hn Ks concn | use 15. VA Fast De 71 5 ut RoE ma 18 rata Chm 16 bling = erat: td hey cnt 02 wel 8 to Weds. in 17 hatha thanta de? th seo ort fn, i Sdvossmipme [1318 A. Toatwas— the wma pe of ves. ax 18 thes sein pce ein a ee i ir E19 Art a saree Gr 20 abuse i Roald wd ae subsort con 20 sccrptstcn.. mtems cr amberng Yours pega Toe 21 tases as cere, yo mele sess) en A “aubantart es caatabl word, but Yoru 22 ces ti mare th by sve Er J rn 28 Seer tite: ve ox Bort 3s zo Lv 24 macy shout th allpadons. a 24. cations ocd elke ev 2S ves pn ands chats ve ok nas A. Mo. t dont inks. Esau peoTON SCH HOURS OLPORTION SOLITIONS sn susan 1 acco ETE or TTT TT Ame a WFAN 01 08:15 7h oo 1A am wb rman fun 1 reo spores th. oi 2. tars oo Anton pein, pro x 2G he, en 3 ee esas, er esses, ero joss 3 Sh SCORE: Cod ok atk sian 4 prime mins ne a rd aes nt vs ou ey i 5 yom aster Un ere nl fon 5 eyes se rao wor BA Ye on § (nen, poset re a rd Co TO me sep ann ks IO — AR an 8 SERA Tn ene S10 A. Theta on ht ant nr 0 rr p—— EE ET N— da 1 beh shes assert, fiz a veer ase vores. Dey J SpA BR bar 13 we dagen, sr Contd A Swe. Ces. thi wes cis kel et oo earner seg Cnt ws 15 baer ly te lin hd ba Gig on st EE a ous 18. ht okt a swan ya an bt of peo were Be ee 7 towing 1. To ca 1 amo ne mt Cm ST Goat reap 6.25 mt, at, | i 18 cores exsmles of a vlouon of cme vit’ Veet sear women craoeem | JE T— Cte Cae, mi ones vam ex, H on 20 Ad a cert en tree | ce 20 Sco sack epee TL bie i a 21 yong pote oman svc ord tate | seen 2 et resale pom, SE “hn 2 ying lo oe ten, Whether wenag genes | 32 eve, ppl op, 2, amt a 23. rently or ore row ti what vn di primeira [non 23 Sara. Coxe 24. ging to bint 0 0 re 24 tes man ad mares eo rT PR Viv Oe A LOUKSDESUSHICH SOL ONS Fac ar Sep SoU 0S Br mamen 3 : = = sien 1 aeons sn bs cok ben nil DE San 2 mr uti a ey Cn cost a ww 2 aye 2 eka pres clon EN Srp pe rp —) eat 3 bea er dy 08 i! ae 4 A Shabadtneauytespcok wort uh, |p 4 sold bese henge i “ian § sai, Tits prepara hanes of | ann § RYU SOUP Siri 6 aerating has the mma par ATS |srce 6 Qi oma cart a ean : woe 7 lo haa arin. tes Teka mesons am. F's eo 551 — Fo amp, Vroins rovers coma be Op 1 wae 3 amachad, sna tink aw wer son shee OP EA Tp i Hoiet 0 vemeaan we pave ses ids hm Kido minck | 230s 10 prbotly hou ave boon more prec, They bdr | Lun TH hat sr oro con ct rid Wa tol | won 11 once Hom lv entrees wht 1 move, Tort {xn 12 afin, S10 ay Ue tha young women scx | acs 12 hen Palm Seach Poi Bratman vot ua he Eaten FONE a ———— Lt 13 marion, they fom selon cares 3d ser a sa 14 cunts Lea aver stacy vere we comess | PON S— 15 var, ny ous anvesance cameras, nd when hey fea 16 DE SOROGUSHERS Wh 4 SDE RS | aur 16. Socksa forth apes sete wth thst coma | tl wr ian [EO A | fen 8 [Lp p— rie 18 hou he ly i la, 53th re ve 10 [nese (FH SR ——— RO er M2) Q Sessa Sas 4d rer or Ar SO BO —— oi 22 Rhyne rss Cott on ZL A. hrs ram eapes svat 130 23 A Toso ar 23 anfaceranto ts Br and 1 ro Bano cm win cm? a a ace 28 mas tony coca aur care. Wewwce yi 15 FaZ5 A. Thankyou Tha yeutor tatngma lakes | soc 25 getthons and we sre contig oy tog ho Fam cAvoRTION SOLUTIONS CSGAL UERSTON Solum GS Oma Setzer dias TREE Err cin 4 bu cist, trot nabs cima socal 1 bir bs dts ] wie 2 had the ability to — 0 destroy the evidence that's rows 2 HR, SISO: Sack won wom 3 seen ates np. gi 5 two Fon 3 bars et os ers oe nT Tho hve nl cons wkd ety mrs mn 1 Tite et pemastar : os Er i pi —— th oh ; sea 11 A Yeh an 11 A. And] = mayb L should =~) sce some. 1 a —— Fil iy tA ma ju pot Siu —— tA ane or 8 5 coe, ed dr, ont Ge sar, att vor rd agin eo 18. uta eh oe do ot er 72. 84, i Ret tty rv ly ew 23 ameastti epmots we rTE at |e 23 A Tne fading th ete, wa Tia a eves vee it 38. ti ur — ur ind 1 arp fe Bee: we 3a. win atom wig oe rug ak a abegebers wire SAAS Cer HTN ons Cam (oan SH SOUTHS A vise _ OR AER — RO piu Sgn Pra —— EE row 8A hegre, Those thrive ennai he [Eran e— ea t0 Ge. te ar ce re ll i J em 111 fa ons edo, es abpstors Son12 TQ) She. ow ve erste hen 12 tf ls ec, AY A ron 14. ars en 18. a Rots cor he, ED Cor 15 A. atthe tims mth omnes — ts A ve i 18 tik oie michecaring ut arc eng bi: SP 27 17 tetra. Ha ict a to he etn [eI TLR cota rissa Winey wre een eves Tea T8 bine pom tin How Powe Wert 15 18. stare ha were esi, At ellis am ane St 20. shaman, weet th 25 Amy's Ofte at A Ase rw 31. punted Sree ems mac, fovk wets SEG Gehan thins [va Z2 you ing on ormaton rt Dora we. you v8. share sept, ao, rein 11223 Low canted wn tlt the vio woe E8 Foto tte A 21 38. cama or sult vou 0 uc toss Lies an x SOLUTIONS esau eo on Sem Ee SEE on 1 nt eter ham com ve ecm rman [sv 1 tend stats mie rs i. tin 3 spans tio, Som im Sk rrewera vith [oon 3 fo Yon, Trg than thigh sot, | [Lp Lp EA Dr 8 ericson mrt des iy ee 3 a eer ions, | nk 7 tree ast rer sans ove [reo 7 Fn tt ol Reunite 3 tain at hk cont th rato ond ei 8G. ho cr ath ss id nr 10 tn forward with th case. ovr 0 sc son tor the Soars Oizo tote —— Teac te ws of taba evn 11 eget te AP fe re ok Pr ira 12 oganane hey war rata Spt 13 {non 12 tot, ee tei a rs tn 18. meee ain eb rater sh ch moon aon, Jn 15 A, 100m kn racy what eration they EA {own 16. Frtues prsboui veesrs, hn he U2. vo TT ese ead eet hash sre [men 37. mares sea: es sn ening obeys at er 18. fem mses 8 wok whe astra th rape Son Tots mtn pots hating tnt oe 13 mtd rato a en in i Tn 20 arto str To I0 camara hes ves sr in ok ol dt Sem rm nm, [vec 2 hi eT AL wal Sow ony ox stacct mtr,|vun 23 suis trons of log snd ators Ti 28 utd on ered 0 «beans roe | 1 24 mrss a ini car, st ink Tun rome mtion, TT mas vou bow [vous 35 apport a sd sre fe mn ig 1 fre Frm em irre Poy pr oo Ee] E in 1 cna hth pies om et wwe ol [sian 3 sora samara gous. wn 2 spent svt vada mitt ment ses 2 td ety sth ree Tire 3 we bre ks Anton sr ot re eld |v Se bee 07 ed es er pf ee 5 tu pprsriete ay tr band soe pri dA Die A meter ve 8 se SG mmtemmmmmm ol SS —— von 10 tin, smb at tm, SO A170) “10 tit, ur. Ton tha the bt the ss — Coz 2 are ome mo rrr bi [ET S212 cus ue cat core of der pict Ry on 14 ct a ry a arti of ht. tly wold [ow 18 [pr — PE Grom mony [nS ns et rsa i at sr po re acon. el mht hy bd aE Poacames A canncatan with seeding Ytgation. se 17 stacpicion or vibe if == you kiow, & isakonibla Suspicion PE SE eA 10 or pnt pid Tod ar i pi J BR Sm aa ON fea ve ion. Te 20 ort ret srt et os ro, het Ceazt 0 sar, Yo mt ey ot re Lr 20 wt thor vend Mon one, con 23 vento ee re 1 ss br, 1 x 25. tht sv et, you sor a hy 2 Sach El L230 vet mann rte ova am ben ES vet me Po igi tty |i 25 doc, Nov, hey id ith ht rm, me om GR [mera ! JE oo eseman _ TEE TERE ww H oT El Tw PU pe r— vn 1 cain bolo Eh godt be shorn | brn 2G fa ahah bc Cons a 2 my ccm, to olor hat ss, and ry os men 3 Love 03h 0 ee ol, ro 95, [aan how Sean io i AR ni 3 th rte hone ppg vc + iat nov bon abet th contacts one hat JOP fe 5 rabasto hanes = 3 frets fn th tO Gnm—en—— rca © inthe Cama Victims Wihts Act at tot would hse wat 7 0, Sersbomitg, bu. 9 a5 Ua enone eve? Leven 7 wn Gavorable hu une of is fiands snd potential fang [LA Sp — lun © Tove pat. J mews: sac t Knott sme joes 8G Arde verve ba ve, ot 10 nat pore fat ma, Seca Thay Lone 10 netting Fist Ere gover end lon repssast hy it JA, Viren 11 tant wo recordar? tt WE THE: A, css {ed we 12 A They dawt— somo. ne na tesa < i hema “ina 13. nate ak sks andy Bt ma drt ta 4m srs: sae run $4. orm thi ct vat the mr ncn. Th a 15 Hep ean 15. vest wf thy sek ve document, Thy ts um we 18. natok thay hi have sn toting 1? Yo. SW 1 tah ae 17 tomseee — ten pe Tote conan: They sezerd whole on 19 avn seen oi 19 sre of prvepes mse tvs tad 0 9ek a 20 Ga memet spa tare Se 20 ifort stung hia Raa, Sth ak hst Uy oa 28 i SOU fr be ne TT ar bm ta, gad Bene Ana, av, —2 ate “iva 22 pease doth bt vou confor te omc zx Tm pm—— sara 28. offer is cna hig, Tomes th requestor cr 28 sen serson os 24 production of documenta. Sei2E GL Ath srw de aed hs rs [A SSaURE nEpOSITOSLIT CS COOH 0450S oH SOLITONS on va [I = ENG - en et, St 3 vd rs wom 1 ometin ong eb bt nee bpd ard | vie 2 senrasy ne vc dnc vg a crt en im 2 the comer wh are fend wk seein of pega | vin 3 dames tet a ca bbc dens «ree 3 ana ght, remembar omacly, shat 10400 | sac 4 artiste: ete @ Fates ot daarmonte nem whale scot sntges wars | me 5B Theriag terns ecw vion [ven 5 Suna semtete i wow 8 ecoary conus st nad em propounded Kenko § OL. Unga uns eBe Ut t | (re 7 with regard tn they ant erin, md my ceolection. | won 7 SIRS Mone orf oss cag mr AN | wc Bis with segue to another, whars thara had bein an ans 8 2 werimaror the Bitch Roa Far dy? i ners 8 sugmtionol preiege. vr 8 A ot dsc, bus thers cota re i ATT I AT —— ca 10. pecs of rogetns. 1 y — vb bu | anne 11 304d, 3 resperze te raze anca he cavemen 420 11 tht porrfud omtminty woukdo's go out at dicectty. | me 2 ee be ar dear lt crc th 2212 Wot they wont rity doy tama wet | JOS 2 13. ors thay cu rou ne drs sts ad md, | wee 4 al, EE oe ae? ass 16 you kinvow, amd some of the, you know, big-named kwyars | 15 A Thstoewnh rapa tothe yodcoting [cos 18. and try owing Shin there <r work do | ee 16 shout REP, rsa fo eodction of curr 8 [4518 That, kin, fy i Kl, ot sou | ToT mm —— ores? empronmemmieestoroetorwd | ro 8 0 Amd Cece 30h 0d koa 0h yor |e 8 Tm cing th — hat aed on hove would You i 5 18 satis soni mob, case? eve 16 are 3 ont nn Arce ciation ster? | azo A Cons ia 20 Yoo ty to et Go bt os es yeu contd nd | won 2d O prd asad ry ts elev om 21 sun you Knows you Svs, fur oo eich plc) | ri 22 at Pr Avie sore hard force 4 S22 panyvmsin paver sna y ost perpevmo sre | ws 23 aeoiaton tar WOR le Dh Ses 311 na 23 wethconnects to thot cota arty, ties Tk i 28 ti a 24 a, i own 25 A Taam nove direct evidence of tha, but es 25 So that tha vn The Think samvisody ight | SEALE SPOS ON SLITS SCARE EAROBICS i wens mwas } Fm vo a 20 6 FEET Tn) Save quan shout ivinotrlosstimsmmstrerss, or 4% nom urtiissah Hein bere miter free 2 vor plead. rn 2 Nightin, i that an AGE prosram or OC or or some PO Sl Pa — om 3 other aevmrte can 4 speci, cama? a 4 yn ok kw. hee nn [oom 5A ll your avasion sods Well how iets | cum 5 cond Le Mtr RN fhe te, Fo 2” [ee © Crayon do 01 Ana 131 gave you my newer 38 |r § 6 hace. a to ges “00 7 1 owt think somebody could vet dothat yer. loon 7 A. Yeoh, yesh yesh Thats good, Thank vou CoS Amand esd donation ane § QL SENSE. Sein he wena on ary Al Te 9 reams mak ds bee UL hey GS nun 9 2015, yo lo kof CO es Lk 1 noe 0 hate je ws. ser. She. Ema, Tou nA Dewan J Tit a wien, [im 2 SSN Ti sa ir A Welz _— THE NTHESS: Tae vo Te te SS. eEAIEY: ar, wa oly rh ts A ven. rE a. sur 1 om Lt tr sie, vB wehbe, re (ow aman, 17 econo a (= a VS. recA, Sar i Cats A Sore, Abmoutey, ome 18 ox i smpson t S18 umtopS one [won 1S Ghats Gary en uid | nD kt wh eres, Ae Seno noe 20 eo ARC ee quate: esr, sos wih [Ee rin 21 Gm Lavan 1 oth ims erin was ZA Great tleskfomard to in 22 ly sone 1 Pi Ache ad Nan Brom, —n SR SHOUT Co 0k 0% | 23 peda coe ee. oe ted ey Cn hase PEL e110, 2s A eek, LNT hens novune berg anata ahr [win 25 G. Sor share bbe em ne | Sale SEPOSTTION SOUTIONS £SRUIRE DEPOSITION SLAP IONS sn sito SATO | B co ae9 Ed wr 3 US bn sr 1 ive ABC Ses G1 rctssr Bsn BE em 3 20 tos nd eg ort arn 3 com hn mabe RE tbr rind or [arr 3A. Nou think says tot Eth eveyer who 4 dnt ior 4 a epeeting someone who ha hs da those 5 ov sso oa § angio. wen § G Lulgwesiesto tewiess, ana to DE Te 7 ny me comer ihe Ten ce test, [aes 7A on i ee 8 nthe coil yon midis Roos a wie 9 ich spar ts bo ci Ford Gal ca 8 “Tyan main noes seat sss vn Cort 10. Income Sk on Suntan Tawar Ah 0458 [cm 10 Brace Ac £1 ln Dr sion. ma 1 12.48 pun. pn FE J JS C13 QL remus hase yo et, oi 43 A tncontent A hi twas mkrstood Ut 1 L718. ser th cri hl ad is chenge [14 wi he aanve representing he wih thot chim. am AB oF coe ih Was 52 15 A PRAT oss. ls A vee ets wn surson: tT 0 anaes in ohare as er wet? GQ Whe Cte A Showorkafor— whchowhich-oh, [use 18 HE MITHESS. 7s. Vt Conn 16 ihitine, Sh ork For Nighine, er. eas moms nand0Q Eusaes ait ARC News? a0 [— Tn A Fboheus tat rion ves nt [Ee —— tem a aa iB contin, Coe oman nid Ca A tmemtfcantrememben Thenchwok [oan 28 badd, chess? Ol 2220 was inifint 1m but sh itn Uh Whine | un 24 JT pe “aa 25 program. 3 uta tinker a mfr ogre. Rdont [row 25 on. ESQUIRE OEROSTON SOLITONS C50URE ORSON SOLUTIONS | eens saa | SB Chaka FE - FE ES A cas, 1 Cm? Wate atmo eatin. rae 3 CORT RTA. Fre use sepazzon, would ike 15 Kaew wha IF 5. po A SMES "ad Lthoag ie tle fot ove vy ose, ite priya joe: kl: veo bee it it mas. Deseret Phd fhjiiiomiabiii ree immu ws RPS Mh Deon ahs sis {owns maps ot shoe eo nt To. Gd: 4 ti fa 18 om pam oe t6 ton Lous 17 Ard the peo of the 0g chs te own 17 MR, SCARD! 4: Than ws vs peasy 20 cv =n. H rT ts 0 leases st cat : a TE tre mE ean vesmmAn———— ] et seams, rh ml i sue: 25 HR CSRS OPLIL Alan ethowss, joann 26 A Right. i esate Eros Fos : pS i "sn ni prop ER w oa 2 ME. NACAVILLY: He Jt ha Just = emu 2 Uezhoniz abused quis Kabens of ens cher vino oy nes vee Cn 3 We Pete hE avai so het —t HL SUVSON: tenons Ashes |e 4 in cpraenting 3 young woman who hs made thse -— ppd A ry He ne mr mmr ——— ot 3. Prsmmmtesto ame a eontogt o43 —e WR Shean, oh etre rosnle | van soma amuses oy vero pole. bo J 8 Te Ther Savver— oe = a 18 cree 7 owt mean arnt a we nin vt preven | ens 1 herds ve eure Tt emesis attest fh [oan 13 A ol on tha ert, yas wih garam ot nly mle on 2 Hem rman mc ere — pry 117215. wink mn me evn ed everest tot ts mous es rae CHB ete S01 dt on tte tr i TR we TYE em—npowase— phere tate Jim 10 on EG: tors Womb Ft, | moe 8 ov Te, th wenn masa ian [Tmt irommreen ar ry [mia aa t————rem——— ma rn iy emerge emit Leen 21 IING wr AT Aste on Ty end. sain 20 QS Creed, 5 Lack ue = true, PAE wa on 22 HR LRSM Z: wes me who sed it, 1 mares 22 A308 IKE with FATES OF SAIH pu) FHIONE0 20 55 fore 38 te Doom awn an an re 8 teen snr po pismo ARR 14 EY rr sn SRS i Win Re 1 ON SRS pri proppY esto sc i Swamees mwraesnans wicrenns Eons Lawr 3 soma rcparters in that copay, vas. ime 3 TE ALINSS: Me. STE wigle Luar 4 ©. anc ard -- ane 3piground means thet ts ww 4 fellow La, ~clianiion. 398 0 Asmar. ove 21 Le kinounl alae Virgin & 500082 i36e1a04 10 35 fea 21 BYR SIRCR: b) rite TT. i a i iran 2 bam smelly shusee 3x Mr. — Frofeswr Dessomte! own 2 It T Buus EARS 2, BUT dont think k have. i (3 TE any pat enacvner Lie 3 nae ! FE Hr m————— a 1 2 TLR ne mera To mand 1 § ® sion Tone wa | ws 10 cxampies, many cromplcs, where © hove said, 1 represent | css 10 A Okay. So, maw, lets sec Okay. Yosh. I i cama 11 2 woman who has olleged thate, Soma yerbol formulation [ran 11 Bava evn 10 Tima an - ana Gon tik pao gral vt 14 sat lad sei H GET I 1 Rs ivi i TVR it mre —— ra ] ame 20 A have [rn 20 1rd weldenes that az £m 6 repecaRItrg fe the ] GEA RS PE or CEE TTT wat atshedts PES — en wi 1D Lake meh pes dient constr foo 1 sen wn 2 then ean 2 “Unhet, nse. wa 3 A omy. an 3 unstirred BE re py “Beir: He cam: ey — rely olen. 1 wn B 3piRQ 1, yo ce Spr Sentng othe cst done 5 le res a et four on Tow des 92 wri § llegstiors, ctu sesertens, ere upp — are vas 8 od is hat 1s usd 84 the up ane 7 cuprosd iy the seed cations ha are gies fr oan Te propeiton - es 8 th, core? sr BA Tae I would like ta look st the document. Gun SA Yeah. Tmean, obvious, whoa you writen [wer © G. im esms to ve sos the dst before T nes 10. rer, ya you're — you Know, you're trying fa | a 10 i 303 i Samer on ns 11 roprosent that thi ls the best product Lean come wp |e 11 A. Sure, ani 12 with, Se 12 QL Dall 5 ene ha was tad ses 13 Mow, vou know, in 3 40-page Brier dig + | ama 13 Finca ve 18 010-15 hace some you know, rvor a ctstion or [asc 14 A. Okay. wn 15 something ike that? 2 have to - Xm not perfect. Tm [nu 18 Qos th content wane 16 sure that's 3 possibilty, but, you know, worked hard [oz 16 A. BUT mas, thare's this £3 rae 1r20: 17 to ry to ut together the best product that T could on [wns 17 wel, that's what I'm saying. 1 would like -- my 18 benalf of Virginia Roberts when Iisa ts brist. | once 18. eccalicction i that bhere are number of pares 1 the Ser 18 QL And nam geri no bar ia [im 19 Aletta | mr 20 act, 4 3 represen Uh cur that re ar 20 GQ. ho My myenly qs thabiet, | ono 21 onrtans othe recerd spp é folaal iss 21 tn orn ageing resent 0 Fin cours ta ! A ann 22 ction supped an cts sien H 00128 Q. - srupostions shen tn tn court a2 A Bue thats ue, ves. 1 oms28 A veal, tats right. To the best of you mG okey. Eada + 0125 now, your ability, sure. wa 28 “0 sve, ay celeron af. ‘EBOUIRE DEFCEITION SOLUTIONS F5OUIAL DCFOSITION SOLUTIONS sa 32s08 1358 30120 od : = oo = won TQ Toes ok yor wou sgn 20 ona 1 ne wars, comin dhe house whan ] ono 2 a our. iw 2 Prince he was he? Guasten, we 3 Q tins ofthe age ns 3 “nso co we born, ut rm ot H wo 4 A Okay. ono 4 su. ca 5 Qt smnent Tw Deemer Soon [mu § Hotere. When He Dutshoniz was vein? | cn 6 tac Muss uma sani vs hem, sed then Ws res © Ur, i om 7 hich 1 citan to the Aes dition, se ons 7 Het cen i he care? roe B75, le 1316.20. Go you ve Ural re 8 hm camry + ho cry ven, Und | re 8 A td ree 8 oye ot loss ur ar fi res ) owe 10 Q. sommsmnce st mpmosgme ann fawnd0 A Okay. ses 1 tt sents ke ssatig tne cart that gis fase 41 Q. Du you sae ake a boat ree oni 12 Reh care the Fam sh bose wien Tis [cn 12 A Yeah H aru td Dmbonts wes thers? omc 13 nS. cisRason: sage 2. uth A ves ones 1a en, sis: wndS QTM Ow rend yr wate mid for an nds Q Fase 3 leo 6 1H nae (0H; ae 16 enpasitan. 1 con 2c 0 yeu you ee. conne 16 if als yeu Pc. | cf? A woudlie tose it beciuse, youknow, [ow 17 A Yeoh, Okay. Allrignt. hate whatthess | ev 18 its possible Ym off. [TT —" i oe 19 QL Lame tad tre recon nn 18 OQ Duy. semen camton bt Tan H msl) A Swe aw 20 so, an attics, ccs rt conta coset | me? Dd wll rd wht 5 led. 1 ese 73. ona 21 tasSimony support th sseticn thes bess won 22 loos 22 0 26 ons 22 DT 308 im ipbors une the see te er) Peta = Fi eh, E10 TI. 8 J. vied 2 20. Une 10: mr 28 A Those — those ines 18 Lu oun 25 a A ‘HOURS DEPOSITION SOLUTIONS ESQUIRE DEPOSITION SOLOS. Esta osm ete sbess TS TA AEE EE ose 1 ssn ot nc snes =n er 1 gs bao 1 A ever look, mis i notte fit at epson Gece, ay ec, fur 3 OQ fmm eset oer Corsten th Vii Bebats hd fofesce ein & Ae <a lava as ite 10 wrong in uber exe 5 Dini wire st : Uns ure rk? rors 5 on tranectpt or something, an yore sagection wt § A Thun es sentences Uren tea. fous 6 Mat = you know, vel concede that cited the wrona en TG Wht os mae re. PE ——— uri 8 A Thote-. thoce three toss: "Notsure, When saw § Qu Are hs wet werk ecu: When ot rs 3 Wr, Derchowic vin visting. Une. How often di he | vane sap 18 xo 10 nm, cok 30 Qtan, wr 10. coma?” Those — those hiss es, G01oe, UL Iooke | ove 0 1G 15, Un ahs = ye 9a 140 23 1 2 2 rH Uk mittios Ber. agree wRhyouan tt. | ns 18 85,1645 2. Lm samy ou 0d 1010 20 wichin AZ Q ano reE in mate orl, ra 12 do ease tha? ri 13 theo 1 chin hori e soenbre 19 sir 3 A Tome 181020, yes. ra 16 supa av» ale, rd Daas ios por ero ena Tors 16 Use an igi Raolss oomtestaony, [wre 15. Raber ami ee owe, rest fon 16 1 ary a a on chae 2 r ne d6 A. Lines 1610.20 do not refer to Virginia fon 17 suman - tn 17 Roberts — oh, ne, wait « minut, How, ii = fin 8 A Hono, mo, no, no. Thatwould require n |e 10 because who T1ook aL har, hs 151 Len 18 S0-winute smsmers ra 18 08 ye evs ay reciemion ari 2 OQ. Oy. [wontescr ad mete saner [ane 20 Sri Neaers, ome othe use wae jp SCAT Aan ex hom eran [ane 21 Pre new wes Bre?” aa 22 2 ua zn becuz W's mow 14120, wr 22 Frew HLA hia basen Tre not sare, ] ra 28 SR SINISOH: 1 wma op. hove are evn 23 “Nat aava. Who IW. Borate Ae | Grad more ane oore ust, va2s ve i zs The ries: Dy. rats Sona won Lead, ain, Tier H SORE DEPOSTION SOLITONS ESOUIRE OEPOSITICN SOLUTIONS 950 3510003 ey Ca LA = wa 1 wri ses vm 1 gin mt ns sus on = ve ru 2 QL helt Ht vance thot vn 2 yo kn, 1 rang 23a. moss ne 38 agree zn 0 Sh wh CO 1 en 3 te nm bce. ha be. Dec es ise, een BE SACS I ey wre Oger, PRE rs 4 ult, cul Ean ff ame 16510 cos ie 8 stance, dass rp tht armen? an 5 tsa, tat stor ics es, bt 16 foe © A. Tull darks with vou nk here AGORA To |v 6 el SYS ors dena hrs. a3 LPR nur i Hae 7 baa lstatln of th Be mantis of the ck 18 [11a cs 7 unpocth cet a the gostion, ic ve rt [ren 8 tureugn20. Et fuer 8 ow, you're saying tat there 5 not ora 8 suds nem would Be dete. Fo Lenape | cree 10. information outside of 8 ines 1 through 2010 [seer 10. Lo Sng 55.15 hr 1 nw, 13 hos wer } xn 1 suppor the allepmion, and hats uiog to reaubies [rans wrens los rambsis. : Gru 12 ch longer ances. ae 2 [ras ——— i Taeef3 Qe mantaiongmsonn bat Ls mintts |oreus 13 ut wast irk hod vedo nt 16 Ct H wn 48 cn. hon go me ut ccc 14 alo] pro i rsp U5 te Fave, 3 i 16 HR SEARO: Youth si nt wun en 16 conto, ctr ot 19 ess ws cove. oar t6 asin er: 16 [LR —— fawn 17 [Rp — ut Sabo: 1d medto fon dis | loon tB ta, were ne gang te howe ara, cus 18 one rtm sins, int Us eta, 0 : fonts rectus Loot te re me sre commit. [own 19 etn nen, H foe 20 HE TTUESS: her. Sere en 20 mv sro: i fone 21 vt anv an? Q bare rave : Jos GQ Tuncerstnd uno ee rato tt nu 22 Wi SCALA Aamir tof te rn 23 ma thre yo codecs os 23 3000. STIS: | nh yen a ! wn 25 Qbear Mout Scan: ds ar sl rig ca afta SOUR DHFOSTION SOLUS ‘ZS0URC OEFOSTION SOUUTONS | on zannn as 251403 ER rr Cree H ET TT IE wo 1 rae, — ssa 2a Yom 2 we wesc: nger- re 2 TIC SIOEOGRIER: ie aren a he eo i TUR —— 3 won ats fe 9 i. EINSON: Ta mils, A, Tho: 4 foe 8 norte 5 cess exes) tn 8 mo, smn . hepato wre sdsmat Cr 7G tsar mon cso i wan B that testimany. Would yeu piny #, plese, for the. { El wrk 8 vines? Tiss Com Ue vieclage cf Ue ceposion. | 9 ar 10 THE WETS, Fen hE | Sastre es rat tn seen here pe Lat aa Event th, ul ying ion on tom tis shot ns he ne $4 yard ne, nk 540 | hart 30 OE " Pd 1 re Kerstin ned. £0 Tent bobo ee respecte fue ps in “ ToD tan whore sh iteat, 30a “ nats car of rose? i nm SARA: i not ging dt n en? memo ate. for green, the wa at fez meg oop er 2 on HR. Hp: Ota. #8 non 24 HR. SEAROUL Rn 121 50th = TaTS pant soni Thee vee be shone = FSQUIRk DCPOSITON SOLITONS ESQURE DEPOSITION SCLUTIONS | as span wasn —— — wen 1 tht ul hae five 3 have fist ill 1 [DEPIETIIN RATA SHIT i Sew 2 Frio Dashowke sd wa pO Gn 2 | wen 3 that, So by agrecmnt, thes anoson ir raw 3 signet ro: 220150 i 4 ww a GAIDLE J. ECARDS ad PAL G. CASSELL 7. | pe MR. SIMPSON: fL = U's = i's wading ove 5 ALAN HM. DURSHOWTT. 1 en © kon and ns tis s | ng RACAL © man en by OECARTION OTR PEAT OF POR | it a8, SPS: th I gang 2 in mg a | poi Sy 9 cae nde peal of gon tow | ato Scan Okay. 10 coarse wovseng os my opera: | tt HR THON Uh sss tel 1 cot en the ctr rr rae | Ta12 kekstine vacate he ptr ere 12. on ren mm, nd th se bv and scat, | “an 13 Sep tho put chores in 10 sr anil cc or Charges ane cons, Hass, | “ont timony = sug mo slareiom re 14 aad Uy ra on tr CEFOSI TON BRRAIA SHE | 2eS the qomion of shri bss and 16 Neo, Ar the anstarng hs Se toes | Tea fE Fete Desh me ere 0s arc re, 16 cronge = mdr nt. | TE —— o i iw SARA hat record er. 1 So onte dro, —— M OR050M: ar smo oki ts. 1 ws LB dete out kaon to mors cesar, tot w | [I bl SS rm eS: Dio. aed wnke | 2 pr } TeaT3 deorstoct mkt bs bap tao n | coat everihag, Me wilde het st ancien Se % H a2 pues 2 i SSOUNE D030 601 ok SEoURE DEPOSITION SCUTIONS i tr sty 0:40 I si EE — i : 3 eageMe__LineMo___Cospetei 3 wABGANRS | Jee | ee End —_— 10 andes ache sa ary i 1? rage, Joc bo. Changs hd DH fae oi 2 i Re ee ——— ® T—— } EI TN UP = TL — | 2 u § ery 2 5 DTORTION CARMA SHEET H 2 ry, [rrra— HER I J Hl cmp ————— © Fn silat mii T I SE A TA Balm in ; BammREns z Se Nl CRE Bees eemmmm e ERS RT — asm ie BA SE URS % ———T « HEE PS ——— wa of wast. A Remaon “m chure: Ein. 3 WB PaguMe___ neo Gouger a I er = pp Eo a | ® ——— | Filing # 37201585 E-Filed 01/29/2016 03:47:44 PM INTHE CIRCUIT COURT OF TIE SEVLNTELNTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE 15000072 BRADLEY J. COWARDS and PAUL G, CASSELL. Pluintifl Counterclaim Defendunts. . ALAN M. DERSHOWITZ. DelendantiCounterclaim Pluintill DEFENDAN /COUNTERCLAIM PLAINTIKE ALAN DERSHOWLIZ'S MOTION FOR CLARIFICATION OF CONFIDENTIALITY ORDER OR RELIER FROM TILAT ORDER The transcript of the deposition of non-party Virginia Ruberts Giullre (*Ruberis is curently under seal as a result of the fanuary 12, 2016 Confidentiality Order in this. action. Dershowitz secks larification that the Confidentialiry Order docs not prosiude him or his cums] fram submitting the frascep of the depasitian & the Office of the Slate Allomey. the Office of the United States Attomoy, and othe appropriate investipative awhorities salely foe purposes of requesting hat those offices consider opening perjury investigations regarding Roberts's testimony. To the extent that the Confidentiality Order precludes such disclosure, Dershowitz requests thar the Court modify it to permit the requested disclosure in the public interest, Roberts has stored in an effidavic originally filed publicly in fedocal court in what the paris hve refiared 1 as the CVRA Action that she sas present en Joffiey Fpslcin’s private inland, Little SU fares Island, at the same time es former President Clinton, That atlidayit was 1 stricken in relevant part from the record by the federul count, bul Roberts's counsel filed publicly a pleading 10 this case contosting Defendants assertion thar her statoments. in the media regiming mcling former President Clinton were untrue. A capy of the public affidavit filed in the CYRA Action and the sxeerpted portion of the pleading filed in this action are attached hereto as composite Exhibit 4. Thecause fommer President Clinton did nal leave office wil Tunuary of 2001, tnd Rusberts has reponly stated in publicly filed sffidavits that she “escaped” from Epstoin while in Thailand in September of 2002, the allege mecing with farmer Fresident Clinton must have taken place between January of 2001 and September of 2002. As explained tn the lector amachod as Fechibit B, former FBI Thircetor Tauis Freeh made request pursuant to the Freedom of Information Ace for documents from the Sceeet Service ropseding Scorer Service personnel wmvelling with former Presidous Clinton to Epstcin’s private iskid and the Us Virgin Islands. Thssed on the response by the federal goverment to his request, and His knowledge of he duties, peotacals and operations of security provided to a formar President. Mr. Frech opines in the atuched letter (hut the shsence nf such recor “sinmyly establishes that former President Clinton wis not peesent on Litke St James Islaad during the period at issue™ IF Mr. Treehy's opinion is correct, then Roberts's publicly filed affidavits in which she stated thar she mot President Clintan on the isd during that period ure abyivusly false. Derhowits intends to bang chis public information to the aration of the appropriate authorities. Separate fram the public information, Dershewits alo helieves thu Riberts gave fuse testimony at her deposition. The relevumt testimany. which Dembowiv intends w proside Lo the appropriate authorities, is bog filed under seal sontemporancousiy with this motion. In an abundance of caution, Density. amd his voumsel da not want to disclose (ix non-public 2 information even to the responsible public uliiciabe wil u right and need w know without olbvaicing confunation from this Court that doing so would not violars the Confidentiality Order or aiemsalively relief from that Cemiidentislity Order. Respeettly subined. & Fo 2 Sent bows Soot Foci Bar Na. 149100 Tham coger corn SivinR Safin Florid: iar No 07028 Stevan ftsiiesRsgalsom COLL, SCOTT & KISSANL, A. Dedsland Cenno TL. 14h Floor S150 Sou Dade oulevard Mian, Flovida 33 56 Phone! 308) 35-1500 For. (308) 373-2391 Kichinl 4. Swepsn (pea ht 1) mipson ilestin cos Sars 1. hrs ip fa ees wher wileyreia com Ashi I. ler (pm fu is asligsiigrcincom Nicole A. ands go bu vices wrichendsonts wiles rein com WILEY REIN 11 1376 K Steet NW Whinslon, I: 30000 Phonc: 202) 219-7090 Fo: 07 119 TI Kenneth A, Sede ac he) Keds som SWEDLILS ROSS 13 Oli Stoce Boston, MA 92110 Phas 1617616 1oa Fox (6:7 646-44% Counset or Alan M. Pesionsz CERTIFICATE OF SERVICE THEREBY CERTIEY that a copy of the foregoing has been electeoaically filed through the Clerk af Browsed Coun: hy using fhe Florida Courts eFiling Portal and thus serve hy electronic mail: SX{Scanes law com. INCHES arc la com, scanslateamigs careylaw.com to: Jack Scarola, Esq, Scarsy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, 2139 Puli Reach Takes Blvd, Wet Pals Teach, Toridu 33409; orijones diutah go to: Tors I. Jones, Esq. Assistant Utah Attomey General, Counsel for Plaintdt Cassell, 160 East 300 South, Sal Take City, Utah 84114; braciipuihiajustice. com Ls: Bradley T. Fulwands, By, Farmer, Taff etal, 425 Noch Andecws Aven, Suite 2, It. Landendale, FL 22301: cassellpiaw utah. edu, ta: Paul. Cassell. Esq... smocnloyiibsillp.com, sperkinsdibsflp,com, fleservog bsfllp com fo Sigrid $. MeCuwley. Tisq.. Ties Schiller & Cloner, 1LP. 401 T. Ts Olus Blvd. Suite 1200, Fi. Lauderdale, FL 33301. this 29° day of fanuacy, 2016. Ty: sf Fhomos 1: Sons THOMAS E. SCOTT EBN; 149100 STRVENR. SATRA TR: 0S702% 4 EXHIBIT A Case 9:08-0v-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 2 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JAKE. DOT #1 and JANE DOT. £2. Paitioners w. UNITED STATES OF AMIRICA, Respondent ) Lo My name is EI | + born ies August, 1955 2 Lamcumeatly 31 yoars ald. 30 Tne up in Puli Roach, Tlorida, When | wane ltl, 1 lived annals und wired 1 be a vererinacian. But my lif wok a very different tea when adults began to be interested in having sex with me. 4 Tnapproximately 1999, when | was 1 years old, | met Ghislaine Maxwell. She is the dughter of Robert Mell, who bad been a wealthy publisher in Britain, Moxwell asked Oat Tome with Yer ts JelTrey Tpstcin's mansion for the pupae. of leaching me Tow ty perform “massages” and ( tain me professionally in that area. Soon after that | went to Epuicin’s hum in Pal Resch on Fl Brillo Way, 5. Prom he fist time [was taken to Epsteio’s mansion that dag. his motivations and actions were sexual, as were Maxwell's. My ficher was not allowed inside. 1 was brought up same sain. There wis naked gay, Tpstein, on the table in the rons. Bpstein and Muswell forced me into sexual activity swith Epstein. | sas 13 years old at the time. He seemed to be in is Ah ar $f. Twas paid $200, Tyas driven home by ane nf Fpsicin's erployees, 1 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2018 Page 3 of 20 ER i” ee TL S————— would travel with Epstein on his private jot and have a well-paid profession. Epstein said he m——— 8 Sol started “working” exclusively for Epstein. He took me 0 New York oa hus er ———————— —————. ——— 10 a room with a massage parlor. 1o mc. it looked like an S&M parlor. Epstein mde me engage mm—— 9 You can soc how young | looked in the photograph below 4 3% ea [/ wa Case 9:08-0v-H0736-KAM Document 201-1 Entered on FLSD Docket 01/21/2015 Page d nf 20 10. Epstein took me on a ferry boat an ong of the rips to New York City and thece he Look the picture shove, Twas approximately 15 or 16 yous od at the tims, 1 Over the next few weeks, Jellrey Dpstein and Ghistaine Maxwell tained me to do wht they wanted, including sexual activities aud the use of sexual toys. The teining was in New York uml Flarida, at Fstcin’s mansions. 1 was: basically every day and was ike ging lo school. 1 also had to have sex with Epstein many tims. 12 Ts ined Ko be “everything sn man mie me fis be TL wasn'L just sox taining - they wanted me 16 De able 10 cater a all the needs of the nen they were ging t@ send me to. ‘they said that che loved that 1 was very compliznt snd knew how fo keep my mouth “hut 13. Epsicin and Maxwell also ld me that they wanted me 1 produce things for them in addition to performing scx om the men, They 1ald ta me ns pry stlention ta the delails ubout what he men wanted. 50 1 could report back ta then. 11. From very carly on 1 was fearful of Epstein. Epstein told me he was a billionaire, Taal my mother that T was seirbing Gar this viel soy, anil she said “go, yo far away.” Fpwiein had promised me a lot, and | knew if 1 et 1 would be in big trouble. 1 also knew that 1 was a witness fo a lot of illegal amd very bud behavior by Fpsicin and his friends. 107 lefl Epstein. he Kiev all Linds of pawertid people. 1le could hive had we hilled oc abducted, and {always haew ho was capable of that if 1 did not obey him. He lot me know that he knew many people in high luce, Speaking about himseli, he said “1 can gel way with things. | wins very scan, pariculady sine | was a teenager 3 Case 9:08-0v-H0736-KAM Document 201-1 Entered on FLSD Docket 01/21/2015 Page § nf 20 15. T visited and traveled wilh Teifiey Fpstein fin 1999 though the summer of 2002, and during that time 1 staved vith huen. as his sex stave, at each of his houses really mors Tike mmsian) in Tagations including New York City, New Verks the area of Sain Fe, New Mexico: Palm Beach. Florida; an island in the U.S. Virgin lands: and Pacis, Ceance. [ had sex wich him ofien in these places and also with the various people be demanded that | have sox with, Fpstsin uid me for vmany of these weual encounters. Tn fact, my only purpase for Epstein, Maxwell and their frends was to be used for sex 16. Ta illus my connection these places. T includ fur phisogaiphs taken uf me in New Mexico (showa belaw). The Gist ane is a museunt in Santa Te, New Mexico. We iad gone sightsceing for tho day. Epstein took this picture of me, 1 was spproximately 17 at the ime, judging from the Tasks of iL AL the end of the bry we returned ta Ttein's Zor Ranch. The second pictuce is me on one of Epstein’s horses on the ranch in New Mexico. fhe following. two wre ram winterlime in New Mexico 4 Case 9:08-0v-807368-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 6 nt 20 | | URN ¥e in Sa = - a Ne [. VE. When was wih Wim, Epo oud sin with slug gis i uly Basis. Tin Sonor in this kind of sex wes obvious tothe people around hin. “Ths activites were so obvious Case 9:08-0v-H0736-KAM Document 201-1 Entered on FLSD Docket 03/21/2015 Page 7 of 20 med ol that anyone spending ny. significa tine ut sme af Tpuein's residences soll have clearly been aware of shat was pours or. 18, Fpuiein's code word for sexual encounicrs was that t wis 1 “assage”, AL times the internction between Epstein and the girls would Sart in a massage oon sein. it was alvays a sexual encounter wud never just a massage. 19. To wddition to consti finding widerige girls sutisfy thie personal desires, Epstein and Maxwell also gor gurls for Epseeia’s friends and acquainances. Epstein specifically Lal me that the reson Gar him doing Uris was so tha they sould “owe him, they saul “be in his pocket” aad he would “have something on them.” 1 understood hin © ean that when someone was in his pocksr, they owed him frvors. 1 also wndorstoed that Epstein thought he cand get Tendency if he was ever cunght ding anything illegal, or more so hit he vould escape woudl altogether. 0, Ghishaine Maxwell was heavily inva in the illegal sox. Tundentood her ta be a very powertul person. She used Epstein’s money and he used her name and connections to ‘nin power and prestige. 20 One way ta describe Viaxwell's mole wane as the “madame.” She ase « position of rust for all the ick, including me. $he got me trust her and Epstein. It warned out tht Viswell ws ll shout sex all he lime, She hid sex with undernge girs virully every day when | was arcund hee, and she was very farcelil 22 1 first had sexual aetivitios with hor when 1 was approximately 15 at the Palin Dsch yansion. 1 hod ny sexsal nelivities with her over the vest several year, in Fpstein's various residences plus other exotic locations. 1 had sox with Maxwell im the Vien Islands, 6 Case 9:08-0v-H0736-KAM Document 291-1 Entered on FLSD Docket 03/21/2015 Page of 20 New Mexico, New York, es swell an Fence sind ning other locations. T als observed Viswell have sex with dozens of underage airls. 23, Maxwell took pictunes of mamy of the underage gir, These pions wore sexually explicit. Maxwell kept the pictures on the computers in the various houses. She alse made hard copics of these images and displayed cho in the various houses. Maxwell had lige nnsunts of chill pomograply tht she pesonly made. Many times she nude me sleep will otter gids, some of whom were very young. for purposes of taking sexual pictures 24, Hand law profser Alm Denhowitz wes around Fpsicin frequently, Deeshawite vas 56 comfortable with the sex tha was poi on hat he would even come and chat with Epstein whilk 1 was giving oral scx to Epstein. 251 hd send intercourse with Dershawity at least six nes. The fies tine wis when | was about 16, carly on in my ssrvinude to Epstein, and it continued unt 1 was 19. 26, The first time we had sox look place in New Yark in Epstein’ home, TH was in Epstein’s mam (not the massage room). 1 was, approximately 16 years uld al the time. 1 called Dershowitz “Alan.” 1 knew he was a famous profossar, 27. The secon tine that Thad sex with Derduonwitz was at Tpssin’s house in Pale Beash. During this encounter, Dershowitz instructed mew both poctorm oral sex and have sexual interoourse, 3.1 alsa had sex with Dershowite at Cpstein’s Zor Ranch in New Mexico in the massegc room off of the indoor pool area, which was still being pointed 20. We ulsa hid sex al Liddle Suint Times Ihind in the US. Viegin Wands. Twin asked 10 give Dershowitz a massage on the beach. Dershowitz then asked mo to take him semewhers mors private, where we proses W have intercourse, Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2016 Page 9 nt 20 airplane. Another gurl was present on the plage with us. Dershawile on television calling me a “liae.™ [le is Tying by denying that he had sex with me. 1hat man is the same man thar 1 hyd scx with at least six times. 3 Topstein mude me have sen with Prince Amlrew several times, Prince Andrew, Maxwell. and | are shown in the photograph below. | had sex with hum three times, inchiding one orgy. Thangw be wns 4 member of the Rritish Rayal Family, but T just salled him “any, ho Kus | 33, One day when | was in London (specifically in a townhouse that is under Maxwell's mame), T gol news from Muswell that T would be meeting a prince. Later thit day, Epstein 10d me 1 was meeting a “major prince.” Epstein told me “w exceed” everything 1 had been taught, He crphasized that whatever Prince Andrew wamied, Twas lo make sure he gol, then went out of the hous and stayed our front in their car. It was just Epstein, Maxwell, and me inside ulone wills Andy. Twas introduced ks the Prince, anil we kissed formally, cheek tw cheek. , Case $00-0v-80736. KAM Dovumom 201-1. Entored on FLSD Docket QLI21/2015. Fags 100t There was u Tot of egal discussion about Ardy and His ex-wife (“Fergie”). Then the discussion twened to me. Maxwell said “guess how old she is” Prince Andrew gucssod 17. 35, Then we all went Inu Chino vessiuramt for dinner snd then ta Club Tran, + Tones “membecs anly” night club in central Landan. Andy arranged for alcool 1 be provided 0 me at the club. Eventually we Left. § rods with Epstein and Maxwell back to the townhouse. Othe wry thers, Ftv und Massel] informed nee thi the Prince wanted ts see “mane sf me” hat night. Andy maveled tm a Separate car with his guacds. 36, Well amived bok at the sorte smd went upstairs. Fpsicin kak # pictur nf me and Andy with my awn camera. The picture abe is that picture. which has been widely circulated on the infomst, Andy has his Loft am around my waist and is swiling. Lhe picture was developed an Murch 13. 2001, and wins taken sonmetine shanty bre Thnd it develped. Twas 17 years old at the time. 3% Twaned a pire with the prince bocause T wars kosping in cantael with my family. 1 had 101d iy mom and ony grsadina dat 1 was meting Prince Andeew and that Pd ke a pitare for thom, Thy told me fo “be careful.” 38. Aller the pictims, Fpsteirs and Miowell kissed we ud said b “lave fun” They left Andy and me alone upscairs, We went to the bathroom and bedroom, which wer just steps amy from wher the picture ws taken, We engaged in sexu activities there. Aflerwards, Andy Teil quickly wih his secusity 39. Lchatod with Epstein about this he nest day. 1 fold hin, “it went great.” Epsicin said sonnething Go the vifeet af, “Vou did well. The Prince had fun” 1 fell Tike T was being aceded. It was horrible to have to recount all these events and have to tey to meet all these nosds v Case $00-0v-80736. KAM Dovumomt 291-1. Entored on FLSD Docket QLI2L/2015. Fags 11 of and wants, T wld Fpstein shot Andy's sexual interests in fect. Tpulein thought i sus ery funny. Epstein appeared to be collecting private information about Andy. 40. When T go buck from my rip, Fpwiein pid me: mare than he had paid me lo be with anyone else approximately $15,000. That money was for what 1 had done and to keep ory moh shut about "working with the Prince. AL The second time 1 hud ses with Prince Andnw wa in Tpieii's Now York mansion tn spring 2001. 1 was 17 at time. Epscein called me down to his office. When | got there, Fpsicin was. there, alimg wilh Massel], Johann Sjoberg, and Andy. Twas very surprised see im again. Epstein and Maxwell weee making lewd jokes abaut “Randy Andy” 42. Lhad che impression thy Andy had com there fo sce Epstein and to have scx me swith, There was un ler appl purpose for Andy obi hore 43. 1 was tld fo 20 upstairs wih Andy and to go to the room I thought of as the “dungeon” dhe massags room, but it is really sory looking). Thad sex with Andy thers, Twas onl paid $300 from Epstein foe secviciog Andy that tin. A. Lhe third time 1 bad sex with Andy was in an orgy on Epstein’s privare island in Ue VIS. Virgin Tlands. 1 was around 18 ut the tive, Fpstein, Andy, approimstely eight oder ‘young girls. and | had sex together. The other girls all scemad and appeared to be under the age af 18 and didn't really spesk English. Fpstein laughed abiut the fuel they couldn't really communicate, saying that they are the “easiest” gies 10 get long with. My assumption sas that Jean Luc Bruncl got the girls from Exster Europe (os he procured many young forcign girls for Titeing. They were yourgg wad Cursipesn kioking snd sounding. 45. Afterwards we all had dinner by the cabanas. ‘The other irs were chating away among themselves, and Fsisin and the Prince chattel together. T fell. disguied, smi sent 10 Case $00-0v-80736. KAM Dovumomt 201-1. Entored on FLSD Docket QLI2L/2015. Page 120t quickly ts my ws cabana that night and sent 1 sleep. Prins Andrew must have flown sul carly the nose moming, a5 | did nor sec hum shen 1 got up. 48. Thane sen Buckingham Palace's recent “emphalic™ denial that Prine Andrey had sexual contact with me. That denial is (alse and hoetlul w me. | did have sexual contact with him a5 1 have described here ~ under oath. Given what he knows and has scen, 1 was hoping that he would sinply voluntarily ll the truth ahisut everything. The my atlomneys can interview Prince Andrew under oach about the contacts and that he will tell the truth. AT. Tales bod sexu imercourse with Tem Tuo Bromel amy times when Twas 16 tcght 19 years ald. 1e was another of Epstein’s powell Iriends who had many contacts with ‘young girls throughout the world. In fact. his only similarity with Epstein and the only ink fo their Friendship append to be that Briel could get dover of undernge giels and fel Tpsicin's (andl Maxwell's) strong appadite for sex with minors. 48, Bruel nm same kind af misdeling agency snd appeared 1 have an smmgnent with the U.S, Government wheee he could get passports or other travel documents foe young girls. He would thon bring these young girls fyirls ranging in sec from 13 0 21) to the United Stites fore senual purposes smd Farm then out te Tis friends, including Tpsein. 49. Brunel would offer the gurls “modeling” jobs. A lot of the gicls came from pooe caunirics or pow backgrounds, and he lund therm in with 1 promise of making gond money, S01 had 10 have sex with Brunel at Litt SL James (orgies). Palm Beach. New York City, New Mexico, Pacis, the south of Eramce, and Califomis. He did not care about camsersation, just xe SL Jefftey Epstemn has told me that be has skopt with over 1,000 of Brunel's aus. and everyhing thal T have scan confirms his claim. Fpsicin, Brune, amd Maswoll loved orgie with n Case $00-0v-80736-KAM Dovumom 201-1. Entored on FLSD Docket QL21/2015. Page 12 of Kids — that is, having sexi) interactions With ANY young leHagers Mt the sume Tis. Sometimes: a5 any as ten underage irks would participate in a single orgy with them. I porsonalty observed dozens of these avgics. The urges huppened on Kpasin's ishund ia the U.S. Virgin Tslands. in Nex Mexico. Palm Beach, and many elher places. Most of the girls did not speak Engi. Tt wos tng uaderscanding thas th gies had been persuaded to come by Brunel offering them illegal dna or a career in modeling. Bruncl was onc of the main procures of gis 52 In addon to Ghistame Maxwell, ENN. ot IRS = <iso Savolved in the orgies. ALthis stuge, Tam fopofil that these ather wamen will come forward and tell the truth about everything bocausc that will help preveut future similar abuse. $3. Ihave seen sports suying or implying that Thad sex with former President Bill Clinton on Little Saint James Toland. Farmer resident Bill Clinton was present on the Island al a tue whea 1 teas also preseut un thi Island, hut | have over had scxval relafious with Clinton, aoc dave T ever clined Lo have had sueh raladons, have Dever sees him bave sexual relations with amyone S41 now uadecsiand that Fpwicin roachsd a non-prosccution agresuent wilh the fod goverment in 2007 and pled guilty to two sate crimes in June 2008. 1 now kuow that I wis identified by the feral government as on of EpStcin's and is co-couspianor’s sexually abused vietios, However. no ane takd me about thase eveats vari after they happened. 55. On September 3, 2008, the FBI sent a victim notification letter © me. This was the first witon communication 1 had received frum the FRE. Ths letter is attached as Exhibit 1, Ihe loter cescrinos an agreement in whith compensation would he made viethns of Fpstein's 2 Case $00-0v-80736. KAM Dovumomt 201-1. Entcred on FLSD Docket QLI2L/2015. Page 14 of seal shuse. The letter ulsa said that the fodera] gavernment wis wing te “defer Galeral peosseution.” No one had told me about deferring federal prosscution before this. 6. Tn 2011, twa FAT agents, alc we in Awaralia and then am bo mest me, They met ne at the U.S, Consulate in Sidney. They seemed te be very professional and hard working 1 thonght fo myself, “Wow. these people will do the right thing against the bad guys and protect 57. Ihe agents were mainly focused on Epstein buc while thers | provided theon some inflrmation saul shen wha sees invalad in illegal acts i well, Twas sr that a filse Statement 1 these lav enforcement officers was a ceime and 1 wid the tlh giving them the information that I could recall about the individuals they inquiscd abou, $8. Topatein who tufiicked we for sevunl purpases to many ther powerful men, including politicians and powerful busingss executives. Epstein requiced me to describe the seal events that T hud with those men presumably <a thal he could potentially blackmil them, aun stl) very Teall of these men today. 39. 1 will continue to cooperate fully in the investigation and prosceution of Epstein. Maxell, or wry of hie Friends whs prticipates in the sexual abuse of nino, abo laps Oil this informacion is ueared in a way that will keep me safe trom Epstein and others criminals denlificd here sn as 10 encaunige mare victim of similar erimes in came fran, 1 these rites are not prosecuted. despite my volunteering this infamation and cooperation. then it may deter other similar vietins from coming forward, 60. Tis advil, The wid a focus on ho | was, tdfichesd For esl pura, 1 have not described al of th details of the sexual acdvitios Epstein foreet me to have. Also, | have mal described all of the details af the ther events discs here. TF a judge was me in 3 Case S0R-0v 60735 KAM Documont 201-1 Enered on FLSD Dogket CL24/2015 Page 15 of present my information fn more dete. incloding more specific descriptions of the seaval activities with ihe men Epstzin sont me 9, could a 30. 61. Thue directed mp atormess, Bradley J. Rewards and Paul G. Caseal, to paso an reasonable and legitimate mens to have criminal charges brought against thes: power! peopl fi the crims they have committed aginst me and other srk. They are representing me in this case pro boro. 2. Since [filed my motion in this case, my credibility has been attsoked. 1 an telling he truth and will so et hese attacks prevent me foun exposing Ue nuh of how: Twas balicked fo sex to many powertil peop. These powerful people seem ta think tha hy don’t have 10 ollow the same rules as everyone else. That is wens, 1 hope thal by coming foro, | can help expose the proem af sex taffieking and prevent the same sort of shse and dogradstion hat happend 10 me from happoniag fo othr rls. G.I declare under persis of pajory that the foregoing is me ami correel Executed this "day of onuazy, 2015 (Location of signutre eft undisclosed fo sovuty rasa) 1 Filing # 33754151 E-Filed 10:27:2015 06:33:15 PM IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS. and CASE RO, CACE 15000072 PAUL GL CASSELL, Pluintich, ALAN DERSHOWTTZ. Detendans CONSOLIDATED REPLY IN SUPPORT OF NON-PARIY JANE DOE NO. 3° AND BOTES, SCIITLLER & FLEXNER LLP's MOTIONS TO QUASIT OR FOR PROTECTIVE ORDERS REGARDING SUBPOENA SERVED ON THE NOW-PARTIES Defendant served virtually identical subpocass on non-paity Giuftre, and hor counsel Hoies, Schiller a Flexner LLP ("BSF Tn an eifir 10 conserve judicial resumes, the min- parties ace subanitting & canslidated eply Isquesting that this Court quash the unreasonable and oppressive subpoenas pursuant to Florida Rules of Civil Procedure 1.414s3(1 or alfcruatively. sue protective unde sharply limiling the scupe of the ubusive subpoenas pursuant 10 Florida Rules of Civil Procedure 1.280(c). INTRODUCTION Aftee publicly seating that his mai goal in secking discovery from Giutlie is to puc hee in “jail, Dofendror sored this non-party with a subpocns containing twenty five (251 unrewsonuble urd appressive request. Tis without question that GiulTre was sexually abused ws * June Dos No. i Visginie Robes Gio. and will bersioatio be refered 0.2 “Gite. See Tabi | CNN terete, Ne Dey Janay , 2015, See Ti, Avsisfan Bekins Sys (ABC). anuery 6, 2015. “My goal is fo bring charges agaiost the licat aud require her to speak in court,” 1 Telley Tein. Defendant spends over five (5) pues discussing the federal ution and eleven (11) of us subpoena Requests Jans Dos Subposna 1, 5, 6, 7,8, 9, 12, 13, 14, 22 and 24; BSK Subpoena 3, 6,7, 8,9, 10, 12, 13, 14, 19 und 22) relate 10 the federal action or Jeffrey Fpstein. Tor sxample, Request 24 socks “All documents concerning, relating or refoeeing to your assertion that you met former President Bill Clinton. former Vics President Al Gore andor Mary. Tiahetly “Tipper” Gore on Lille Sain June Tkand in the U.S. Virgin Tous.” Defendant clsitns tht this discovery would go to the issu of whether or not Giuflie is felling the truth shout Defendsint hut thal effort i fmpesichment is leary collateral at hest and fils 10 ures the contal issuc in tis case. “That issuc is whether the Defendant had any basis to support us medi ssl against tn avsyens claiming hal they Tubricaied and then publicly led false charges of erieninal conduct on the part of the Defendant. [cs the Detendaar's credibility and not the credibility of Giufire that is the focus of chis defamation action. Defendant sugges's that Cull rust be a Tie because it would he uneurd uf for ane of Fpsteins young gir w have met President Clinton. Quite the opposite is true. There are a aumber of accounts documenting Clinton's regulur visits with Fpatein. For example, Chaunise Davies recently shoved pictures on The Inside Edition progeam of hee travels with other yung women in the company of Bill Clinton and Joffiey Epsicin on kpstein’s plane. See Exhibit 4, ‘Lobia Express’ Mussease Reveats Lucid Details foo teres Fpuicin’s Privaic Plane For the Ruch. Inside Fition. April 27.2015. The Epstein light logs also demonstrate thar formar Presidear Bill Clinton maveled with Teflrey Epstein ami ther young women. See Fxhibil £, The Canker, Tamuary 22, 201. All of that information, wile 1 doubt interesting, ot irrelevant i the defamation ise before hic Court exept to the extent it casts doube on the Defendant's own credibility, 7 EXHIBIT B Professor Alan Dershowsiy Tlarsard Law Seoul 1575 Massscusets Aveave Hauer Hall £1 Cambridgs, MA 02138 Hun. ous I. Frach Mobile 2032138221 EE Jamar 21.016 RE: FOIA Request Dear Benfessor Dershorwiv: As you know. on Ail , 2015, a ragquest was wade tn 122 United States Scercs Serviee under the “ederal Irecdom of Fx ‘ormation Ast (101: $ U.S.C. See. 552. relstme w Use poriod 1101 0 1102. or any sad all shill gs. vel econ, ierazies. sports aad ates ceconds for LSS persue] eavelig with former President Hill Clinton 1c $. James Isaad and the US Virgin Islands” (Atachman: A). The basis lf the above described FOIA eguest wos is clian by Viggiia Robt, fn wove popes filed ia carly 2015 in Finrida federal cou, thet she aad former Presiden: Clinton were an | ls SL Jamas Island. atthe same tin: during the 1010] fo 11:02 period. Asset Garth in January 16, 201s liter fram: Kim Fx Campboll, United Saas Scerot sorvios Special Agent Tn Cliege, Freed: of Tuforunation Act ad Deivacy Act OTe, the “USS ia conducted reaanalle Seals for FespaIve eons. I EATS, om yiew of LISS main indiest, Cat Tere ars no records pertaining 10 your reqest tha: ars reforenced in hese indices” (Atcha. Bi 1senctore snschide fram cis respons faa formar Peesiden Clint did 10 in fact fret 0, 20: as he present on, Lit SA. Jams Island betwen Jansary 1, 2011 and lanumy 1. 202 Hasad upon my experisnes and knawledge of hs diries, protncol and epecatians af LISS Pravective Details, the Special Agents accompany and escort former Provident Clinton 24 sours per day, and world have cectsinly went with him to Lite St. Jauges Tseud cing “he period sé ive. Ibe Agents bd accampaniad the Sarmor Presider. 0 hat Incation, hey wn id fi boca requized ta Take and file ic: Jos, tral suschess ind rehied dosmentation oti bo Us visit. The teal abwsnee of any such sosards and doeure sation, in wy npinion. szangly ssahlishes at farmer Fredeal Clo was no: present on Lite SL. James Lund turiag the period at ssc. Hest Rogarts. 7 ps: of dl Lusis Freeh wr DEPARTMENT OF HOMELAND SECURITY TATE S11 SECRET SERGE adnan BE A Frooom of Information Act im Privacy Act Brunch Communications Center 245 Murray Lane, SW, Building T-5 Washington, D.C. 20223 Dae wr gy Patti Buscript 3711 Renaett Pike, Suile 13¢ ‘Wilmington, DE 19807 File Number: 20150826 Dear Requester “This is the final response to your Freedom of lnformation ActPrivicy Acts (FOTA/PA} rogue originally received by the United States Scerct Service (USSS) an Apri) 16, 2015, for inlormation pesteing fo amy wad sll kif ge rave] econ, finenries, eeports, and other seconds for USSS personnel traveling with fonmer Predident Bill Clinton w Liltle SL. Janes Island and the L8 Virgin Tohinds. In sesponse to your quest, the USS as conducted reasonable scarch for responsive recs. Ti appears, from a rovicw of USSS mai indices, thi thor are Toco pertains yea tequest that ve referenced in these indices. Fnclowed a topy of sour ariginal request. Allernatively: if you deen one decision an adverse cerarmization, you may oxercise yout sppesl tights. Sond you wish to file an administrative appeal, you appeal should be mide in writing and seceived thin sixty (60) days of tho date of his Fehr, by wring Lo: Prec of Tloriation Appeal, Deputy Dircetor, U.S. Sect Service, Communications Center, 245 Moreay Lane. SW. Building T-5, Washimglon, 1.0. 20223. 17 you choose to ile an administrative appeal, please xphin the basin of your appeal sod reeceace the case mamber listed above. 1 you have aay questions or would like to discus fis mater, plese concac this of ies ac (202) 406-6370. FOIA File No, 20150826 ix iwigred to your request. Please refer to this file ‘number in all fture communication with this ollice. Sincerely, tire Cosi —r Special Agent In Chiree Freedom of Information Act & Privacy Act Officer Flosure: Copy of Original Reguest. Patti Beseript 3711 Kennett Pike h Suite 130 ‘Wilmington. DE 19807 302824 7144 - April 6, 2015 Delores Barber ‘Deputy Chief FOIA Officer, Director, Disclosure & FOIA, The Privacy Office. Department of Homeland Security Headquarters & Privacy Office Building 410 - STOP-0655 245 Murray Drive, SW. ‘Washington, DC 20528-0655 FOIA REQUEST Dear FOTA Officer: Pursuant to the federal Freedom of Information Act, 5 U.S.C. § 552, 1 request access to end capes of For the period 1/1/01 ta 1/1/03, any and all shift logs, travel records, itineraries, reports, and other records for USSS personnel traveling with former President ‘Bill Clinton to Little St James [sland and the US Virgin Islands. Lagree to pay reasonable duplication fees for the processing of this request. If my request is denied im whole or part, { ask that you justify all deletions by reference to specific exemptions of the act. Twill also expect you to release all scgregable portions of otherwise exempt material. T, of course, reserve the right 10 appeal your decision 10 ‘withhold any information of to deny a waiver of fees. 1 100k forward to your reply within 20 business days, as the smtute requires. bis og for your assistance. sho FREE GROWTH AND OTHER SURPRISES rap Gordon Getty FOREWORD BY THE AUTHOR How Come This Book? Afeve months ago, Robert Trivers was kind enough to send me his new book. the title is “Wild Life", Perfect two ways. Bob is a world autborizy on weildlite, to wit evolutionary biology. But his books and papers about that are already well knot. THis mes one 5 about his awn wild life, with his ideas in the background. Tye started my own hook tree for fur times over Une past tlecade. Bob's gal me stacted gain, Try il. 10s Bob's real vuice. One of his papers, co-suthareed by Mey Newlon(2). is houl deception and sell-teception. | never saw much of either in Bab, I never saw a guy Jess anxious Lo impress, Fine if you knew his achievements, and fine if you didn't, What he wanted to talk about was great new ideas by others. It was (roun him that | fist heard about the Hamilton-Zuk pacasite theory, and Paul Ewald's complementary one about parasites stabilizing population density of hosts. Both are beautiful examples of the obvious-in-hindsight. Trealized that my hook could take a cue from his. My avn lie hast heen wild. It as heer intersting because ie genius of my father gave me interesting places Lo he an things Lo do. Tcaull say spmething shout that, But te book would be mostly boul my ides in economics, Bob's ideas are well Known to anyone in bis field. Mine aten't. 'm ten years older than bob, without ‘much to show for it except in composition. (My last two operas have been getting some traction, and ay SACDS get pretty good radio time:) a [I run my economic ideas up the Flagpole, in my veal voice, and see if they prove deception or self- deception ar something warth the time. Declaring My Blases Ta bi Tree marke. fan 1sould hove it even iT agreed with socialists at there is something inherently iniquitous about it There are bad guys and conflicted matives Forwanl By The Astaor 4/18/16 L in markets and government both, What love boul iL is the chance (o prove ides. Tove Wall Street innovations such as swaps aud futares and ETFs and mortgage- backed securities, even admitting their dangers, And who vould have thought that the San Francisco Bay area, a stronghold of political cormectness at the voters’ boath, would nonetheless innovate Siri and Alexa and driverless cars, in its free market havens here and there, over the past ive years? Remind ine the last inovatian by a cammitiee, Whi would have thaught we vould make the warli’s best car, the Tests, In this labar stranghold? It takes guys who prefer the impossible. t takes guys like my Father Yes. al was J. Paul Gelly. I] declare a bias for him. His Fults were just what we read they were. | Liked them fine. by times with hin, with an exception Jl note in. Chapter 1, are some of my favorite memories. seem to be the opposite of pharaohs who began their reigas by chiscling oft their father's names from the monaments and substituting their own. That was something about a ticket to the afterfife. 1 put ny Father's name on things | build. The aftertife will come as ft comes. Since this baok is ahautrowth first, T should say has [fel about growth, Most economists, which 'n anything bul, reat it 1s a goal. [love innovation, which bas translated to growth, while worrying plenty about growth itself. What happens when anyone can make a doomsday weapon on Lis desktop? Depressed people do awity with themselves every day, Some might take the rest of tbe world wilh them it they could. Armageddonist religions wouldn't be needed. Not even destructive intentions need be, A doomsday weapon bought at the five and ten might go off by accident. Then why do | root for Innovation when Tin seared stlf about ts consequences? Tecase allurmatives re scarier still, Qumans will innate anyhin, while Big Brother or the religious authorilies aren't looking, and 1 don't like the prospects of imation driven unilergrouml. Well have ta find same way ta face the risks anil Forwanl By The Astaor 4/18/16 2 ‘manage (bem. This book doesn’t say how. (will open hil tan of worms, and others 100, and try to track some but not all to their destinations. Une look Jeads to another. "his shots that I'm 110t an optimist in the sense of making rosy predictions. But | seem to show that bias in evaluations, I'm two thirds Panglossian. (Ductor Pangloss was the guy in Valtaire’s Candide who said that this Is the best ofall possibile warlds.) side with the god ator in that | cannol imagine an improve ment lo his world arta the haman cae. 1 sec the dangers and evils, such as Armageddonists, as somehow part af the scheme. The winld would nak he letter it used no thrals a challenges la solve, Ta solve therm is not 1b wish ther sway. The stories of Aladdin's Jamp and Use monkey's piv el] us a each wish aller the Arstis to wad the one before, | thick that's what Shaw was telliog us in Don Juan in Hell. Don Juan and the others are free to go to heaven whenever they like, and occasionally do. “they come back because they can't stand the boredom. Where ind Fault, and differ veith Pangloss, Is a5 t the doctrines we are taught. Whatever study, 1 seem ta ind a god measure of nonsense taught along with wisdarn, This bank is about what {ind af both in econamivs, 4d a problem [ry to salve, nol wish away, is he danger of sing sight of the poiols an which Panglass wits right, My verse and music Ley (o remind us. And I anit a bis for the surprises my tile promises. Love unending what we had all assumed. Fund And all the more fun when | can show that famous economists had already seen and said some of the same things | do when we read those economists again. Surprise need not he true novelty. My free growth theory is really John Stuart MUI, althaugh na ane seems ta have noticed the paragraph [ quote from him. My next generation theory really belangs 1a my 17%-century rhymesake Sir Willian Pely, who happens Lo be my nominee for greatest ecanamistof all lime. Tos wit, T could also cred it 1 the period of production thearists John Rae, Nassau Senior, William Stanley Jevons and Bugen var: Bavhm Bawerk. They need arly have considered husnan and (0U capita) as explained by Petty wo centucies before. Forwanl By The Astaor 4/18/16 3 This reveals my bias for economic history. it seems dry as a bone until you find something terrific like those insights. Jt happens that | bad written both theories, and published one, decades before | found those great precedents. Should | have heen chagrined? OF course not. Forgatten or unnoticed precedents are at least as mach fun to paint oat as the surprises they shied ahead of me. Twill also reveal a bias for cvnlutianary binlagy. Its main axiom, the biological imperative, becomes paw af mine. The tea is that. behaiars are selected for sucoesstul reprortuction. | will ry W show thal the classical schov] treated this is wriomatic {rom Pelly through Smith, Malthus, Ricardo aad Mill Mallbus wis only the most obvious case. (t Japsed from atteution when a brillixnt new insight called ‘marginalism preferred to do without explanations for tastes, Above all comes my bias for the great thinkers in those fields. We saw thatas to Bob “Trivers. Although | often cite them ta disagree with them, 1 sce all as glants from whose shoulders lip in eying to climb. 1 don't kick sand an 97-pound weaklings. Mill eas a merch who gives us all essons in attribution and generosity, particularly 10 schools be disputed, wi who nonetheless dido't mind being « minority of one in his books or in parliament. Petty was sometbiog beyond. Polymath, self-made tycoon, anatomist, music teacher, father of national accounts, originator of present value theory and human capital and next generation theory, and esteemed by both Adam Smith and Karl Marx for other itmovations | don't mention. Such men are understond slasly and incompletely. Forwanl By The Astaor 4/18/16 I CHAPTER 1: RECOLLECTIONS Inever finished a course in economics. | started one atthe University of San Francisco sixty years ago, and dropped it when | couldn't see the foundations. But the bug had bitten me. | kuiew that one day | would try ou my own. always loved logic. My favorite philosaphers at USF were the pre-Soctatics who Nked nothing better than ta confound common sense. A brilliantly vexing exaniple wins Zens Une Fleatic and his argument that Achilles an never calch up Lo the Tortoise; Achilles tut first reach the line where the Lriaise eas last, 1nd the tortoise has since moved on. Logic cn play such tricks. But] sensed that economics was the place to try its limits. Dropping the course didn't mean giving up, and logic would be the key. Neither did 1 take a course in business administration or investment, My major was English literatare. As a grade schooler { had asked my father about this, Where and what should 1 end up studying? He had read economics and petroleum geology at Oxford, and | supposed he would advise samething like that for me. 1 gata surprise Carvar-arivnted majors were line bul nal nevessary. 4 graunding in the liberal arts could be as mich or sre. The trek ws learn his 1a learn, Thal sound right, aol anyhow right for me. So I chose USF, 1 Lwenly-minute walk from bowae watil my ‘mother moved us Lo San Rafael, a hf hour drive cross the Golden Gate Bridge, and followed my intuitions toward English lit and bistory and music and philosophy. | graduated with a degree in English Jit in 1936. This was the time of skittish peace between the Korean and Vietmam was, and the Reserve Forees Act meant 1 had ta repart far six months active uty starting in the spring of 57. Meanwhile | worked for ay father. | and my brother Paul, later Sir Paul, started at the hottam pumping gas and changing ail at separate gas statians not Far from our home in San Rafael Thal Tel Lime for a fexs weeks ata bulk plant (oil warehouse and tank farm) in San Francisco, stil working at the bottom, before | reported. Baul had served in the Chapier 1: Recollstiors 106/16 1 Korean war, sui was now exempt | wis a shavetidl second liewenant, thanks 1o the ROTC program at USF, in the quartermastec branch at Fort Lee, Virginia. My eyesight was never good enough for the combat branches. Jie, who was then president, had started in the quartermaster too. My military career was 10t 50 glotious. Somehow [finished the six months at Fort Lee and seven and half years of inactive duty following, abligating inc to one weekend per month at military posts near home, withaut being Jromoted even to first licatenant. By icy. 1 shauh have: buen pramited or usted Uo Ue ranks. later learn thal my schaal chum Manel Teles, who worked at Fort Presidio in San Francisco, had somehove fixed the record, Thank God for ald friends, My weekends of saluting were postponed when aul and | went bick to work for my father in 1958, My father then Lived in the Ritz Hotel in Paris. He liked ordinary two- room suites. Ihe sitting room vas his office. His filing system weas steamer trunk. ur job was to sit and listen as he met with executives or art people ot old friends. He would usually take us along to lunch and dinner, and wangle us along when he had bec invited out, lle was the warld’s most attentive Father whenever we were with him, at least if focused elsewhere when we weren't Paul went un tn earn refining ane marketing in Nay, aller those few weeks in Parks, while 1 went to the oilfiekds ry futher had just found nd developed in Ue Neutral Zone betyeen Saudi Arabi and Kul, Pil soon leswned ali, became general ‘manager within two years, and ac things well. | learned only a little Arabic, but also became manager in 1959, and soon blundered my wity into wo weeks’ house arcest. 1 had got crossways with the local emir, Mohammed bin Nasr, not bad guy, about perks and privileges he and his staft expected Getty Uil to pay for. “The ease against me was rigged. One of aur junior staff drivers, a Kuwaiti { think, had aceldentally rammed and damaged a pipeline. le had fle the cauntry to avold ail Jul there were no fun, Tis supervisor, fim Kinnel, was waraed thal he (fim) was accountable under Saudi law, and wuld be sent th fail Instead. fim caine to mre realized whit was breveing. Laws are exible, anid im wind ave gal aff witha Chapier 1: Recollstiors 106/16 2 caution al most if weren't al odds wilh the governor, Iwas obviously next, But 1 was not about to gamble that the threat to Jim was a bluf. told him that if L were in his shoes, | would go back to England. He did. That left me. But J was in my shoes. he blunders had been mine, and 1 would face the music. My two weeks of house arest went peacefully. The plain cement-block house had been built for my father at our por camp of Mina Saud when he lived in the Neutral Zane in 1953. The Fanir's identical house wasa few steps away. My father's favarite maple sugar wars il] in Une ricige roan Une fiese Shakespeare plas 1 hadi’ Uread in college, and read vr cured the vom plete pas and plays of John Keats. The house arrest was probably is much dressing-down us | deserved. Pad, or anyone else, would have handled the perks and privileges more adrotly. But our host country, Saudi Arabia, may bave picked up on something too, Getsy Dil was not one of the concession companies in the Middle East named in the baksheesh {bribery} scandals that made the front pages over the few years remaining before. most concessions were negotiated away and host countries ran things themselves. Tack to wy father In Seotiand, where he was visiting his ald friends the Maxwells near Termes, and then ta he Luo-raarm suite at the Riz in fondu atiout like the ane in Paris. The drove the six hundred niles between, in 4 vintage Cadillas, taking two dys and stopping 10 visit bistoric sites and museums. He needed no guidebook. J satin on meetings ind events everywhere with him in London as in Paris, | assumed that the Saudis had cleared the house arrest vith hit, and | would have agreed as he did, He Loo was io different shoes. He was right. He had solved a rel problem with minimum damage, Lesson learned, and no hard feelings either vay. Itweas clcar to both of us that | ws not cut out to be a line officer, meaning one who ums things from day to day. My mind goes off on tangents instead of tracking arguinents in veal tine. Tt works far ne, hit not as an administrator. We decided ta try nes comsullant. Chapier 1: Recollstiors 106/16 3 ‘That began al my father's Spactin Aircral Company in Tulsa, Oklahoma, He hadn't meant to buy it. He had bought control of Skelly il, centered in ‘Ilsa, and Spartan turned out to be ane of its holdings. Then came Pearl Harbor. by father was 48 ‘years old, and had been a yachtsman. He took a navigation course at USC along with Kids half his age, led the class, and volunteered for sea duty. 11s ald friend James Farrestal, Secretary of the Navy, steered him ta Spartan instead. Spartan cold make training planes and could Lean pilots. My Father acceptent. Ne paid himselCa salary af onc dollar a year. Te had decisions Lo make when MacArthur aii Matzushila signe the peace irealy. The training planes were nol meant lo leave he ground, Spartan lacked the capacity Lo make the real thing up lo competition. The demand for trining planes pretty much ended sith the war. My father could sell out or find another use. He decided to make house trailers. It worked. | had lived in a Spartan trailer in the Neutral Zone, like the vest of the senior stafh, when | stayed at our Wala oil field Father than the house at Mina Saud. We and the market had liked therm ine. lierschel Shelton had been one of my father’s vight-hand men during the conversion to trailers. 1 sald that the place to lank far hin was never in his office. You would fim him in averally under a Lrailer an the Factory Noor, with a welding iran or riveting gun. The liked Lo be able 1 do any job his workers did. Tow else woul be Know if they were doing il right? J stayed in my father's house at Spartan, as at Mina Saud. Jt stood at the opposite end. of the runway from he offices and trailer plant. | drove another seasoned Cadillac that my father had left in case he came back. Max Baltour, who ran Spartan, called it a clunker. (t clunked me around the countryside on weekends, or to Jamil's restourant or Cap Balfour's house for ditmer, or downtown to the movies or symphany ar opera house. Cap (Captain) Balfour had Flow in Warld War 1, and showed crippled hands from when his plane caught fire. Tle was cranky, urbane ani razar-sharp. Tis problem ws Lat Spartan wouldnt seen to come oul in Ue hla. Me worshipped oy father, and figured he had Jet him dawn. Oc seems to have: Chapier 1: Recollstiors 106/16 p brought bis moods with him aller work, which my (ather generally didn't, Thal cost hen bis sunny young wife. { somehow got a pass. | could understand him, and | was my father's son. My advice in the end was that my father should sell. Meaowwbile [ was taling an interest in economics again. Busmess was about rate of return. Spartans was negative. What was the benchmark? 1 did a fttie study. Tis easy a sec that return Lends to even aut fram anc eampany or industry to the nl. Wee piu investment into high-return prospects, and unintentionally drive that high return down Wward the nor by expanding te capital denominator. | dida’t Know thal Robert Turgol had wrillen be sume in 1766, Bul what struck me veas (he smipression that return, net of inflation, seemed to revert to a norm over tite, Why were interest rates, averaged over business cycles, about the same then as in Daote’s time or Julius Ceasar’s? Why should buna srpatience be steady norm? That puzzle nagged te for about a quarter century until | found the answer. Another decade or to would pass before | leamed that Sie William Petty had found tin the seventeenth century. Towent hime in 1967 ta study harmony and counterpaint at the San Francisca Conservatory of Music. Thad found time fa compuse a few things al the Hause al Mina Saud with piano | had bought in Kuwait. They included 0 a cappella fumaccompanied) choral selling of Tennyson's “All Along (he Valley”, and sometling to which I Jater fit Emily Dickenson's poem “Beauty Crowds Me” in my song cycle “Ihe White Election”, The composer Chirles Haubiel published "All Along the Valley” in his Composers’ ress in Los Angeles in 1959. The one change be suggested, an mexpected D Hat major resolution, is the best touch in the piece. | had noticed capies in music shops in Tulsa. $a it seemed about time to develop that interest too, and the canservatory hack home seemed the logical place Chapier 1: Recollstiors 106/16 g Istudied there from (al 1961 through spring 1962. was probably the ouly composition student already published. My teacher in both the fall and spring classes was Sol [oseph. He vas a legend there. Most of what he taught confirmed my instincts. Maybe five percent was old rules | didn't think much of, and five percent good ideas that hadn't occurred to me. All was useful anyhow as a guide to what Jeading atharities have thoughtand taught. That was the pont We were to accept what we liked, and any hives Jean the lingo. Those Liv causes covered traditions of the eighteenth and nineteenth centuries. Most campasers in the 1960s, ami probably same or most af my classmates though. af that as a stepping stone loward study of the serialism and other alonalism ben in vogue. I skipped those cliesses. 1 realized tliat was a nineleenth-century composer at heart, Nov the veorld seems to have spun back to where | was all along, For most composers now, atonalism is oni of the colors on our palettes. Even | use some, So did Hach. We reach for that color when we want to express disorientation or angst. found cauld get mare said Most of the tine sith major-minor scales Five short piano pieces | wrote then were published hy Befwin Mills in 1964. As my father's son, you ight imagine that 1 was asked to pay the casts. Nope. Neither had | acd onl ta Composers’ Press. Vanity press exists, bul that was nal the business model of thase two firms. {gol standan royalties from sales, nol amaunting lo much, aol they gol the rest. Six published pieces by age 31 would not have impressed Mozart or Schubert, By Jesser standards. iL was pretty good stat, There ire distinguished composers who have never found a publisher. Tomorrow the world! | would write operas and symphonies! What happened instead was sixteen years of writer's block, or eighteen since finishing the pices in 1962. | suppose | was trying to say “Shazam!” and tam nto something [ wasn't. The ice would brea in 1960, when | realized that Billy Tatsan aul have to din But that gets me ahead of my stary. Tiarried Ann fn 1964, making ita banner year an that count even are than the publication, anil went bck ta virk far my Father. Tht Wok us to New Yuck in 1965. Chapier 1: Recollstiors 106/16 & Tidewater Oil Company, which would merge into 1s parent Gey Oil Compiny & fev vears later, had red iok problems in its Eastern Division. My job was to see why. Eastern Division was ran by “Jim” Jiminez, an upbeat guy | liked. I don't think he 100k the red-inks probloms home with him as Cap Balfour had. He reported to my halk-hrother Gerge at corporate headguarters in os Angeles, and Gearge reported 10 my father in Londan, Gearge had varned is ob as president by outstanding earmance ab even level wn he way ug, which is mre than you coll say far me nthe Neutral Zone. But Genre was tauchy. 1c had a chi on his shoulder. 1 think my Father liked ta rite him, and he sometimes fell unappreciated. You have bo shrug that off, George was doing fine. The problem in Taster Division was nol in hin, and iLwas nol in Jim Jiminez. Then what? Ilooked at the baoks. The red ink had notbing to do with management, Eastern Division did refining and marketing, Its new refinery iu Delaware had been aptimized to process heavy Wala crude ofl, which then was overa dollar cheaper Derbarre an the marke: than the lighter and casfer-ta-refine crude we produced in Texas and the Central Rasin. Tidowatess Western Division refincry al Martinez, by canteast, Had all the cheap oil iL awed in our wn San foun field, The Martine: refinery seas old, and more: expensive W operate. Mut the net advantage still went to Western Division hy aout a dollar per barrel. Mes mvhile gasoline sald for about a dvllar less per barrel, although only (wo or thee cents less per gallon, in the reflivery-Joaded east than in Californis. ‘Management can't do much about itaport quotas and market conditions. | reported to my athe that Easter Division was at least as veell run as Wester Division, where the ink was black thanks to cheaper crude and pricier gasoline. “hen could ve cut costs oF baost reccipts in other ways? 1 proposed that we close our ald and inefficient Boston [Harbor terminal, where harges unloaded gasoline into our tank farms ta be trucked to statians, and supply Boston from our nev terminal al Pravidunes two hours’ drive away. 17 hal worked, other distribution cansalidations seemed possible. Cater propased much the same thing for our Chapior 1: Recollestioes 1406116 7 operations in apan, where be neve terminal it Kawasald could theoretically obyiste the older and clumsier one in Tokyo Harbor. | realized that plant-closing might be unthinkable in Japan, but thought that something good might come of the idea. Sometime alittle later came my lawsuit agains: my father. It isu’t my happiest memory. There had been a stock dividend years betore, sehen 1 was still in school. We had treated ita certain way on the hooks. | read the law os saying it should have heen treated another wag. The law was probably on my side, and common sense on my father’s. Jute Peery wisely found a way bo make common sere win in the end Meanhill Thad accuser my father of nothing worse Gian aversight, My visits lo Sulton Place, now with Ann aod the boys, went (he same as before, The Ls uit seldom came up and was discussed in easy terms when it did. { suggested lo him, for example, that he might want to settle with my stepmother Teddy in case there could be claims by the estate of my late half-brother Timmy. He did. Somehow we got through the lawsuit without had blood. One would not have guessed so much was at stake. The stock dividend had been a huge one. What | leamed from my Father, then most af all, was perspective. Ve: belleved in an even keel. Zena the Stale, nat the Fleatic, would have el his mated, The lvssuit lasted fram 1966 thraugh 1971. Tn hindsight, thank gosh hu wan. 110 a, lax consequences wauld have heen ugly all around. Again Thad learned a lesson, worl gain there were no hed feelings either way, J continued to do consulting jobs for him throughout the lawsuit and atter. J charged expenses, bul no fee. And [ didn’t pad expenses. I) had, you can believe he would have seen it. [stayed in a single room in the best hotels, ate three squares a day, and paid for anything else myself. | was trying to make the point that | didn’t srant to be paid. Neither had my father at Spartan during the war. The idea was for me to be of use. Lua paid like everyanc else sshen working Foray father full-time, but never on consulting jobs. Those: naw cane ance ar twee a year, and lasted fora week ar tan cach. Campasing ws tll on ie back hurner | was keen on physics, exonamics, hunan origins ami Chapier 1: Recollstiors 106/16 3 cy planning. [ becune clear thal al but the ind needed beter math skills than | had. So 1 bought the Barnes and Noble textbook on College Mathematics, got through tina week of bard work, and then began on the fobnson and Kiokemeister textbook on colculus along with Halliday and Resnick on physics. Together they took me nearly 2 year. At the end, | was allowed to Sit in on the Freshman physics finals at Cal Berkeley, where the same bo Lexthanks were taught. Ttweas the finals for physics majors, and meant ta be tough. Cal took physics seriausly. Not overy Treshman was destined Lo yo farther, Some shoul be steered Towarils eoginsering, which pays better anyhow. There were 10 questinns. Three hours were allowed, Bach of us bad a calculator and nothing else. Nol even a table of integeals. My God. | had to remerber thems or rederive them, There are some thal had taken even Newton and Leibnitz months to solve. | don't rementber any of the questions. There were 200 to 300 kids in the rooin. Maybe 20 or 30 orientals, about three women, no blacks. Not one finished cary. And some Hgute to be Nobelists by nove. Were palling about Cal. [ had answered seven questions when the three haus wire up. Was that goal enough? 1 gata call Tn a fis days. passed, and heat the class averapy. My ald friundd Matt Kelly warner me about this Lima: hat George sas in raul, Matt Til knowin George's new wife fackie, aunl hal heen invited ta dinner tere. Matt's smpression was of oul-of-contral mood changes. He said thal George al one point had drawn bi aside, shown a pistol and warned him about paving too much anention to Jackie. The next mivute they were back at the table in jolly spitiss. Jearned later what was wrong, George thought he had a weight problem, although 1 never noriced one. Doctrs prescribed amphetamines in those days to conarol appetite. They revved him up and wade it hard to slecp at night. So the same doctors reseaibed barbiLurates alight la set him Lo steep. ppers and downers are: dangerous enough. Add a drink ar two and you've got trouble. Of caus] shall have Lold my father. Bul Tdin'L want ta be the ane. liked lo Nous my brathers. Many must have seen the symplams Mats sas. Let them break Chapior 1: Recollestioes 1406116 9 oe news, But the others must have felt as 1 did, We waited (oo Jong, [gol « phone callin 1973. George had died at Mount Sinai Hospital, There was an empty bottle of sleeping pills. My father's death came in 1976. Ann and | had got word it was coming a few weeks before. We were there. $0 was Norris Bramblett, an accountant who had worked for my father since | was in schaol. My father trusted him. So dic 1. He had only a fourth grade education, but a PI's worth of character and sense. My father, Zeno the Stole when things gal ugh, cracked jokes Uy Uhe end. Karris alone could unicrstand Tim ry then. [le Lranslated patiently. My father was giving me one mars lesson. (le Tapsed into 4 coma. Aun and were called dow from our bedroom when he died. that left me and Lansing Hays co-trustees of the trust controlling bis companies, Lansing ran the law firm that bandied nearly all my father's business and litle ise. It was a big job. Lansing was smart, abrasive, and dead bones. He didn't mind hurting people's feelings. 1 was not immune. It didn't matter. It wouldn't have ‘mattered to my father. What mattered was that Lansing know what trast meant, and tthe Trust frst. That's what | cared shout. Lansing was alraily on the Getty Ol bears. | was invited Lo Join Wa. We met faur fines # year, mast uflen in Los Angeles. Taruld Rers, an ofl engineer fiom Colarado, hal become CEO (chief execulive officer) and chairman aller George died. Sid Petersen, an accountant, was COU (chief operating officer). Harold was warmer and more approachable personality. That's what you'd expect in an oilfield guy. Sid was reserved wad analylical. That's wha you might expect from in accountant, although Norris Bramblett it anything but the stereotype. Harold and $id were both clearly well chosen. Neither then nor later did | doubt that Getty was run at least as well as its big oil rivals. The hoard tan were tap people. But trouble: was brewing. The rust, meaning Namsing and 1, iss nerd about 43% uf the shaves. The Gelly Museurn, also chaired hy Marold, awed anther 11%. Boards and managers profer scattered ownership, so thal they ean operate mar freely. Second-best wauld be concentration in dacill Chapior 1: Recollestioes 1406116 10 hands app to follow the board's guidance, Bu my father had made it lear 10 Lansing and me that we were to trust our judgment. We should be ready “to vote the ‘management in and out.” Since stockholders elect boards and boards hire managers, that meant to vote the board in and out. No wander they wore conceraed. Lansing and [ were bath boat-rocicers. Wouldn't it he safer iF there were a eorporate co-ustee? These are usually satety-minded hanks, and many hanks did business with Get Oil Concerns rose when Lansing died in 1972. That Jefl me as the sole Lruste, [was Jess abstreperous thi Lansing bul also less prediclable, Hostile Lkeovers were common then, where bids are made directly Lo shareholders rather Un clesed through the board. Getty was rich it ofl reserves per dollar of share price, It could be a target. Board members tend to feel that they know stockholders’ interests best, and that the angels are on the side of “friendly” or board-approved takeovers it any atall. Stockholders don't necessarily teel that way. “Temperatures rase when [ pushed serious study of the possibility of taking Getty Irivate. The idea was t gIVe up oUF EOIPOate SEAMERUTE 10 escape the corporate dbl tax. Managernent and its investment banker, Galina n Sachs, advised against. Troe think they were right, although my idea hard gor precedents. 1 pressed an, unwisely, by eying lo convince (he Museu lo buck me, They hid eller sense. Twas time 1o heal the breach. Marty Lipton of Wachtell Lipton, a lop mergers and acquisitions law firm, represented be Museum. He proposed i moratorium (the “tripartite agreement”) where the ust, Museum and company would hold the status quo for one year. Harold Berg had retired as chairman of Getty Oil, and $id was now chairman and CEQ. His COO was Bob Miller, a keen petroleum engince. Harold Berg still chaired the Museum, although Harold Williams was its CEO and main volee. We all signed. But Getty O1f had its Tngers crossed. & few days later, the campuny petitioned Une court ta appninl a ca-Lruslie. 1 propised Bank of America. Tol A's chairman, Chauncey Medberry, sat on the Getty Ol hoard. Paul and George's daughters Joined the plaints. Chapier 1: Recollstiors 106/16 1 ‘The Museum was more outraged tin [wias, Marty fell tht he hed been used He and Harold Williams, a business-savvy guy who had chaired the SEC under Jimmy Carter, realized that if | could be hogtied, the Museum with its 11% was the next domino. his was in November of 1983. Within a fow weeks, the Museum and | signed a “consent of shareholders” taking over the company. The required public disclosure ofthis, on top af the tripartite agreement and co-trustee lawsuit before, was blood in the wale Pennzoil unched a hostile takeover bid in December, My concern was tal the trust should not be locked in a minorily position. | mel with Pennzoil in New York, We resolved that to my satisfaction. The Getty Oil board met, also in New York, on January fourth, The mood was not sunny, Harold Stuart, one ot the brightest and finest board members, assumed that | had invited the Pennzoil bid. Chauacey Medberey thought | should be sued. But Sid aud the board acted responsibly overall, We countered with a higher price, Pennzoil accepted, and we went home thinking we had a deal Texan offered a higher bid twir days later. Was Getty Oil alrwaly hound Lt Pennzoil? Tus Tawwyers and mie sai it wasn wolil Ue foal agreement was signed. Cad my doubls. Bul liked Texaco's offer better, ind my duly vas clei, The Trustand Museum would be paid cash for their shires, rather than locked in. | had insisted on Jangusge in the Pennzoil agreement that bound me only as “consistent with my fiduciary duty.” My duty, in the light of legal advice, was (0 accept Texaco's offer. did, and voted the same way as a member of Getty's and the Museuny's board. Those were fiduciary duties too. Pennzoil sued Texaco, and eventually son punitive damages of some eleven billion dnlars. The: Muscum and Trust had cashed out, We were not parties, The Pennzoil anil Teseen flgs bath spokes swell of me, Bul thers was stl Lhe lavessil seeking « carparate ca-trustec. That would hae been very dangerous before the sale ta Texan cashed us aul. A corporate vo-rustee might well have assented bn “carparat Chapier 1: Recollstiors 106/16 12 defenses” blocking a sie and effectively locking (he trust i « minority position, Bul now that danger was over. the remaining plaintiffs were my three nieces and Paul. couldn't blame then. How could a corporate co-trustee burt? But [was still worried. | now wanted to split up the trust into four separate ones tor my family, Paul’, George's, and my other half-brother Ronnie's. Corporate co- trustees tend to prefer the safety of acting only as required, and anyhow might nat he keen ta vote themselves out of a job. Were Paul and my nieces man al me? Telieve iL Lavisuils get thal way. Lawyers nn both sides say pasty things, That lasted because splitting Ure Trust (wok line, The math was easy, bul Une Jegal precedents were vague. My lawyer, Mose Lusky, thought swe needed new California Jaw. Ulaintiffs counsel didn't think so. | was accused of stalling. Someone had the bright idea to approach Willy Brown as Speaker of the Senate, The Law Mose wanted had already worked in other states, and Willy liked it. He pushed it through. Problem solved. The Trust was split nto four in 1988, and an unhappy chapter ended. My nieces and | are as elose as ever. So were Baul and [until his death in 2002. My interests by the time uf the split wer campasing, verse, economics, human arigins and evolutionary biology. Campasing was going preity well, My writer's block hid melted away in Ube sunmer of 1980. Ann and ] and the boys were in Paris then, We wandered into Smill’s English language bookstore. | bought the Thomas Jobuson variorum of Emily Dickenson's 1800-odd poets, "Variorum' means including Emily's own variations shen she mailed the sume poem to different people, or put a copy in the chest at the foot of her bed. I ead them all over the next twa days. Emily had been ane of my favorites at USE, She died in 1886. She had published only eleven pocns. Squahbles among the heirs delayed publication af abiout half the vest until Jahnsan published then fn 1953, hese years aller | geartuatid. Many alewady published ad been Bosdlerizd® a fil canventianal rhyme and geanimar. Johnson gave us the real McCay from her manuseripls. All was new 1o me. Chapior 1: Recollestioes 1406116 13 Is no pin io our hotel room in Paris, but sel a few of the poems in my head to write down later. biore followed. Une of her poems [ didn't set begins “Mine by the sight of the white election...” Election meant choice. Her white smock hangs today by her bed in Amberst where she was born and died. White is the color of weddings and burials. [lor choice, | think, was a death marriage to the reverend Charles Wadsworth of the Arch Street Church fn Philadelphia. le was happily married. She me hin bul thee tes is her fe. 1 would Ll her story in 31 of her poems, an: nto different settings, in my cycle “The White Flectian.” Twas completed in 1981, and broadest on National Public Radin wo years later. 1 seems 0 have male a goud impression. Skva Rostropovich bad kind words, and invited me Lo write something for cello and orchestra sat he could schedule on bis upcoming tour in Russia. Placido Domingo invited me to write a song for him. Renata Scotto wanted me to choose five or 50 of the White Election songs that she could include in her concerts. All were big appartunitics. Somehaw none happened. Other stuff was coming out the pipeline. “That included my opera “Blump Jack“ Here 1 would tell the rise and fall of Falstattin Shakespeare's [lenry the Fourth and Filth, This was risiccr. Now the accompaniment would he archestis, nat piano, and | na background in archestration. Composing and orchestrating are not the same, Composing is like wriling x play, and occhestralion is ike casting the play. There are composers thal don't orchestrate, and orchestrators who don't compose. Most of us do both. | always did my own orchestration because no one else would know what | wanted. { gradually learned from my mistakes. Now | can probably hold my own in orchestration, although many do that better. Plump Jack was completed scene by scene aver same twenty years. | sould think it was finished, and then decide ft wasnt My nest two operas, cach running about an Tor, would he composed much faster. 1 sot “Dsher Hause” mg cardier libretto Basie oy Paes stary in abasic wewks in 2008 and 2009. “The Canturville Ghost’, on Wilde's short stary, oak me: abut tse weeks each, with twa moths between, Chapior 1: Recollestioes 1406116 1 for Libre o, composition and orchestration. The last two operas have been premiered at major opera houses. Usher House ran again at San Francisco Upera. Upcoming performance of the “scare pair®, meaning Usher and Cantervilie as a double bill, have been announced in other cities. Plump fack is still waiting its turn. My interest in buman origins led me to the Lealcey Foundation. | had read about Louis cake in the papers, and had met him a tew times in as Angeles and San Francisco. Brilliant, courtly, ree. fle lot you know shat was rong. became a fellow in 1973, a trustee the next year and chairman the nest. Clark Howell, who taught anthropology al Berkeley, chaived our science committee, His co-chidr wis Dave Humburg, « Stanford psychology professor who specialized in reat ape studies or primatology. Most leading scientists in either field were ‘members or regular advisors. They recommended grants, and we trustees funded them. We took a venture capital role, usually making geaats of a few thousand dollars to promising new prospects rather than bigger amounts to steady-state Projects already proved. Those proved ones included Jane Goodall's chimp studies at Ganibe ov Richard f.cakey's digs at ake Turkana. National Geographic, or the Wenner Gren ar Warld Wildlife or National Science Faundations tended ta fund the Enon winners, We're a lot bigger nove. [am pie of the few living links Lo those geval people and lines, We've evolved wilh (he science, Bul we stick lo Ue veolure capital role. hat always left time to organize lectures and symposia. A few of us including Kancy Pelosi. long before she tried politics, put together an all-star two-dley symposium al the Palace of Fine Arts in the San Francisco Marina district in 1973, Tickets sold out, and hundreds watched on screens set up in the lobby. [ulian Huxley Togeeted, but sent his good wishes on tape. The octogenarian Raymond bart recounted his discavery af austroiapitiicets ofvfcanus at Taung cave near Johannesburg in 1924. Tavis T.eakey had died the year before, hut his equally legeniary widaw Mary updateal us an the digs al Oliluai. Dick Uy filled us in an the geolgy ere. Jane Gada gave the news fram Gombe. Dave Hamburg reparted on the new Chapier 1: Recollstiors 106/16 15 chimpauzer compound nes the linear reaction al Stunford. Clark Howell briefed us on his veork at Torralba and Ambrona in Spain, where our ancestors half our size had hunted elephants twice the size of modern ones. (Elephants go back at least as fan as mammoths and mastodons.) Desmond Clark covered African arehacology in general and his discoveries at Kalamho Falls in particular. Sherry Washburn showed the way in which aur DNA Is 98% the sane as a chimps. All were my clase friends. Ttwas at a sympasium in 1974, in Washington 1 believe, that {first heard and net Ir DeVore. lis Lalk was on evolutionary bialogy ani Tamils rule. Bath were new 1a me. Tew eas 3 cham pin speaker. Students packed his anthropalogy dases al Harvard, He became a Leakey stahwarl snl a particularly close friend, 1liked bis topic. Genes code for traits, and traits more adaptive to niche pressures ave likelier to carry the genes that encode them into the next genecation. the likeliness is fitness", A beauty of this is that you can predict traits from the environment {niche}, and the environment from traits. That promised the kind of logical challenge that | loved. Survival of the Fittest was NOT Hews to vs. What was news was that bright scientists iki: Irv weer specializing in thal lagic, and making testable predictions for creatures generally, humans inured, cather tan sticking the groups they studied most. Thal meant people | could talk to. Hamilton's rule was pu up as the prime example, Tt starts from the principle that the end gine in biology is investment in (be ext generation. Hamillon bad reasoned in 1965 that genes coding for most efficient investment in closest kin, who were likeliest to cary copies of those genes, ought to leave most copies in the next generation. We would invest in them when consanguinity was greater than castybenctit ratio measured fn ites given up and Himes gamed at the other end Tiida’ Tike this. Something was missing, The Jgic was seductive. But Achilles does overtake the tortalse. Traits compete, like those racers, for niche space. The winner 5 the fittest at meeting needs of the niche. Hamilton's rule seemed to leave that out Chapier 1: Recollstiors 106/16 16 1 got Darwinism bickwaird, Darwin's ide wis lia Une best-adipted leave most progeny, not that leaving most progeny or other close kin somehow bootstraps itself into adaptiveness. The math of Hamilton's rule didn't work either. In diploids like us, where each parent caries two sets of chromosomes, closest relatedness without inbreeding is #. "That meant that fitness would have ta double or more with cach generation. The reason is that fitness not expected to be transmitted ta successors wauld be a contradiction in terms. FL canna be lransmilled (invested) al less tan a 2:1 efficiency raliv (benefit cist atio], Uren iL imust be expected ta double ar mars with each reinvestment, Bul aardvacks and falfish aren't 1024 Limes Otter than heir ancestors of Len generations ago. They aren't even a smidgen filter, by any measure of fituess known to me, unless the population has grown, Fopulation growth in nature usually fluctuates around zero. But bis rule was right in important veays, Nepotism is cotmon in nature. The Trust passed my tather's wealth to divect descendants. Most wills do, or tavor nephews and nicces as a secondary choice. Chimp mothers maneuver to push their offspring up the social ladder. Warker ants and bees, wha don't breed, push the chances of thir yaunger hallsisters. Damian's rule was clearly 2 goat rule af thumb, uve thwugh the uath neetied ting, Why should it usually work? | couldn't know then thal Hamillon bimsell would find Une biggest missing piece of the puzcle in 1982. Economics was always somewhere on my screen. Jt was the biggest challenge because {had to reinvent it from scratch, | bad dropped the course al USE because | couldn't find the foundations. But vee don't build a foundation without knowing what we want to top. | bad to reinvent everything at once. Docs that mean thought Iwas hest qualified for such a task? No. Plenty of people are etter at logic than [ am. Rather [ seemed to bie the anly volunteer. Tixplicit ecanamic axioms are sin as a nineteenth century thing, There are implicit ones toa degree. Macracconomics Is sald t rest an microeconomics, and micricanonics on the logit of supply and demand. Gand se far. Tut UTel the need Chapier 1: Recollstiors 106/16 17 ofa logical context for ose, Too darned much was being Laken for granted, What do wwe really want (rom economics? As we gradually tigure that out, we can figure outthe most etticient vocabulary for description and prediction. That's was what Neswtan did. ] didn't lice the lazy assumption that those problems had already been solved Neston lucked out in that old words like mass, force and energy vould masty do if he gave them exact definitions within their usual ranges of mcanings. Brand new terms would have made Uugher: riding, and his Principia Mathematica was tough envugh in 1687. Thad the sane Tuck in Ure en. But lida’ knas tat until Thad callected lextbooks and economic dictionaries, along wilh mast books on economic history [could find. and meanwhile worked oul whit | thought the right vocabulary ought to be, We pretty well have to solve every section of the jigsaw puzzle at the same time, ['m ty father's sou, by the way, and balked at the three-figares prices of some of those texthooks, even though | might forlc up as much tora battle of wine. My icicas on growth theory and capital theory (explaining rates of interest and return) will get plenty of coverage later. It happens | have also taken a lifclang Snterest fn hanks and mane theary. This bask isi't about that direetly. At hanks anil money are part of Ue story of grossth and interest, and anyhow are warth allention in themselves. Money his been defined elegantly in Lerms of whit we want (rou iL, We wan « ‘measure of value aud a medium of exchange. The qualities to give those things are “moneyness”, Money should be “Lransportable”, for one, in tit we don't really want 10 lug bags of wampuu around. t should be stable in value, 50 that we cau contract over the future with least uncertaioty. Jt should have the same value in different Places as well as at ditferent times, to minimize the nuisance of conversion. There should he enough oF it that shortage doesn't drive us to the clumsiness of barter. Jt should In: “divisible into ting units, as hundred-dollar Wills inta Lens and ones and pwnnies, for exact payment with nothing wed back. 1 should be fungible in that one Chapier 1: Recollstiors 106/16 13 unit, say dollar, is worth exactly (be same as nother. Most essential of all, money should be something actually and reliably valued. What meets all these criteria? Gold has been a contender since ancient times. But how reliable is its value? Spain and Portugal stockpiled gold and silver from the neve world for two centurics, and bought nothing but inflation for their trouble. Gold is good tor filling teeth, and for displaying status so long as itis rare. Then what is hetter? Tawar niliant andl dangeraus adventurers, the Scalsiman John Lav and the Irishman Richard Cantillon, proposed Lun. France in 1720 biad rio new sworkl mines, aol needed money. It bad plenty of lund in Mississippi. Liv and Cantillon pul wo aud two together. | thiok they sincerely believed their advice to The Duke Orleans, the regent after the death of Louis XIV, that Jand could be the most reliable basis of value then known, More than that, { think they were probably right, But it wasu't reliable enough. Early fuvestors in paper rights to the land had made a mint as others crowded in. Market euphoria led to more paper rights than underlying value. You've heard that one heave. Law and Cantillon saw the crash coming, It would be called the "Mississippi bubble. Cantillan sald aut just in time. Lav preferred to face the music, as would in the Neutral Zame a quarter millennium later. Land wasn'L thw answer, Jet ll Law and Cantillon good guys like be emir, Both seem Lo biave committed ‘murder for money, Law Jong before and Cautillon Jong after, in scandals in London having nothing (o do with te bubble, Bul they bad good days. Cantillon's book, which { kuove only from descriptions by economic historians, seems to be a ‘masterpiece of the obvious-in-hindsight. Law went down vith the ship, like a mensch, and seems to have kept the trust and friendship of many backers he had bankrupted. | mention the phusses of these twa Ten ta remind us that the truth fs seldom black and white, ani to mitigate: he folly of the French in trusting them. Money taday, in the United States and elsewhere, Is nat backed by any cammodity. ft is “government fal maney” baked by Lhe Lixing power of government. That may be Chapier 1: Recollstiors 106/16 19 the best solution tried so far, The value behind the axing power is the Lota capital of the nation, meaning human as well as physical capital. And the dollar has proved pretty stable since Paul Volker's tough reforms in the early 1980s. That means that government fiat moncy in this county is working about as well as anything we have Known. But there are problems. Government taols for stabilizing government Hat money, which has no value in itself, are limited ta control of its supply. The toals are monetary and financial policy. Monetary policy is mostly “open market operations” where gavernment sells bonds Lb soak up excess money, and buys em hack again 10 put money back in the system, You can also raise br lower Centra Bank interest rales Lo get the same effects, Fiscal policy trims money supply by rising lisses and cutting government expense, and pumps mouey back into peoples hands by lowering taxes and raising government expeuse. Monetary policy is the tool of choice because it hos acted must faster. But either policy, or any mis, is a tightrope. walk. Too much maney courts inflation by mativating people to spend rathes than save. Toa little courts recession hy motivating the apposite. That's why mAcrOscwIDIIics is sai a rest on micraronins. Ark we wise fa push our luck on that tightrape farever? Another prablem is thal our curcent maney syste may depend fou much on banks, Banks buy and sell hack the government hoods, lor example, «nd crete be money they Jend by writing it into the borrowers checking account and booking the promissory note as value received in retucn. The problem is that banks ave failure- prone. [mean plain commercial banks which do nothing but accept deposits and make loans, not the still more dangeraus commercial investment hyhrids sshich osc and fell aker vepeal of the Glass-Steagle Act “The dager is leverage. Depositors must be attracted at some cost, say checking services. Morrawers must be attracted ata rate covering those costs ta give prolitin the fist place. Ther equity investars must be alla ed af an vuity ale, generally higher because equity imposes risk. These rates and tosts are market givens Father Chapier 1: Recollstiors 106/16 20 than whl the bank decides, Then how can profit from lending rates, watered down by costs of attracting depositors, translate into higher equity rates? Easily, but dangerously. That's where the leverage comes in. Ifthe amount borrowed is much larger than the amouat invested as equity, absolute profit from borrowing might be large compared to the amaunt invested. it hens lay only one egg per dag, but] awn three hens, then {can eat three eggs a day. More maney lent out, eampared ta equity invested. presuppinses more deposits to Jeni The leverage nesded, or feposits equity vatia in te bank's case, works out by equal Ue marked euily return for investments of equal risk, divided by the market borcowing rte for loans of such term and risk, nel of expense percent including costs of attracting depositors. This has tended to pencil out at about ten to one, Fits in general are considered risky when leverage (debt/equity in that case) reaches one to one, Four to six is more typical. Not ten to one, Banks invest in loans, which ate safer. But not ton times safe. Fow people today would risk their money in hank deposits without federal deposit insurance. Yiy awn reading of history finds that depasit-and-lend banks have failed systemically, ar needed baflouts, about once: er generation since they were innovated in Marco Polo's tine. They filer hese Bowers default in high wins, and lefaults are nragnifiee Len fol in effects vn stockhoklers’ investment, We rebuilt them, and the enfold leverage, because we blamed tbe high winds ritber than the rickety structure, The Practical Pig koew better. It began occurring to me in the mid 905 that tutual funds might replace bank deposits, and deal with the tightrope problem too. Too much money burus holes in Pockets today because money carns nothing while we hold it. Mutual funds pay veturms, and are owmed for their own sake. IF their shares were somehow money. Jeople woul feel no finpatience to spend It and na supply would be tao much. | graiually figured oul how the abvious prablams in fungibility and divisibility and other maneyness qualities could be addressed. Chapier 1: Recollstiors 106/16 21 Mobelist Franco Modigliani Lieard of this, and invited me 1 MIT for a presentation. He talked like Gepetto in Disney's “Pinocchio”. There were a fev other top brains, including Ruddiger Doobusch and2julio Rotemburg, in the small classeoom where | spoke. Sometimes Modigliani interrupted. “Getty, you don'ta consider this.” "You forgeta that” | guess | thought 1 wasn't doing so well My tall: ended. and he and | ysere standing by a window. To lighten the mood, 1 said something about the Red Sax. (le said “Getty, getta papers on banka reforin every week. ¥aurs isa the fest” Milton Friedman, aovther nobelist, had 1 diffecent take, We bid given talks ala Calo Foundation symposium in San Francisco, He buted my ide. No great surprise, He had written that money ought to earn nothing so that we wouldn't own too tuck. Any arcempt to back money with anything be told me, would meet Job: Law's fate in the Mississippi bubble, The backing commodity would become inflated aod then crash. So Nobelists can disagree. My version of the same idea today loaks iest to ETE {exchange traded funds), which are more quid and moneg-Hie than mutual fonds. FTF are usually index funds, which replicats index holdings with no active management ani sa charge very small expense ratios. But mutual funds might becume money toa. My iiles, decd apposite from Friedman's, is that both money supply and money yield should be held us igh as possible. What would happen to hanks? jor angst, but not much damage. They would devolve into their separate deposit and lending specialties, with separate stockholders and only incidental interaction. Deposits would be invested in EUFs or ‘mutual funds. Federal deposit insurance would wither away as unneeded, There are 0 TunS on TE, Lending hanks would have to raise lands to lend from investors expectinga return, Tsthere.a downside? There bs certainly a visk of one. The devil we don't know is what would happen to lending rates and what the consequences might he. That had Chapier 1: Recollstiors 106/16 2 been one of Modigliani’s points in his interruptions. Federal deposit insurance subsidizes cheap money and keeps lending rates Jow. Most tradition associates easy ‘money vith growth and prosperity. Higher interest rates are associated with restraint in investment and consumption both, Modighani was right to worry. My guess is that the bank reform and money retorm | propose yrould drive borrowing casts up, horrowing volume down, and equity investment up to hil the gap. Carparations would issue new stock to retire corporate debt. Newlyweds wad rent, mal buy, Until thei incomes vere high enaugh bring other aptivns Modigliani was also worried that monetary policy woukl become impossible. It would is we know i, | have argued elsewhere that fiscid policy cu be made lo work aswell and as fast. And | will argue for an unusual and more direct form of monetaty policy. But no one knows. These concerns are reasous to go slow | think that the reforms [ describe are developing now, with no input from me, and will continue if they succeed Depasitars will he attracted aveay From banks to [£11 accounts of equal liquidity and full return, Federal depasit surance will not be atvantage enough ta hold them Tanks will get the: message and join the parade by spinning off their loan departments and investing depasits in BTBs. 17 Maligliani's valid conterns haven't found good answers, the parade will stop until they do. I could backtrack tv (ke starting point, The reforms believe in ought (6 work, but can be scrubbed without much mess if they don't. Jam not their only advocate. Others argue for splitting up commercial banks more or less as | would. Meanwhile many people maintain liquidity in EVV or mutual funds rather than banks. There may be some originality in putting the two reforms together, This prersanal accmnt can end with more thoughts hou my father. My stepmother Teddy's tovehing hoak about their inarriage. auta couple of years aga, tls the truth, the whole truth and nothing hut the Truth. That what she does. He seems not to have Chapier 1: Recollstiors 106/16 23 been the easiest guy (0 be married lo, He pinched pennies, went on trips while she held up the home frou, came home late. My mother had about the same story, But | saw different sides of him at different times and places. Twice | saw bim cry, Once we were listening to a Caruso record. He might well have heard Caruso, although | don't recall that he said 50. He vould already have been 26 when Caruso last sang at the Mez. One ofthe twa hooks he wrote hy himself shows Wien as an apera buff sehen on bis awn in Gennany in the 1930s. le wrote what operas hie hal hard, wha sang, ani wha he liked. My mther said the same. Once they arrived late at a performance of La Boheme somewhere on the Riviera, could fi a program, liked Lhe tenor, decided Lo help him, and learned thal they bad failed 10 recognize Beniamino Gigi. ‘the otber time veas abous bis and Teddy's son Timmy. Timey's brain tumor was inoperable and growing. He was 13. The doctors had told them to prepare tor the worst, We wece in London, he papers said something about young toughs called “Teddy boys. My father started crying. Timmy wouldn't make it, and the Teddy boys would. Tene Jost san mysell. Vou thank the graces far what's left Lo do. Whats Jol bn dw includes campasing, verse and econvmics. The first has panned out okay. A fair bil of the verse wis sel in Ue music. AUleast Ural makes iL read sod beard, Aside from the kind words of Modiglians and x few others, Lcan'Usay as much for my economics. So here goes again. Chapier 1: Recollstiors 106/16 2 CHAPTER 2: EAST FORWARD 1 dropped the course on economics because { couldn't see the foundations. Not that they should be clear from the start. That isn't how the mind works, We see, do and amderstand in that order. The pyramids Tose four thousand years before people like Galileo and Newton found the laws that made them possible. Practice comes first, and selence last. Science Is ahstractian from the particular t the general ts fesver rules predicting more putcomes more exactly, The pyramid builders kinew miles fr this kind af stare and that kind of aod or rape. Newton gave rules for mass and fre, Those are nol articular things ike stink anil wand and rope. They are quits ofall things. Their rulis ace wugher Wo gel aur minds around, bul predict everywhere once we lo. What book or course should offer from the start, even betore the foundations, is an inkling that it should be worth inishing. We have to sense that we're on to something. The price of getting there will be the nuisance of abstraction from things 10 qualities, and we necd t see a reasan ta pay it. 1 didn't in the course on economics. ows it's my urn. Pliny a Gast farsward through (ree growth Ueary and my ther arguments Lo give an idea where we're headwl snd why it matiers, The foundations and then be slower tour will follow. Free Growth What call (ree growl heory will probably coun as the chiel surprise, a least lo non-economists, because the argument and the supporting evidence call for a major reversal in tax policy of this and other nations. But itis not original. John Stuart Mul wrote the same idea in his Principles of Political Economy in 1648. | will quote what he sald in my Chapter 4. Although Principles became a leading texthook for decades, the paragraph 1 quote seems ta have been overlooked. Reanmic Wistarians including Joseph Schumpeter dessribe Him as a champion of growth thigh bell- tightening, The paragraph | will quote makes the opposite lear. We now hive means 1a prove his ir. Twill shaw haw: Wo Lest it and will shaw Lest resulls in charts and Lables Uaking up about 20% of this book. They imply that tix Jaws Chapier 2: Fast Forwaud 106/16 1 eacouraging investment over consumption 4nd plowback over dividends. particularly in the Last half century, have Jed to dangerous overinvestment in the private sector. The empty eyesores and bulldozer bills of 2008 are symptoms of pro- investment policies founded in many countries ater World War I. They did no harm when the world needed rebuilding anyhow. But | suggest that autput grawth slowed because of them, not despite them, after 1970 or sa. 1 will argue that optimal investment al the national scale, strange as lLsaunds, is depreciation plowlack and nothing mare. Mill showed how that could be true. The sane geowth will arrive, say ani Land he hers and Lables, sith ta consumption sacrificed. Mare: consumption al na cost L growth ailds up Lb more output, Output nosed dawn since 1970 or so becuse we squelched consumption lo no purpose. hat means oly private sector overinvestment, prompted by unwise tax motives, and only at the collective seale. Government follows ditferent motives, and has somehow followed them to an apposite problen in this country. Gur infrastructure Tusts and crumbles. It seems that our gand friends in the Tea Party think that roads anil britges undercut market freedom. Growth is interesting, even withou! these opposite distortions, because bistory is interesting, Growth is our history. is not the history of other creatures, who repeal norms from generation to generation once evolved. That's why the math of Hamilton's rule doest’t work, And we care sboul it because there are ecnotional and moral and belly issues attached. | gave an idea of its dangers in the foreword. The past has proved suvivable, The future has tot. Then what about ts cost? Docs faster growth need consumption restraint at the stan? Is ta reward for sacrifice? “That's what Mill tried ta answer n 1845. Te started with Une idea tial pulp, meaning creativn of capital, must mean growth af capital (“investment”) plus consumption, will call this the Y=11€ for Y=C11} exquatian frum Lhe stands d nolatinn econmists use. 1 will argue that it is ve with two adjustments. Investment must include investment in buon capital, and Chapier 2: Fast Forwaud 106/16 2 consumption must exclude any schooling or nurture alceady counted in thal investment. (Schooling counts as consumption.) Mill would have understood the human capital concept, defined by Sir William Petty nearly two centuries before, but economists only recently have began to sake it seriously. Mill's meaning of the Y= C+ 1 equation, and the one accepted everywhere in macroeconomics even today, Jeaves out the grassth in huinan capital and includes all consumption. That equation, which [wll Ly to prave carrect If we make the twa adjustments, shows that less consumption brings fester growth ilautput halis still But athing in the eauation says 1 will. Tsiays that less consumption means either more growth or less ouipul. [doesn say which. Joho Maynard Keynes, probably the most famous and influential economist of he 20 century, put this fact of math a special way in his General Theory of 1936. In his aualysis, saving through less consumption is cither invested or not. Since output is consumption plus investment, saving minvested is so much less utput. 1 like to pat the same idea with a range of degrees. All saving is invested. as 1 usc the sword, hut finds different returns, Saving under the malls is invest ment at era eturn, and drops putpul just as Keynes said. Tovestimenl at the current average relurn keeps output unchanged That's what Keynes meant. Bub investment at lower returns lowers output, and conversely. Keynes’ version sees intended saving (consumption restraint} as either invested or not, and sees it as translated dollar for dollar into actual capical growth if itis, Mine allows way degree of capital growth below or above the actual cost of investment in consumption given up. “This is a Surprising concept, either in Keynes’ version or mine, because it seers to. fight personal experience. Until the next ralse or Joh change ar layoff, aur incomes soem ta be known quantities. INwe skip desert, and watch TV instead of galng ta the movies, we ar pul mor in the bank. AL lwast aur incomes will not drap because we sived those costs, But itis different for all of us collectively, When Whe whole nation saves ani either does not invest wr invests less prouctively, output drops. Keynes’ analysis says (be same, but leaves vul the “less productively”, Chapier 2: Fast Forwaud 106/16 3 My reading of the Mill parageaph says that if we plowed back ouly depreciation investment, without invading consumption for more, we would stil grow it that investment paid oft in higher returns than the current norm. Then capital would grow faster without making consumption grow slower. The gain in output, even though we had invested only enaugh ta make up for depreciation while keeping carsumption the same, vauld have bien split in some far capital growth and some for mare consumptinn. And Mill gave the reason for the gain in autput, The driver was “whatever increases Une productive poser of Tah. Ue was king about better ides, We would mike returns higher if we could mike capital more productive al the same cosl. This possibility troubled Nobelist Robert Solow, who came reluctantly to a conclusion most of the way toward Mill's a century later. He felt that growth should not be a gratuitous deus ex machin arriving at its own whit. How cauld Mother Nature say "Shazam” and turn less int mare whenever new frcas come along? Didi the capital chicken have ta graw before the mulpul gg? Didn't ve have bo tighten Dells 1 invest in nes plant applying those new ideas? Bul the wwidwnce seemed 10 say that the rise in ouput came firsl. Rise in capital followed. Thrill seemed 10 play little role. Tests by others have tended to find the sume (hing since. My own tests, using new data from national accounts and my own ew testing method shows in my charts and Lables, reduces he role of thrifl Lo zero. How could thatbe? How could better kinds of capital arvive without costing more, at least at the start, than the kinds we already knew? My best guess is that the cost of innovation in failure rates and learning curves is the cost of being human, that. vie pay it abit the sme every day, and hat growth happens when the warlh of innovation praves more than the cost, J can because swe are human, The cost of being human means the cast nT adapting. fLis how we cape. We Lurned in our Tangs and fur in exchange for the savvy Lo make tovls wad fire and clothing do beter. Other creatures wlapl Chapier 2: Fast Forwaud 106/16 p 100, but we became the specialists. Adplation grades into innovation whenever it somehow becomes a norm. That too happens with other creatures, but not as often or as lastingly. Their new norms almost always revert to the old ones, Oe innovations collect and accrue. That's why growth is our history. 1s costs are allure: rates and learning curves. Mang fonavations are blind alleys, and most athers inked shakedown rns. Rub were stuck with rose ss Ui cast ol heing Iman And were stuck with them whether the result right nw 5 growth or not. They were our cist of survival during aur millian years as bom erectus, when the archeological record shasws litle averall change in the stone tous we mate, Growth aol lusting innovation picked up marginally wih the emergence of Ancestral Eve and bigger brains about 200,000 years ago, and began accelerating about 50.000 years ago. Growth happened because the more or less constant cost of adaptation. and innovation became less than the payoft. New ideas tinally tound traction at no added cost. Mill's idea was that more payalt in growth need not presuppose mare saerifee. Does tat mean that all wy nee fo growth is ew ideas and the courage ta Lust them? Well, no, We sill have ta plow back depreciation as the cost of holding even. We need practical savvy and patience loo. Somelimes great new leas must wail for an opening, That may be why our bigger brains showed lide effect ou the Kinds of 100ls we made unti) about S0,000 years ago. And | will argue thal innovations need Jaws and customs that welcome them, Otherwise they will make a few bucks for the Jocal warlord rather than yeealth for the originator and the world, But what they don't need, say Mill and J and the data, is tighter belts. Adam Smith, In his Wealth of Nations published in 1776, propose growth by belt tightening. Mast Lradition hs agreed, with Une proviso that nw ins must ome. first Solow raised doubls about Use role of consumption restraiot, but stopped short oF lenying a need far iL Mill acknawledged bath ways to grow. My charts and Lables will confirm that only (he kind UL troubled Solow bas actully happened, in every Chapier 2: Fast Forwaud 106/16 g country and period tested. | call free growin. My own free growth theory acknowledges groveth by consumption restraint, which I call thrift, only as a ‘mathematical possibility which doesn't seem to happen. So my idea, taking account of data Mill did't have, is different from his. | MUSE be careful Rot to put my ideas in his mouth. When | say “Mill's idea, From now on, | will mean some of hoth. Na ore had Ue tata Lo grove him right until national aceaunts began reporting market-valued capital in 1990 or so, and reconstructing it for a fw decades before. What they ad ear wars Une hiok measures af capital thal we: see in balance sheets. They don't reveal enough. Baok measures assuone depreciation norms. Gulcomes converge Lo norms over Lime, bul meanwhile might be anything, National accounts follow a form of this book or depreciation accounting, They now report ‘market-valued capital too, but till prefer book methods to calculate investment | and output ¥ in the ¥ = C + [ equation. That doesn't work well. id you know that national accounts in lreance, Germany, U.K. and the United States al) reparted Dositive net investment in the crash years 1929, 1930, 1937 and 20062 Net investment, muaning nel af vepreciation, is infeed bn show growth in capital value, Do you think values really went up in Use cash years? And national accounts can be just is wrong in the opposile direction. In the boom year 1933, when stock mackels were up 42%, 67%, 96% and 46% in those four counteies, Germany nd US, reported net investment (capital groveeb] as negative while France and UK, reported it up less than hall « percent, All this shows in my chiuts and tables, Reports of net investment in national accounts tend to prove radically wrong it years of unexpected upturn or downturn because they dons get the news of wars or national disasters or discoveries or business cycles until new assets are hought or new products sold. Purchases and sales are normally the pay input into the hooks. Average time between ariginal purchase and realization in sales Is the "holding period” or “urnover period” of capital. Far all physical capital together, it runs several years. Accounts in those stump years were reporting the god news of boom years sharlly before, including the bans if 1933 as well a 1933 preceding the sump year 1937, Accounts in Ube boom year 1933 were finally gelling the news of Chapier 2: Fast Forwaud 106/16 & the crash. {Yes, some of the strongest booun years in history came during the world depression.) his is 10% to question the need for national accounts. We could not manage without them. But the genius of accountancy is in its reporting of cash How items. Depreciation, even its sophisticated farm used in national accounts, i a makeshift agproximation better than nathing, 1 argue that itis obsaletert by aur access fo market-valued capital appearing in the last few decades. Mill's cgumment was that capital growth might be explained by produttivily gain as wells by theifl in deferred consumption, The way o lest between then at vill describe takes mesurements of market-valued capital, its year-to-year change in these, and consumption atthe same time. | call it the simultaneous rates method. In any year and country where consumption restraint explains growth, although the data show none, isc in growth rate would equal current drop in consumption rate: {consumption /capital) while rate of return {output/capital) holds unchanged. When rucductivily gain is the explanatian, as the data confirm sa far, iL is cansumptian rate hat holds the same while growth vate and return vise epually, That's what { test, Dit in chet and Lables for hose four nations from 1870 through 2010, and from Australia, Canada, aly and [apn from 1970 through 2010, show that faster capital growth colucides with higher consumption rates in the same year as often as nol Less consumplion his simply meant less outpul will 0 growth to show for iL. Thats the sense in which growth is free, “hese countries and periods are not chemy-picked to support Mill's dea. They are all 1 have found. My source for natinal accounts including market valued capital was the viehsite of Thanias Piketty and Gable) Zucman adjusting thelr data ta nifarm acenminting standards and measuring em in 2010 surrency units. Lalo cullects recent and pit research by other economists modeling what national accounts again including aceunts of market-valued capital, wild have shown in years before they were founded io 1930 or so. Simon Kuznets, for example, who Chapier 2: Fast Forwaud 106/16 7 founded the national sccouals in the 1920s and reorganized hem dong Keynesian lines when the General Theory veas published, reconstructed them back to 1870 for the US. economy. Piketty and Zucman incorporate this research and others. They have acted as editors only. As a layman, 1 would hardly be qualified to find and interpret original sources. Even most ccanomists might lack that specialty. | simply trust Picketty and Zeman. They will have compounded misrcatings and editors’ Wis in those: sources hy achfing their awn, and 1 will have ade mine. They and I have plenty. Rating is bias hy definition. But we can't do without It We manage as best we: an. To mike sure, [so est Mill's ied on stock marked dala from the same nalions and periods. Here my source was the Glabal financial Data website marketed by Bloomberg. Market cap corresponds to capital, dividend yield to consumption and total return to output. Charts and tables show free growth as essentially all of growth in stock markets too. Nave ry a first look at the charts and tables. The loli pop-shaped Greek letter @ {phi is something [ call the [ree growth index. [reads Lin years when grow(l is explained as Mill described, 0 in years when belt-tghtening was the explanation, and something iv: between when theve was both. The free growth index will be explained in chapters 4 and 5. The charts can be messy, and the data jumps around. “there are spikes, both up and down, which tend to disappear in the charts which screen aut small absolute values of the denominatar (capital acceleration). But the fro roveth index clearly jumps around 1, nad zero, both befinre ar alter the screening IL is as often above 1 as bela, Thal means that growth is as likely to coincide with belt-lovsening as bell-lightening, My ree website Frestirowth&0therSurprises.org shows how everything was calculated. Economists will not be as surprised as they might bave been a century ago. Growth theory since Solow's revolutionary papers in 1936 and 1957 has marginalized Chapier 2: Fast Forwaud 106/16 3 capital accumulation or brill, and his seen most growth i the national scale as “exogenous” or unexplained by whatever we suppose that we give up in exchange. This book takes the next step in the same dicection. The role of thritt is zero. It is politicians, not economists, who will be Rumemoxed. The double tox and the tax reference for capital gains ave examples of policies favoring investment aver cansunption to benefit growth, The record shows no such benefit in any country ever. Pram all evident si far, free growth they is free grinwth Fact. A New Way to Measure What this hook ries to add is no only the next step in Solow's direction, by simultaneous rales method offers a new means of testing. Twentieth century growth theory, led first by Keynes’ colleague Sir [toy Harrod and then by Solow, has tried to gauge the effectiveness of consumption vestraiot by a different method from Mill's and mine. It has looked for effects on later output rather than on current capital growth | coll it the lagged Haws methad. Why the lag? Because itoutput is grovith of wealth (capital) plus consumption, a shift froin the third ta the second cannot change outgut al the same: time. Rather output should Tene afl a lag of a fev years for the capital thal produces it W accumulate, Capital investment plants a Lree. worl output growth is the new fruit expected to follow, “the Jagged flow method makes sense, and theve was nothing better until data for markel-valued capital began appearing in 1990 or so. Bul the lag Lends to blur causality. Later changes io output could have later causes. And output itsels, after the lag, could not be measured reliably for lack of the same data. It has been measured a5 gross ar net domestic product, reported as the sum of consumption and book investment. Books don't get the news until new assets are bought or new products sold. We Just saw the anomalaus hook results roparted for 1929, 1930, 1933 {thet opposite distartion), 1937 anil 2008. Thase are nal the poly exam ples. My ‘method measures oulpul as consumption plas change in market-vatued capital. It sewn Lo me thal Pikelly and Zucimar ought ta ave shows outgul this way, at least asan dtervalive version. [sn'Uil inconsistent 1o measure capital al marke, bul fo Chapier 2: Fast Forwaud 106/16 9 measure its chioge (net investment) al book? And isi 1 better Lo measure the effectiveness of thrift with neither the lag nor the well-known problems of book depreciation? Iwill show the math of my simultaneous rates method in Chapters 4 and 5. Chapter 4rcasons from the Y=C +1 equation, even though {don't accept it, while Chapter 5 ransates findings int Use sew version {di acuept. Charts and Lables show hth wersians for al eight countries reported, over all years reported, and run the avurages. The Uri indies, or ratin of the supguised cost Lo actual grab, averages zero. 1 found it hes a shaw separate chiar or each country by each of the La versions of he Y - € + [equation dd by each of three levels of denominator screening (none, then two progressively wider screens). Other charts track other data that seemed informative. That explains why charts take up so much of this book. This completes ty Ast survey of ree growth theory and its support (n the data. Chapters 4 and 5 will covar Une same ground again fram nos: perspectives. So it will he wilh other hemes of this book and ather chapters. My problem is to sell unfamiliar ideas, although not necessarily new boss, and in somewbal unfamiliar Tunguage oo. My “simultaneous rites method”, yet (o be clarified is an example. nse the standard language of economics where | can, but must sometimes tweak words or coin them. We will see hat in Chaper 3.1 ey 10 cope wilh thal double challenge - unusual ideas in unusual terens - by the same strategy of restatement from new perspectives until all fits together. Fixing the Y=1+C Equation 11 had ang sense Twwauld pretend 1a accept the ¥ =1+ C equatian as Mill and all aher wennomists seer Wo do. Ther 1 ould have done with wl hall as many harks, nil made Uns a bok about free growth only. Ang fool knuws thal & hook should pick facus. Thie data confirming MiP idea would have mad a spectacular ale Why undermine my awn case by questioning his assumptions? Sa should probably Chapior 2: Fast Forwaed 170616 10 have played dumb and quil ahead. Bul thal would have left out half the story snd all the other surprises. confessed that the surprises are the features | can't resist, If they are fun for we, {can aceept the challenge of making thew fun for the reader. Anyway, | already opened that can of worms by showing that | don't accept the ¥=1+( equation even though others do. | gave an idea why, and can sketeh my reason outa litte farther. Tt beging with something I call the tatal return rule or total retarn trulsm, The truism is Uhl creation of value equals growth of value plus cash flow, where ash ow means value Laken out Tess vue inserted from outside, Tan’ think anyone doubls this \ruism, whicl is fundamental everywhere every day in the investment world. Lwill prove it anyhow, just for good measure, in the next chapter. tis probably the reason thatthe ¥ = C + { equation is readily accepted. Net investment | is meant to show physical capital growth. It could look to be the groveth im valu, if we don't consider human capital, and consumption €. could lon to be the value taken aut. Tut a second lok is needled, The logic doesn't work unless we consider all value including human capital. Some consumption is invested in human capital. aod only he rest exis the whole economy in satisfying Lastes. Then he equation would sill be true if the invested part of consumption equaled human capital growth. The reason why it doesn't starts with what we already know about human capital. Petty in 1664 had hi on the idea of this as thue-disconnted fuzure itetime pay. Adam Smith in 1776 saw it equivalently as accumulated past investment in narture and schooling, The Americans Irving Fisher and Frank Knight revived bath ideas fn the carly 200 century. The tempa picked up after World War If at the University of Chivas. Jacoh Mincer vedirive Fisher's present value equation in 1958, and ‘modeled investment in human capital through job raining, Nobelisis Theodove Schull and Gary Becker soan inl in. New insights includ Une realization Ul human capital grows (rom the sell-invested work of learning, as well as the oulside Chapier 2: Fast Forwaud 106/16 1 input of nurture od schooling, aod tien depreciates gradually to zero just 5 buildings do. Yoram Ben-l'orath combined these ideas and more in a masterly life- eyele model published in 1967. We'll get to it soon. Schultz called the part of consumption exhausted in taste satisfaction “pure cansumption”. The part invested in human capital was “pure ivestment”. | change tha ta “vested consurm pian” La avid confusion with investment in physical capital. Since there Is no settled tern for the part of work Invested in learning, 1 call in "sell-investied work”. 1 call the art af viark soll far pay realized work”, Then the consensus view forme! in the 1960s held that human capital growth eral invested consumption plus sell-invested work less human depreciation. | agree, with a clarification as to possible deadweight loss that [1] come o in Chapter 6.1 call tthe Ben-Porath equation, although be drew it from the Schultz-led consensus. It is really a summary of the first four of the equations in his 1967 paper taken together. This explains my critique af the ¥ = 14+ C equation. The equation would he true if human capital gravth equaled invested consumption. In fact it equals tal, plus self- vested work less human depreciation. The trrected weuation sould read “output equals consumption plus investment plus selfinvested work less human depreciation”, | call this the *Y rule Upending the ¥ - 1 + C equation is big news, Macroeconomics and the national accounts are founded on it, 1hat's one reason, although not the main one, why | think that macroeconomics should start over. It docsi't follow that national accounts in themselves need much change, aside from reporting net investment at market as well a5 at baok, because COUNTIES must measure what they can Mumian depreclation and self-nvested work clude market measurement. Rot ecanomists Gan allows for therm, and they are huge Noss. Taman depreciation is depreciation of the larger (actor. And sell-iovested work includes more than Tea ning. Ben-Parath shined, as we will see, thal iL equals all grant in human capital mot explained by inflows of nurture xd schooling less oulows in bumao Chapior 2: Fast Forwaed 106/16 12 depreciation. Tha implies tt i includes l free growth of We larger fuclor, And these huge flows would figure to be wicorrelated. Depreciation of either factor is a steady drag on growth, while free growth is revealed in the charts and tables as a bucking bronco which might be double-digit positive ane year and double-digit negative the next. No wander that national accounts cannot reliably tell good years from had. Anather distortion In the Y=[+C equation is the undue jromincnce given to cansumption. Physical capital, in mast views including mine, is ly a third la a iflh af wtal including human capital. Tuma capiiz] is the lion's share, Pure consumplion is mosL of conswmplion, in my view, bul not all of consumption. I the factors grow in enutual proportion, then, the ratio of total capital growth to pure. consumption wil be much bigher than of net investment to all of consumption, That explains, think, why national accounts have reported not a single year of negative net product in any of the cight countries since inception. Balanced portfalios report negative tatal remrns every few years. Sa would net product, sere ft nat dominated artificially by the steady positive of consumption. is as if a partfolio dominated hy investment grade bonds were Uaken as reprisentative of a realistically balanced portfolio. Solving the Age-Wage Iuzzle Jveill nove ey Lo solve a feature (hat troubled Ben-Porath snd bas troubled many economists since, | call ix the age-wage puzzle. Age-wage profiles are published reports comparing pay eared by all working ages at the same time. Since all cohorts (same-age sets] are compared at once, as in a tawily portrait, age-wage Irofiies do not show cftects of technological growth over thne. They show effects of age and experience alone. What appears s that pay ir wage rises steadily until retirement. ar avar iL Msmvhile human capital is present value uf remaining lifetime pay, and shrinks steadily 5 approsching relirement aud mortality leaves fier future payelays Uo discount, Most stants of human capital including Ren Doral reason thal sell-investment must end when lime fl for recovery in higher Chapior 2: Fast Forwaed 1406116 13 future pay runs oul. So do L. The puzele is bow pay coukd ise while human capital shrinks smoothly to zero, “his would not bea puzzle if ve were speaking of ofl wells whose oil might continue to he pumped outat a steady or cue rising rate until the well ean dry. We are zed because pay is generally believed ta equal and compensate work. Wark mass the aubput of human capital. Tow could less capital steadily produce: mare output, meaning creation as distinet from depletion af value, particularly If sane wark is sell-inwestied rather Unan marked for pay? Thal waull imply exponentially rising productivity, meaning mle of return, and rising Lo infinity al the end. Think about iL. Strictly speaking, buman capital is present value of future pay less spending on future childhood nurture plus textbooks or tuition or job training {collectively called “schooling” by Vineet) invested in human capital. Ben-Porath Knew that, as had others before, but reasoned that investment in anything must stop when not enaugh thie remains for recovery. 1 think sa tao. And {argue anghaw, from observation rather ian Ing, that invested nurture and schooling substantially end when we enter the full-time job market sometime in vur twenties. Then human capital in adulthood is essentially present value of expected pay, or even less if Bea-Lorath and L are wrong and nurture or schooling continues Lo the end. When only a year of pay is left ahead of us, human capital at most is time- discounted present value of one year’s pay. When one day is lel, iL is al most present value of one day's pay. Yet age-wage profiles show pay (wage) holdiug level, or even rising, as human capital grades smoothly to zero, This is the famous age- wage puzzle. Pl Hesh out the same thought experiment later in what {call the parable of the boss and her secretary. Tonamists have recently prapaser salulivns which [see as farfetched. Possibilities thal human capital inieed grows nore productive with age, or depreciate dl 1 ance, seem implausible ir each ase aml Gonnol begin W wxplain uraugh. 1 think Becker hinted at the answer in 1964. Becker pointed aut tbat job training at the Chapior 2: Fast Forwaed 1406116 1 employers’ expense is par of investment in human capital, wd reasoned (hal employers won't pay it unless they expect eventual recovery with interest. What Hecker stepped short of saying is that the same is true of any investment in anything by anyone. When we invest for our own henefit, we expect recovery by ourselves. When we hvvest far the sake af others, we expect recovery hy them, Rescinvery means resovery of degreiatian. Our parents would nol have invested in our han capital withaut expected recovery of aur human depreciatian by us, and the yang Further invest the wark af Teaming in themselves beciise they expect that 10 be recovered with interest as well, There is another proof which call the deadweight loss rule, Capital of any kind is presentvalue of cash flow, meaning expected realizations in transfer or taste satistaction, Deadweight loss means decapitalization with neither. tt follows that deadweight loss, although a common reality, is implicitly unexpected. But human depreciation, like plant depreciation, is expected from first investment. That rales out dedsveight loss, and makes hwman depreciation expected as cash flow by elimination af alternatives. Each proof is sufficient, The first expresses what | call the maximand rule: we ‘maximize risk-adjusted rate of teturn. Robert Turgot observed this in 1766. 11) say more about that in (he next chapter. 1 takes ite thought Lo realize (bat musimiziog risk-adjusted return begins with recovery of investment, and that this means recovery of depreciation or amortization. We are depleted like the oil well, although we create value too. The second proatnceds only the assumption that human depreciation 1s kareseen. It adds the specification that human depreciation fs realized in foumvan cash ow. That Wins wat 1a man that tis realized in pay. The salution bs the age-wage puzzle is thal pay das nol enal and compensate realiznd work above. IL compensates (hat plus human depreciation. [call this the “pay rule’. Chapier 2: Fast Forwaud 170616 15 The pay rule joins free growls theory and the ¥ rule as the tree major suprises promised in my title. Recovery of human depreciation in pay changes a Jot of equations. It docs not impact public policy and tax laws as radically as free growth theory, but] will argue that t impacts them enough, Even Iie didn't its probably the most startling assertion in this baok from an ceonomist's viewpoint And although 1 naw knaw better than to afin originally for any idea i economics, this one just might pass he Les. IT someane out there knaws a precedent daser than Becker's, as eventually found anes for shat | had thaught were iy own free growth and next generation thenries, all the mare fan in finding tase unsuspected arcarsors. (Nest generation theory will be outlined soon.) And the twa proafs Jesve no doubl. will add a few more as we go. Ibis never overkill to drive another stake through the heart of entrenched misperception. Meanwhile we can already be assure of that expected recovery, not actual recovery, as of anything we know. The arguments trom the maximand rule (Tuegot's insight) and the deadweight loss rule are unanswerable. An analogy from samething else we all knaw leads to Une rest of my argument. Pay aver warking careers is something like payments over Une period ofa declining: balance mortgage. Mortgage payments are partly amortization and pally inleres!. Amortization is like depreciation, though without the same sense of physical wear and tear behind it, and interest is ike the worker's ouput marketed to employers, “The declining balance is like human capital. Mortgage payments are almost all interest at the start of the loan, when the declining balance is almost the whole loan amount, and then gradually less interest and more amortization as the balance shrinks. As the balance approaches ero at the end, the payment approaches all amortization while the interest share approaches 7¢ro, My deqrwciatian thenry, which well come Lo son, argues Wal depreciation fallaws the sme logicand the same math. [will wgue, in the face of whal his seeped o be contrary vvidunce, that depreciation of bith Faitars Iegins al era and grows Chapier 2: Fast Forwaud 106/16 16 exponentially o become al of cash love al the end. This completes the explanation of age-wage profiles as we see them. Pay is all buman depreciation at the end, What! Thought Once Chapter 6 well compare accounting for human capital to accounting For a frm. Pay, in this analogy, fs the worker's revenue. The inn deducts outside aperating costs af Tahir and supplies Lo leave: grass realized output. The analogy for human cipital would be maltenance consumption enabling life and activity. But] don't deduct thisin reaching Lhe workers’ gross realize out pul (gross realized work) because Take it as pact of the ned pulpal we intend in itself rather than a cost in retusa for whi we intend. [see astult consumption as mainly Schull’ pure consumplion exliausted from the universe of capital, including husan capital, in satisfying our taste for adult survival. Opinion is divided here. Some cconamists have treated the maintenance camsumption that keeps workers going as new fvestment fn human capital for the sake of higher pay in futures Some in the 16 century expensed i, like: maintenance in the firm, ax a cast recovervil in keeping up Ue workers revenue (pay) now, rather (an invested for later. ) did hat for years. [now treat it as recovered neither in pay now nor pay Luter. Even though we couldnt earn without it | count in pure consumption exhausted in satisfying tastes for survival, When [ thought it was recovered in pay and work products, up to about five years ago, realized that human depreciation could not also be. There would be nothing Jeft for pure consumption except Mill's "unproductive consumption” neither replacing nor maintaining human capital. That would stand bialogy on its head. Binagy Is precisely about replacing and maintaining us. Tnpraductive consamptian, Tov whith ther seein Lo be parallels in ober species, is something biology his yet 1 Justify JL caonol be the unique taste satisfaction tht behavior reveals. Chapier 2: Fast Forwaud 106/16 17 1found & solution thal seemed 1 make sense then, [Lwas the exact opposite of what J think now. (f maintenance consumption were recovered in pay and work products, as now think buman depreciation but not maintenance consumption is, then human depreciation instead of maintenance consumption could he exhausted in taste satisfaction! That seemed less macabre to me then. Inked for ways in which Tnan deprecation, hardly the binlagical end in itself, could somehow be its measure Than nt unreasonable, T thought, by interpret human depreciation in aging as the cost of survival. The old gag says that aging I not so bad when you think ahout the alternative Age-wage profiles could be explained, {thought ther, ax recovery of maintenance consumption rather than of human depreciation in pay. And Ia Whose precedents from Lhe 168% century. {knew thal Francois Quesniy and the physiocrats, in Adam Smith's time, had argued too that consumption could be recovered in earnings. ¥ill could be interpreted that way, in bis definition of “productive consumption”, as could Picro Sratfa in a paper from 1960. thought | was on the right track. What brought me Ly my senses was the thought experiment ahout a boss amd her secretary [ mentioned earlier. Pictury hen together at the beginning of the last year af huni cipitid for each. The bass earns len limes as much, Hum capital for each 3 one year's pay, or even less in the unlikely case that invested consumption continues to the end, less one year's discount. If pay measured work, rate of return {ovork/human capitil) would be some hing aves 100% per year for each. It would be even more in the unlikely case that some work remains unrealized {self invested) until the end. Yet their time preferences measured by return to their other investments, say secnitics, is less than a tenth as much. This already states pretty clearly that pay covers more than work. To cans her was dab, go ari a the beginning of the last thay. Age-wage profiles show hal pay far each is about whial il was « year before, Rale of relurn (o each is ns a little over 100% per day. A the beginning of he lasL secon, iL is a litle aver 100% per second. Al tbe end of the last second iL is infinite, Yel lhe securities in Ueir Chapier 2: Fast Forwaud 106/16 13 portfolios are chosen or returns no higher and riskier than the year before, They will tend in fact to be lower, judging from logic and evidence for a decline in risk tolerance sith age. “Then what hesides work is recovered in pay? The twa possibilities [was weighing were maintenance consumption and human deprecation. The winner was abviaus. The higher-paid usually consume more, hut not always and satin proportion, The fact that we must generally he paid enough ta cover consamption does not ply thal vie are: pic Ly comssame, Wee ace motivated Ln do thal anyon. We: are paid la aaply skills, ancl are paid in proportion to sills applied. man capital is skill sels. Pay measures ils Uransfer Lo products, whether in realized work currently created or from capital in place through human depreciation. “that’s how 1 came to the pay rule. We soc why it ought to startle economists. Macroceonamic tradition teaches the doctrine that wage measures work, and teaches it so confidently that ft uses the notation W for either. uma capital tradition recognizes that some work is self-investid, but effectively Lreats human dupreciation as deariesight Joss, That's why 1 use “pay” in place of the more usual “wage”. Refuting a Piketty Argument “There re practical uses for the pay rule aside (rom solution of the age-wage problem. These are the impact or, tax Javes and public policy that { promised. Piketty has shoven corvectly that the ratio of pay to net profit rose substantially during the world wars, world depression and welfare state period following, and has declined since. Piketty argues for higher capita) taxes in cansequence. lis argument folios tradition in comparing pay and net prafitas the shares af workers and investors in incame. Bul tradition is wrong. Pay ix the worker's grass realized income, meaning gross af human depreciation. Depreciation, for either factor, isa steadier Qow, This makes gross out ul for wither less responsive Lo uptarns and downturns. [Lis a particulily high share of realized income or output in hard times when dislocation Chapier 2: Fast Forwaud 106/16 19 ofboth factors (human and physical capital) drives net output down, Comparison between net income and gross realized income can mislead. Piketty is right about the data, but wrong about irs interpretation. Depreciation Theory This is the explanation | pramiscd when sald that depreciation fs essentially like amoriizatian. Acwounting Lends Ln practice straight-line depreciation over stand depreciation periads. A well-lmawn refinement, allowed but not nuh practiced in Business, is talled current ost accminting. The idea is to corre istortinns due to ast inflation. The problem is thal books reflect longterm assets and their depreciation al original cost at date of booking, Currenl cost accounting adjusts both 10 the equivalent in current dollars. Lt shows both net worth and depreciation as higher if prices inflated since booking, or lower if prices deflated. That seems to ‘make sense. A further adjustment called replacement cast accounting docs the same, hut alsa rupees linear depreciation with a curve believed more realistic. National accaunts ardopt this method, (Lis sound in principle. But they stipe the curve in the won direction, They rely un records of uctual sales of plant 10 model depreciation as steep initially and slower later. | suggest that bis record is misleadiog. My starting point is thal value of any capital is discounted cash flow, To keep things simple at first, suppose that cash How in constant dollars is expected to hold steady for titty years before asset lite ends. Also suppose a constant time discount rate. Present value at the outset Is fifty years of discounted cash low. At the beghinfng of the sccand year, tis 49 years present value of the same gash law at the same: discount rate. All ral is been Tost is prose vate of the 50% and most-liscountisd yer. A the start of the third yeir, capital bas dropped again by present value of the 49 aml secand-mos, discounted year. Sa il continues until the end as the discount Chapier 2: Fast Forwaud 106/16 20 ‘period approaches zero, Depreciation increases absolutely each year, and increases even faster in ratio to capital. What | have just modeled is depreciation rising exponentially from zero at the start 102 maximum at the end. National accounts show the exact opposite. They show it decreasing exponentially fram a maximuin at the start, The reason for the difference is instructive. [would rather Last the present value frmula t show what assets are worth subjectively ta thelr owners. The national accounts prefer to trust evidence is Lo whl they are worth to others if sald. That's a solid methand toa if the evidence is likely 10 prove representative. 1 isn'L in cases where Liansactions are more likely lo have been driven by pressure lo sell than pressure Lo buy. Plant is generally tailored to purposes of its first owner, and not medwt to be resold. Mant sales tend to follow disappointing results. These are ikelier to come early as business plans are tiest tested. That could explain why evidence without logic has suggested that depreciation tends to start Rast and slow down with time. Twnuld recommend that national acount continue tracking actual sales as an indicator af ue depreciation curves, but limit the study tn rental buildings expected from the start 1o be resold several limes. | mean apartment buildings, oftice buildings and warehouses designed long standard lines. Many investors specialize in buying and selling these tradable assets for portiolio purposes. Pressure 10 buy snd pressure Lo sell lend Lo balance. J can testify that prices bic for them ave found either by discounted cash flow or internal rate of return {JRR) methods. [IRR is a variant of the same thing. A id price #5 modeled as the original negative cash flow in evaluating the prapased purchase. Then the positive cash lows at each year's end are mideled, and the discount rate Tourid which nets present valu of all Mins gether bo zero. This rate is judged competilive, Ube purchase goes ahead. This method was vriginated by Keynes in the Generat Theary ws his "marginal product of capital”. Chapier 2: Fast Forwaud 106/16 21 And repeat thal most other structures re nol mean o be resold. Productive plant is customized to original owners, Tract housing is not, but becomes adapted to them, Qriginal plant operators and homeowners typically expect to stay put. Most do. When they do, thelr own valuations arc higher than would likely be realized in sale. Owners’ valuations matter. Eeanomics is move than prediction of sales prices. It is Irediction of behavior. Tis the owner's valuation af an asset, nota hypothetical outsile valuatinn, thal. predicts whit Te will do Lo split and defend it, My depreciation thenry dae nol jolt sel belie as fareibly as free grnwth theory ar the pay rule and ¥ rule do. [contradicts aoly a minor feature of the natin) accounts. Bul it contradicts hat diametrically, and adds clarity o te pay cule Loo, [U 5 also original as fac as | know. Who has said such a thing before? All the more fun and satisfaction in finding out and setting the record straight, There are giauts out there, whether | ever make it to their shoulders or not, and economic history means identifying them Retirement Theory Retirement generally means the period or first moment when people end the. careers for which their raining has been specialized, The reason is Lypiclly not diminished skills and performance just yel, as age-wage profiles show na litle or no drop in pay toveard the end. | think it is more that we and our bosses see the drop coming. Liceval pay is typically zero in retirement, Instead we carn imputed pay for taking. care of oursclves and one anothey, and for driving the grandkids to the 700. These services are tangible, not psychic, fn that they: save the hire of athens to do the same. The imputed pay Is what the othes would have charged. Tut it typically Is not. enmigh Wo meel aur consumylion needs Relies must Lypically draw dawn savings ar depentt on “sovial lransler payments’, meaning support from government or Family wr foundations, to make ends meel. Chapier 2: Fast Forwaud 106/16 2 Iu seems tha these infusions from savings or il cannot be interpreted as invested consumption to be recovered with interest later, but are rather pure consumption recovered nove in the satistaction of survival. Then human cash flow, or pay less invested consumption, remains positive to the end if we recognize imputed pay. Feonamists should, [ think, hecause it figures into predicting behavior as much as literal pay. So does psyehic pay. allows that human capital, mean ng present value ofall pay in the absence of invested consumption ta deduct, aontinues aller retirement. That shins Ural my parable uf the boss and her secrutary is oversioglified. Parables tend (0 be, The secrelary may hiuppen 1o hive beller skills as « full-time caregiver, which both she and the boss will igure Lo be in retirement, and so may reverse the disparity in ‘human capital then. All models, | guess, assume ceteris paribus (other things equal). My retirement theory leaves much unexplained It tries to throw a litle light here and there. | believe ft achieves some surprise, and even originality until we know heer, in my argument thal human capital cantinues afler retirement. Yel this follows directly from Ben-Parath, Tnvested consumption must end when time for recavery runs out, whether or not am right in ending iL wilh job entry decarles before, and human pital must Last as long as eral or imputed pay dos. The endurance of buman capital through to mortality is not logical certitude, but need not be doubled either. Retouching the Ben-Porath Model Ben-Paraths lite cycle model seems right enough in all features but one. Fquations in his 1967 paper ply that pay measures realized work alanc. This should be adjusted to show Ue pay rule. 1 would also model invested consumption as ending ainidependente, or a fess mnths Tater Lo alla far initial job Lining That tows nol contradict Ben-Porath, who leaves such a possibility open. wold further apply depreciation theary to matel human depreciation as grimving from a negligible share of pay al firs! employment Lo substantially all of pay at te eod. Chapier 2: Fast Forwaud 106/16 23 My model is the same as Beo-Uoratl's from birth to independence, All consumption and all work are invested, for modeling purposes, until schooling ends at full-time job entry. | model this transition at age 20. Pay, realized work, human depreciation and pure consumption all hagin at that point, althaugh human depreciation begins at essentially zero. Selfnvested wark continues as an hnportant but diminishing share of sari until Tate in carvers, just as in Ren-Porath. | differ from him mildly in tat [model all aul consumption as pure consumption. Ben-Porath allows adult invested consumption wilkoul issuing il regicd il as read bul negligible. Age-wage profiles are explained by self-invested work and depreciation theory alone, I model this scif-invested work as subliminal accumulation of job experience. My reason is persanal observation. What I have seen in plants and aHices is people working Full tine on the joh. We don't take time off ta learn. perience siaply arvives, neh as free growth does. 1 think thal my view an this contradicls Ben- Poratlys marginally. Te seems Lo allaw some such allocation of lime 1 lelp explain age-wage profiles. Next comes retiremeut. L model this as just shown, Later | will expand this model to include acquisition and disposal of physical capital Loo, The combined model will give most of the math and mechanics of next generation theory. Risk Theory Tor practical purpases, ccananie risk is usually measured as expected standard destation in rate of retin. Safer assets vary Joss from thelr return norms. Short- term Lrwsuries are thoughl safest because they combine fied nomial return with fast liquidity in case inflation threatens, The urarked overall bits safer expected outputs up anid viskier ames down, Since asset value is Ue deominator in rate of return, and oui pul the numerator, Ue effect is make risker assels bigher in retucn, Chapier 2: Fast Forwaud 106/16 2 Risk tolerance might be anything in any individual. As a norm, it tends to be a function of age, gender and wealth. Effects of age and gender ave better understood. Teens and young adults, particularly moles, seem readiest to take chances, Prison Populations and medal of honor rolls feature young males. Part of the explanation, | hil, Is Iologist R. A. Fisher's se ratio theary of 1930, ar equally oh Trivers” differential investment theory of 1971, Young males shiv greatest variance in sepraductive prospects. Females are abost always assured af a fess offspring. Young males might leave none ar many. Nature arranges our naments or displays bo ive fitter males the advanlage, Another reason is that the young, of either sex, have most time eft to outride downswings. The older we ger, the more risk-averse. Some businesses and assets are inherently viskicr than others. Nert balls are safer than hand grenades. Bt] prefer to laok past the asset awned to the owner. We tend 10 own assets suited ta aur risk prefers. And we lind ta operate it as safely or riskily as we like, Thi is ue particu vf human capital although it was first designed according Lo our parents’ goals rither than ours. Human capital is probably he most versatile assel, even so, and is adupled Lo our purposes rather than theivs. We make it as visky as we choose. The risk-averse can become florists or “Trappists. Risk lovers can try bullighting or skydiving, Whal does that tell us about the relative risk of the factors? Human capital is owned dispropartionately by the young. We own very fittic Dhysical capital, legally or in practical elect, until maturisy. Pay at first is barely enmigh far sureival. Wee accumulate It gradually as pa rises with age, and then deplete itin pravision for the young and in pur-awn retirement. Since physical capital is owned isproportionaiely by the older and more tisk-averse, and hunen capital the contrary, human capital figures Lo be higher an average in risk ani return Chapier 2: Fast Forwaud 106/16 25 There is another useful inference, Adults own assets in (he business and housing sectors. Older adults tend more to own debt claitns on these sectors, and younger adults to oven equity claims. But all adult ages collectively own both sectors collectively. It does not follow that the sectors are equal in risk, as older individuals night tend to ow ane sector predominantly, and younger ons the other, As a Tagan, | don't really know. What | happen to know ks that the publicly traded carparate scetar, meaning stocks particulary bul also bonds, is far more lui Usan Une housing sector, and thal the rest uf the business sector is far Tess liquid tan either. Risk in gener] includes liuidity risk. This leads me Lo the hypothesis or hunch ba re housing sector in genera] should be safer then the business sector, ceteris paribus, but that the publicly traded corporate sector, cap-weighting debt and equity claims on it, may be satestotall. The idea that stocks and bands cap-weighted are safer than houses might have heen Taughed ta scorn a fis years ago. dasa Lseern sn funny aller 2008. view iL an ida a he esta, moL rusted, uni] more is known. 171t halds up, it will ranks anolber suprise, ‘the effect of individual wealth on tisk tolerance is less understood. Here | judge more from hunch and impression (han (rom data. Given hal human needs are fairly uniform, as with the private and the general, more wealth gives more insulation from want. Talent is wealth in human capital, and gives the same. Less, in either factor, gives less margin for error. My hunch and impression is that the wealthier in either factor should tend ta he mare Fisk tolerant so long as human capital ftsel is not put i arr way. [uman capital operates physical capital, and gives the means af tvcivery. The wealthier, in tadent ur net arth, should prave the lest templet towaril sky diving and Russian rouleile. Chapior 2: Fast Forwaed 1406116 2 In this book Iwill usually be modeling tisk and return al the collective scale or al the caliort ane. A cohort means the set of all same-aged individuals It turns out that the ratio of females to males tends to rise with each alder cohart, for reasons Bob Trivers explains, as does wealth uj toa PORE. But i cohort analysis, both effects {wealth and scx ratio) are incorporated into effects of cahort age. That will simplify modeling My risk theary Is another example af what loalks to be surprise and novelty antl shown otherwise. The unusual idea lies in projecting the awae’s tine reference) rele rate valo he asset rather tan conversely, Thus all the wwners assels of both factors are selected vr modified to fil ber current risk profile, This would count her liquid securities portfolio, cap weighted, as a single asset, All other assets ae too illiquid for practical rebalancing. We own the assets best suited to our isk profiles, if for no better reason than that we wouldn't be the winning bidders for any others if we wanted them. As ou isk profiles evolve with age, we wodity or trade them. We will tend to have anticipated this need, and ta have factored modification or trading costs inte aur bid price. i. turns out ral this interpretation can simylify the math of present value and present cosi. helps in supporting the pay rule, and expluining age-wage prodles, by rebulling a hypothesis, sometimes argued, that productivity of human capital might rise with ge. Productivity, cele of return and time preference rte all mean the same. My risk theory argues that we Kaow a cohorts risk tolerance from the return to its cap- weighted securities portfolio as a whole. All other assets of the same cobort, including human capital, will tend to agree with tin return. Return ta security Dvtfolios tends to he transparent, Tt declines with adult cohrt age. | Infer that return Lo human capital docs th same. My risk theory and depreciation theory together add a Guishing touch to the pay rule The key supporting evidunce is age-wage profiles. Depreciation theary affers salid logic, in the face of apparent contracy dats, thal pay is all buman depreciation Chapier 2: Fast Forwaud 106/16 Pl al the end. Risk theory ceinforces i impression by adding that the contribution of ‘productivity in the form of realized work/buman capital actually declines, Une cannot pound too many stakes through the heart of the doctrine that pay compensates realized work alone. Next Generatlon Theory Tals real. rate of return. This combined free growth theory with insights of Petty In 1662 and William Stanley [evans fn 171, Petes idea was that cach generation asses the baton Lo Use mel. Our investment horizon is he generation Jength. (ls recipracal, or one ver thal period, gives our tine prefervote rte. Jevons also sas time preference as (he reciprocal of the period of production, bul dit nol connect that 10 the generation length. Ladjust Petty’s estimate of the length from lis 21 years to 28.5 by allowing for later births as well as firstborns, The reciprocalis 3.5% peryear. ] add free groveth as an exogenous and nspecitied variable. As with Mil and fice growth theory, | have to walk a fine Iie between crediting Petty and pulling my ideas in his mouth. Bey dictated his hoales ard pamphlets, and is nol always clear, My idea, probably bul not certainly Une same as his, is (al euch generation invests everything in the nex! in trust that it will do the same. 411 our capital oC both factors, although Petty spoke only of & cornfield, is exhausted in putting the next generation in place, The time horizon to get this done is the generation length. his 28,5 years, as Lmodel it, becomes Jevons' “period of production”, Its reciprocal, ‘meaning one aver it, gives rate of retam. he idea of a period of production whose reciprocal gave rate of rerurh had begun with Rac fn 1934, if yau don't count Petty, an passed thraugh Nassau Senior to Jevons and Bich Tawerk. All assumed grovihlessness for simplicity. Relurn is yeh ras pls cash ow sate, simplifies 10 the pure consumption cate at (he collective scale, All these men, even Petty, were really modeling the pure consumplivn rate. 20.5 yes gives te period of replication, in my view, or period of production if there were oo growth, Chapior 2: Fast Forwaed 1406116 28 Free growth then arrives at its whim, like a deus ex machina, without calling for ‘more than this steady effort of replication. | find myself focusing more and more on that cash How COMPONCN: of Tate Of TET, OF ure Consumption Tate at the collective scale, as the part we can predict and model. The generation length is a biolngical norm which probly has it varied hy mare than a Factor af twa since Ancestral Rc some 200,000 yar ago. This suggests that ext generation theory can be lested against data from any period. Meanwhile iL sreicts ouly al the collective stale, Collective return is average risk return. Sublract collective growl ale Lo leave cash low ale, Retuen nd growth are two of the most closely medsured rates in economics. That says tha ests of next generation theory should be practical. will show tables broadly in support, Next generation theary is a blockbuster. An explanation of interest and etm has heen the Holy Grail of capital theory: Boehm Bawerlk contributed a big advance by ruvualing return ais an artifet of ime: preference rather tan the wher way around. Somme including Trving Fisher hive seen nat beautiful insight as enough Mot me. What explains and quantifies lime preference? Whi urned oul o be Petty's idea occurred to me about 40 yeaus ago, when [Airst took an incerest in evolutionary biology. My [riend Alun Rogers. « populition geneticist | did know all the time, was thinking in the same direction. His two published papers on this are in my appends. Neither of us kuew about Petty’s priority. “The idea would have heen still igger ockhuster hefore the wall came down. Wars wore heing fought alm whether return has any legitimacy at all. Karl Mars, iranically a mmpian of Pelly, may have missed his argument an tat Pet's inl is cally the bilagical imperative [discussed in Chapter 1. The frst ‘riorily is survival and reproduction, Twill argue Ural this was ioplicily avcepled Chapier 2: Fast Forwaud 106/16 29 throughout economic history until new insights now summarized as the marginalist revolution began in 1871, The marginalists, mentioned in the forward, swapped the telescope for the microscope. They left aside the grand teleologies of Smith and Ricardo and Mill and Marx to refocus on the mechanics of choice. Reasons for tastes or choices were treated as irrelevant. By 1900 or so, the marginalists had given us microeconomics much as we knaw It today. & century woald pass before Wioecaramics lank firm in response by amills rule. Summary Thal gives the outline, TU is bymian's view of whi & proper economist might not have stempled. Fools rush in. [will cite sources in economics wd biology not lo pretend that | xm an authority, but to give real ones a chance to check. My case rests onthe charts and tables. Mill might have been astonished to find that the kind of growth he described is the only kind to appear in the record. What makes my baa different, aside fiom my lack of credentials, fs the surprises ail the unusual ilegrus of abstraction learling to them, Nol many writers Lry ta follow a chain of inference 5 far without the comforting Louch of the stone and waud and rape, If Becker had been as venturesome, he might well have solved the ape-wage problem in 196+.) see no other path, Economics is all inside. (Lis tastes expressed in choices. Capital is foreseen satisfactions discounted by whatever our Taste for impatience is. Most of itis human capil Leaving litle market record beyond its rental cost in pay, Logic is about al we have left. But the story cannot end in thin aie. Few would pay the nuisance cost of so much abstraction without prospect of surprising and testable prediction. 1 will ry to deliver that. Mil's Idea is a surprise W paliticians, if less so 10 ccanamists, and could hardly he tested mars toraughly and sucessfully. When new ies are thought up, Mother Nature says “Shazam” and embodies them al no cost beyond the depreciation phish we needa anyveay. The dala could nut be nore suppntive iF Mill and) bad invented then, Even my proposed solution Lo the age-wage problem, Chapier 2: Fast Forwaud 106/16 30 which must hive seemed hopelessly stuck in subjectivity, pad off finally in that solution and in a refutation of Piketty's argument, Risk theory aud depreciation theory, each surprising enough, reinforced that solution and the pay rule. I said nothing in the this chapter about bank seform because | covered that in Chapter 1. Predictions of behavior can work hecause tastes converge ta market equilibria What stands behind Une canvergenve, argu, is biology selecting lasts that maintain and reproduce us. The Idea thats act aut the biological Inperative is clear in Petty amt Malthus, and in Ue equilibrium wage theary af Adam Smith an David Ricardo, where pay converges Lo the level preserving Ue work farce, Buti 1 si everything about thal now, [will have nothing lo say later. Chapior 2: Fast Forwaed 1406116 31 CHAPTER 3: FOUNDATIONS Historically, foundations and science itself emerge at the end of centuries of practical application. A logical place for foundations in textbooks is the begioniug. So itwas with Halliday and Resnick on physics, which began with Newton's Kinetics {mation in time and space) and then this three Jaws. Only i the last chapter did the authors remind us that FST later put two of these three fnto question, and even the Kineties. Halliday and Resnick reasoner, correctly Think, thal. we sometimes Tesi mar efficiently by learning something slightly wrong fist and fixiog it later: T will do (hl in a sense, by rexsoning first rough free growth theory as if the ¥ = C + J equation were Lrue, and then again wilk the wo corrections. The sometimes counterintuitive logic of teaching and learning, including that, is “heuristics”, Building on explicit axioms was common in economics throughout the classical period running from Petty in the 17 century theough Mil in the 19th. Then came the major shift in focus, beginning in 1871. called the margialist revolution. What ‘mattered vas less our goals, and more the market mechanisms that aligned supply. demand and price. The meeting point was te margin. Axianis about goals disapeared, including the sual wie of priveilizing survival and reprodudian, and wioms kept sere usually lef implicit. The implicit anes, essential lo marginaliso in my view, included convergent Lastes and predictions, ) will make (bose two and. others explicit, and eventually add back the goals. “Ihis book on the whole is about second-guessing what is taught. This chapter is different. The nearest thing toa surprise in itis the idea that economics needs explicit foundatians i the sense of axions and basic definitions and equations. 411 the ones | chaps ane well accepted. Why | pick which should seem obvious in Wiadsight. But same wini-surprises will accumulate. Why do {take such pains to rine every feature of whal iveryane accepts al vady? Why all the boilerplate amd Iletpranfing? T need them because [will later (ry ta shool dawn other beliefs evirynne acrepts. Wet must ki what is sound Uo find what is nol. Chap 3: Foundations 111/16 1 Another mini-surprise is the physics-like care in definitions, The reason is that my arguments latee will drive logic pretty far. Logic needs words that are like algeraic symbols in meaning the same thing all along. Figuratively and literally, foundations arc graundsvark. They wil be less a chare if you love: logit: Ard you'd better if you're gaing ta like the later chapters Tels gel started. Orfentation Economics itself, think 5s % quantitative rationale of choices, Psychology is i sister study not explicitly quantitative, and accounting for sublimina] behavior as well 1s deliberate choices. The two fields cooperate and overlap. Economics is quantitative in that asks how much as well as what, and focuses on numbers, tis science-lile in that loaies for surprising and testable predictions in the end. [tis philosophy- Tike fn that chofces are subjective and that the larger factor, human capital, leaves tthe marke evden from which W reasin upward. Both facts pul. the burden an reason downwart from axioms Much of the evidence for both (actors, mening physical and human capital, comes from the vecords of liteval markets where we rent and hire and buy and sell Most economics looked no further until Gary Becker and others expanded the boundaries about SU years ago, The expansion made sense. A rationale of choices in literal ‘markets alone sa silly concep. It is silly to acknowledge only choices that ring cash registers. We are the same people everywhere. Logic is the same everywhere, We have ttle interest in axioms that aren't the same everywhere. Becker was vight to sou chalees In marriage and even crime as predictable In terns of supply and drmand and price. Thal includes psyrhic price. nee wee follow Becker past literal markets, we accept psychic value and yield. We must anyhow. Value is in tbe mind, Geonomics works as Chap 3: Foundations 111/16 2 raionale of choices, hence vidues, because bumin nature leads minds (0 converge. The literal market adds a measure. Whea we step outside it, we make do without the ‘measure and trust logic alone. A Diamond Ring Parable Tiike a picture: ofa diamond rig to sha something ahout psychic value and yield, ani even abut whal slut and exhaust in consumplion are. The rng brings Jsgehic yield to its wearer: IF didnt, would Have no value. tts yield bs cach yee satisfaction, and its value sms al Gme-disciunted prospective anes together, Value therefore drops just i lille ss wach yield is finally realized. 1 is as will apples dropping (rom a tree, Yel the ring is inert. IL ostensibly produces nothing, t also keeps all its value as a ring from day Lo day. hen where does the outflow of the value iu the exhaust come from? How can value go out if none vas deducted and none produced? In the tree, we can see the apples growing and falling. “he answer is that some value wes produced in the ring, and some deducted tao. Wha we: dice notices was the canstant shortuning of remaining discount perinds. seach ny pisses, ach future yield comes ane day closer. These are the apples slowly ripening on Lhe ree. Present valu of each rises because the discount period covers Jess Une, This creation of value is output by definition, even though nothing has moved but the bands of the clock. As the discount period veaches zero, the expected yield eventuates 1o explain the laste satisCaction. These yields are (he apples falling to be eaten. The ring holds its value jatact because the exbaust of value it surrendered has exactly offset the output of replacement value as time alone shortens discount periods. Yet nat an atom stirred. The whole points that the valu of the ring ar anything else is discaunted prosent value af foreseen satisfactions, They are discounten because Uhare is such a thing as “line preference’; we value salistactions now over foreseen ones later, This is not quite the same as the difference between births in the hand and birds in the bush. Thal says thal we value cerlaiolies over probahilLies. Time preference alsa values Chapior 3: Foundations 111/16 3 Present certainties over [ulure certainties, The reason is studied in a branch of economics called "capital theory”. iy next generation theory, really Petty’s of 1662, proposes what the average-risk ime discount rate is and why. Present value of each expocted instant of future saristaction grows at that rate as time shortens the discount perind. It disappears, as apples from the tree, when expectation matures nto reality. This diamond ring parable fs ful oT useful lessons. 1 think it cantains substantially all oF exonpimics. “Cansider he lilies of the field” “They also serve sho vale stand and wail” 4 chemist would Testify Wal the ring bas done nothing, An economist sees plenty happening, Economics is abstraction, Physical capilal is nol tings. aad human capital is not people. Is all in the mind. What an economist sees is present value evolving with time as expectations ripen aud eventuate, Output is not what we do, although it has to do with what we do. [ts the passage of time. Exhaust is the fruition of time and the harvest reaped. Only when we allow psychic values can we say that all behavior is ecanamic hehiavior. (Lis chives among alternatives. That's whal makes econamics philosophy. Axioms “then what should its axioms be? We woud like empirical or real-world certainties. find none beyond Descarte's cogito. Philosophy is cerlidn of next 10 nothing, We settle for working assumptions, We want ones as safe and few as possible. Those of economics have usually beer lef implicit since the marginalist revolution. | dropped the course because 1 Flt their need. It should do no harm, at this point, to risk the. opposite extreme. [ets ty putting everything on the table. My first axiom, in thal spirit, will be uguidead natu ral causality. This need nol alarm the devoul.ILis the working assumption of all science, Workiog assumptions are nn creel. {cant rulk aut Une gusibility of wecasional or even continuous intervention by Gad 1b explain whi we see, Bul we know to act as if we ruled iL out Chap 3: Foundations 111/16 p when our stience bats are on. Even philosophy, in the Western Lradition, leaves revelation aside. A practical consideration is that debates of how God is likely to be ‘motivated to intercede have tended to tind little consensus or traction. Science gets some. Tipped iny hand on ny own views In Chapter 1. As chairman of the Leakey Faundation far mare thar 40 years, 1 pretty clearly buy evolution theory and unguided natural casualty as working assumptions. But {invite those who don't to rea further before deciding Unt se will disagree pn conddusions. 17] Fares conflict with the devaul, which T doo, Tswoukl feel obligated Lo warn Uners now. 11 bring, this up again 4s we go along. My next few axioms, Jumped together, are a mortal and reproducing population which competes, cooperates and freclances to act on convergent predictions. tt acts to satisty convergent tastes in a world af limited resources. {will model the Dopulation as human, although other specics would do insofar as wy axioms hold fir therm, “Convergent” means non-identical frm individual to individual vr place to lace ve moment ta mament, but converging ( avn with increasing stale in space worl time. Predictions converge Lo outcomes as well as la one anolher, “the points that tastes and predictions must be convergent enough for markets to foren and hold. A marke, as Becker knew, is where anyone mekes any choice among. alternatives, A litecal market is where a choice leaves a quantitative record, Markets cannot form and hold if we cannot predict where to find thet and what they supply and when they are apen. They cannot form and hold without some consensus that what we predict they wall offer Includes something we want. Clothing stores can wrk because aur siz and sha pes Fall mostly within standard ranges. Their Business wuld be in Lvuble if we did nal agree in number and rough placement of actns and Legs dnd head, Restaurants can work because we can find whal we want ona finite mer. Most crucially, clothing stores and restaurants cannot hold unless there is consensus on what Uneir wares ace worlh in return. Al this convergence Chap 3: Foundations 111/16 g suggests a single species, though the axon ouly said population. The ants aud he picnickers can compete for the Junch, but they cannot bargain for it. The bar in Star Wars is a great gag because ir thumbs ts nose at this home uth. We converge in taste tor the hilarious, Twill add the bialogical Imperative as a separate aon later, although nach of that al least may be implicit in the first ane of natural asality, We hate unnecessary atoms, fram goad Occamite principle, but we hate unsupported inference or questinn-begging worse. Tspell oul the axiom of morlalily and reproduction because | know I'm beading towards Petty's insight and nex! generation theory. Of course we design foundations 10 Support what we want on top. It seems to me that try axioms mention nothing about rationality, whatever that might mean, except in the sense of assumed convergence of predictions to outcomes. And that assumption itself might not be eritical. What seems critical that is the predictions should converge to a knawn fumetinn of puteames. If hey comverge Lo something prediclabily iveroptimistic ar averpessimistic, we're sill in business, Lacking even that, ecanomic science is stillborn. We can't predict chavs. “That's an example of the principle that axioms need ot be strictly true, They must be true enough. We're stil] in business if God intervenes a litle bere and there. Much more than that, and the convergent prediction axiom uns into the problem of predicting the mind of God. “The tw convergence axioms, of tastes and predictions, are implicit in all micrieconomics. “icra”, as ceonomists call It is about supply meeting demand at rice vipuilibrinm. This insight ses Ue main heme of the marginalist revalution, ts exactly whal can't happen without convergent astes dnd predictions. I's exactly why thee bar in Star Wars is a hoa Ants find price equilibria in ant markets, and people in people markels. Ants and people find no meeting of the minds. Then if Chap 3: Foundations 111/16 & macroeconomics (“macro rests on mic, the convergence axioms say only what economics has accepted implicitly since micro began. The “law of one price", ‘meaning marke equilibrium, actually begins a century and a half cartier with Cantillon. But Jevons, in co-founding the marginalist revolution in 1871, effectively ‘made itan axiom. Tort wan. a seem Lo claim thal the wonvergence axioms ane safe because Wey art: accepted. Arguments od maforitatean or ad ouctorftatem prave nothing, But markets di seem te form and ald, and the onvergences seem implied. Authority and majority are sometimes right, Mot all economists have agreed. There have been “historicists” and “justitutionalists" who mistrust the idea of convergent tastes, and prefer to see idiosyncratic national tradition or power groups or mindsets as the prime movers in place of unitorm human nature. Heinrich Sehmoller, a historicist wha stressed national differences, tangled with Carl Menger, an independent en-faunder af the marginalist revolution in 1571, in a childish feud for shich Menger was at least as much to blame, IF yan must answer your critics, be gations. Tharstein Veblen, an institutionalist from Wisconsin, coined he ecm “neoclssicism” for whit we now. call marginalistn, He made fu of it for missing the role of institutions in driving economies for ustitutional or collective goals rather than individual human ones. J think there's something there, My main thew in this book is growth theory atthe collective scale. argue that collective growth flourishes where Jays and practices and cultures nurture and protect it. These are national institutions. New ideas, by definition, are opposite from the fangibie commaditics far which supply and demand meet at price equilibria, Somehow: they came. Dogs bark, cats dimb, pengle imate. Tm with Menger ard fevares am the marginalists and human satire, but wilh astetisks there too, There is plenty lel for bistoricists and instilutionalists lo help explain. Chap 3: Foundations 111/16 7 Vocabulary and Catechism The words microeconomics and macroeconomics, by the way, didn't exist until Ragnar Iirisch coined them in the 19205. We nse terms retrospectively to describe old arguments in language familiar now: That segues into the next steps in the foundations. What should he the basic vocabulary and catechism, caning haste Jogi, in terms understiod Uday? Consideration of purpase alueays comes first. The purpase of eronomics is prediction, We happen Lo knaw thi vue of the most powerful predictors of economic behavior is maximization of risk-udjusted celurn. This was Robert Turgot's insight of 1766, although he left the risk variable unsaid. (His real first name was somehow Anne, 50 we'll go with the second). He wrote that return equilibrates across markets as investors leave low-return businesses to crowd into higher-retuem ones. The shift bids up capital denominators in the higher-retarm husinesses, and conversely, until return converges. It was David Ricardo, in 1817 who arided thal the wnvergence is mare exactly fin businesses judged equal in risk. The evidenue is everywhere we look. {all this the masimand rile: al belaior ‘maximizes pecceived risk-adjusted rate of return. Tl show its proof below. Tht means all behavior in all markets, and markels ure where any choice among alternatives is made. Return means ratio of (net) output to capital generatiug it. “Then the vocbulary winted might as well include capital and output Buz what is capital? Economics is choices, and the measure is price or value. Price can't he measured exactly outside literal markets, which is why cconomists follow those markets, but is measured in principle by what we give up fn exchange. The price: Fay capital, even human capital, is given by the present value rile as time: discounted cash flow. Then cash flow an ils positive and negative campanents belong 1a the basic vorabulary, while the present value and magimiand rules both Delong ir the: catechism. Outpul is latal return, sa the tatal return tris belongs in the catechism lo. Chap 3: Foundations 111/16 3 What other basic terms do we need? Cash flow at the collective scale, where wansters cancel internally, and there is no source of invesnent from outside, simplifies to exhaust of value in taste satisaction. There is no negative component because there is no external source of new investment. Tradition through mast of economic history has called this exhaust consumption. Schultz recognized some: carsumption as ivestient in hurmars capital, [said earlier, and limited Uv: exhanst 10 "pure consumption’. | will usc this and the term “exhaust” interchangeably. Then transfer, consumption, exhaustand pure cars mplion belng in the vocabulary lao. So dues "invested consumption”, my restatement of Schull’ “pure investment” in human capital. his seems to be the right track. The object is prediction of behavior. The maximand rule predicts all behavior, and {have sought to build a vocabulary and catechis to clavify its terms. The right vocabulary, thank gash, is mastly the one we have all used since Ada Smith or even Petty. It has needed anly a little tweaking and clarification, a to tne: tw kinds of capital am cansumption for example There is a fundamental] theorem” of calculus showing hove differentials and integrals (i logetlier, 1s proof takes a lot of thought. There is a simpler one for algebra. Might a fundamental theorem of economics be helpful? Obvious candidates would include the maximiand rule predicting ll behavior, he total return truism explaining the output numerator of the masimand {rate of return}, and the present value rule explaining the capital denominator. lor years I chose the maximand rule asthe fundamental theorem. Then | preferred the present value rule as more fundamental sie It explained the denominator. But sa would he the total return teusin in explaining the rumerator, Naw [apt for the judgment of Parts. Let the: thre Logether be the Fundamental theorems of econpimics. The msi mand rule is the centerpiece, aod he other wo define its terms, All three logether are much easier Lo fallaw, merc fully, then the ane of calculus, Chap 3: Foundations 111/16 9 The votbulary tin also include the standard distinclion among stocks, flows and rates, These are only definitions, not assumptions. Stocks means value measured in money units, say dollars. This is not the same as stock in the sense of equity securities, although those can be examples. IOVS means processes Such as output for consumption measured in dallas per unit time. Flaws are to stacks as verbs to uns. Percent rates are Mos divided hy sticks, as rate: of renin ar grawth rate, anil are measured in pure numbers over ime such as 5% per year. Maw for the andamenta theres, Take Ue present value rule rst. starts from he stom hal ee satisfy convergent tastes in the light of convergent predictions. In simple case, we foresee sal an asset (stock) is likely Lo yield a cerlain amount of taste satisfaction flow a a certain future time. We discount that expected mount at atime preference or time discount rate given by our taste for impatience, tempered by our taste for risk avoidance, to find its present value. Present value of the whole asset is the sum af present values af all the expected future satisfactions together. 4 more gonaral case allows far transfers. The future events we forasce and iistount are no always exhaust in laste satisfaction by purselves al the lime. Some might be foreseen liuidalions Lo reinvest in other assels or Lo give away so (hat we or (he donee can realize Le taste satisfaction later, Either reinvestment or gif is called transfer. | call it "transfer out’, meaning out from the generating asset. Then transfer out = reinvestment + gift. 3.1) “there can also be transter in. Sometimes future realizations, in taste satisfaction or twansfer out, are not explainicd as production by the assetas itis now. The asset might grows later by news nvestinent from outside, and the investment in hotwoen might help wcplain the later yield. I an eight-grader is destined la becarnw # ator, Tor example, ber (oreseen earnings s i doctor will presuppose investment in high schaal and college anid med schoal in between Chapior 3: Foundations 11116 10 The expected future flow we discount 1 present value, lowing for transfers 100. is extiaust plus transfer out less transfer in. [his net diffecence is called cash flow. That 5, cash flow = cxhaust + transfer put - transfer in. @2) Thal's the gic behind the present value rule interpreting capital as discounted cash flow. Tunman cash fs may not be define in those words ang where hut in this book. But the flow discounted Lo find human capital is understood everywhere, | think, 4s pay Jess what Schultz called pure investment and | call invested consumption. | defended this idea in my analogy between human capital and the firm. Thus | endorse the tradition that human capital is pay less invested consumption discounted to present value. Thats, human cash flow = pay - invested sonsumpLion. I tarns pul that this is nat logical certitude. or an inference from axioms dlreatly sven, and so iLs not siriclly part of he foundations. will defend it in later chapters. The great convenience of the present value rule and its application to buman capital 5 that it allows the factors to be added asa dollar sum. That helps iu understanding the total retura rule That rule begins with the Luli that growth of anything is internal creation plus Mow passed in less Mow passed aut. That shows as growth = creation 1 ow passed vl ow passed in 33) Chapior 3: Foundations 11116 1 Algebra now allows creation = growth + flow passed out - flow passed in, {3:30 since terms can change sides if they reverse signs. Ticonamics is interested in creation and growth of value. Value in the stock sense means capital in general, Most ccanaumists mast of the tne vse the word to mean only th: “physical capital” we bug and sell. But Une truism works far anything. | sometimes prefer tne generality of “value”, mesniog any amount of any mix of ‘human and physical capital, This agin can be called either “total capital” or value interchangeably. Flow of value passed out is exhaust plus transfer out. and How passed in is transfer in. Creation of value is output in the net sense. Then (3.2) and (3.32) give the total retum rle autput= grawth 1 cash Mow. 33m) “Income” means rights to output, and is implicily equal o output, Like most writers in economics, | will use these words more of less interchangeably too. Now comes the centerpiece. A good starting point is the present valu rule. We asscunble value or total capital to satisfy foreseen tastes, But we also satisfy current tastes by spending current cash flows. AE the scale of the total capital (valuc} of the individual, were reinvestment cancels fatermally, cash flow simplifies to exhaust in taste satisfaction plus gift given less gift received. Then individual cash flow = ned gill 1 exhaust, [E5) where nel gift meas gift given less gift received. Chap 3: Foundations 111/16 12 Consider net gift. ts negative component, gift received, is concurrently added either into total capital growth or into exhaust. Thus it is the contribution to those two desiderata explained from outside, rather than by the individual's behavior. Net gift deducts that negative component {gift received) from the positive ane to leave the part which the individual's behavlar explains Thus individual putput, as the sum af growth and net gil, is the sum af desiderata realize) by hihaviar. Thal. makes it the andque hohavioral maximand as a flaw: Divisian by the lndividual’s total capita], which is her whol means f behavior, gives tal capital rate of return as the rate: magia This can be summarized in a slightly different way. Cash flow mexsures the means of taste satisfaction now. Total capital growth measures gain in means of expected satistactions, discounted according to our taste tor impatience {time preterence) tempered by our taste for visi aversion. Outputs their sum. Behavior reveals and maximizes the taste satisfaction including provision far fature satisfaction Therefore risk-adjusted output is the Qin maxinand, Capital of both Fictars, a. rst value, is defied as tie whole means of thal satisfaction, ani implicitly of behavior. Therefore risk-adjusted return, the ratio of the low masimand lo its means, is (he re maximand. What Turgol sid in 1766. in Lis Reflections. was "5 5001 25 the profits of one employment of money. . increase or ditninish, capitals turn in that direction. . or withdsaw and turn to other: cmployments.... Whatever the manner in witch maney is enployed, tes preduct cannot. increase or diminish without all the ther employments experiencing a proportionate increase or diminution” Turgot dil nok allow Tor risk in this quick summary, bul atherwise explained the mechanics bat teod Lo equalize retuc, Chap 3: Foundations 111/16 13 The rule does not say that risk-adjusted return tends to hold constant over time, To the contrary. Return equals growth plus cash flow, and my charts show the growth component as a bucking bronco. The maximand rule says only that risk-adjusted veturm is always the maximand [ts notalways the same as ime changes efrcamstances. Proof is fn Turgot's equalization of return at each moment, not fram one miment 10 the next. That is what we see wherever ve Jink. There is a spill arth allention. Behavior seldam expresses taste: exactly, We say ane word when we mean another, We reach for the toffee, and accidentally spill i. Thal was the poial of ty sion that predictions converge Lo outcomes, as well as lo one another, only on average. Outcomes ave generally a little better or a little worse than predicted. There can even be systematic bias vebere all people together seem overoptimistic or overpessimistic accordingly to circumstances, as shown in the psychological economics of Hanmeman and Tuersky. ‘The axiom requires that these Biases offset over scale and time. That saunds plausible, and anyhav males analysis The meoimand rule would be ridicalous iC terms were defined ina literal market context only. Markets must be defined as wherever any choice is made, (would be ridiculous if cash flow were understood to presuppose literal cash, or even the necessily of some guid pro quo Lo explain motivations. Unceciprocated gift down the generations drives lineage survival, All behavior means all behavior. The mise maxioitzes the gravith component in retumm, the parent or philanthrapist maxinizcs the net gift component, and the goa-tine Charlie maxinizes exhaust Have [gone (oo far in this claim? Try to imagine an exception, What kind of bebavior might nal maximize per ceived risk-adjusted return? What if jump oul the window? Deliberalely drive my var inlo a tree? Sell a caw for « handful of beans? Maximize « Chap 3: Foundations 111/16 1 pile of nuclear waste in my sale instead of cash and securities? Drive a truck filled with dynamite into a crowd of unbelievers? Write a book on economics when | have no credentials? Sing when | have an atrocious voice? All express my tastes. There is no escape. Behavior reveals taste satisfaction in the broad sense including provision for Future satistactions. Tastes, Alms and Ends Tusually mean the ward “tastes” as objectives whose satisfaction exhausts capital vale. Ty Ural sige, ao woe just sa, (hes bruisin thal behavior reveals tastes must be interpreted carefully. We see current Laste satisfaction al meallines, Between meals, we mostly see buildup of capital Lo satisfy lustes in future. And vee somelimes are motivated to give capital away, as in raising the generation to succeed us. | sometimes use the term “aims” to mean the sum of this exhaust plus gitt plus buildup, Then to say that output realizes growth plus cash How is to say that it realizes aims. All behavior reveals and maximizes aims explained by ends. This again puts the maximand rule in a different way. 4s capital af bath Fautors is aur whole means of behavior, and as itis present value af foreseen laste satisfaction and nothing else, we might first suppose thet laste satisfaction is our nique final gow. But that oo could mislead. Biology shipes our tastes, and shapes them to replicate the generations. | treat the biological imperative she “ends” driving Lestes and ms. Our bwo complementary ends are adult survival and replication of bots factors for survival of the young, This idea underlies next generation theory. What we maximize bs visk-adjusted present value of curren plus foreseen taste satisfactions by ourselves plus dnces. Current taste satisfaction or exhaust hy aurselves is caunted at full value, and fareseun ones ars aifded at a lime discount. Trisfer is part of te mechanics. The exhaust plus growth plus gifl are the ans, in whatever proportion we ike, and our subliminal deeper nitive of lineage survival is the ends, Chap 3: Foundations 111/16 15 Subjective Certitude Tautologies or truisms are logical certitudes. by theee fundamental theorews are cases in point. The total return truism is a classical example. Since growth is creation less net outflow, creatian is growth plies et outflow. This gives unqualified certitude ta the doctrine that output, or creation af value, bs growth of value plus cash low (nel tf of value). The ather vo fundamental Users are erties in a subjective sense, Whal they rect infallibly is intentions, The present value rule must give capital vilue 1s we see it individually. Only under Ue convergence axioms does il predict observed market equilibria. The same is true of the maximand rule. This rested on the same axioms and the one that a population acts to satisfy tastes (in the sense of aims}. “there are schals of thaught, including Papperians and deconstructionists, which disapprove of logical certitude on grounds not clcar to me. They are rang. A Tose is a ruse Nor ar al exams as inane as Ural ane fram Gurtrucl Stein, All of math is durivwd as logical certitude. Tis proal comes from analysis, not experiment. Proof of Fermat's last theorem eluded some of the finest minds in he world for bree centuries uni] Andresy Wiles published the solution in 1995. Philosophy is precisely a search for hidden truisms or tautologies. Economics is philosophy when it does the same. The pi rule shows thal (heir inferences cen be startling, Age-wage profiles are technically illustration, not proof; of the proposition that human depreciation is expected to be recovered in pay. That follows from definitions and needs na evidence in proot. The pay rule Is not wholly Jagieal certitude because Italo prapases that maintenance consumption is anf recovered in pay. Rather Tague thal from Ue iological imperative: maintenance is exhausted in satisfying our taste for adull sarvival. The Fact thal fia can have doublet his since the physiocrats has nothing 10 do with prov. The shock, anyhow, is in he expected recovery of human Chapior 3: Foundations 11116 16 depreciation. This opened a can worms. [| contradicts the Y - C + equation, wal the related belief that output equals profit plus pay. | will ey to track down some of the worms, as [ pronuised, and release new ones in the process if] must. “This baok will continue to hunt for certitude, absolute when possible and subjective otherwise. IT the canvergence axlans are trusovorthy, behavior will reveal afin well enpigh. Output Exhaust Tilefine autpul as creation of value, and equivalently of capital. Does this overlook the possibility thal outpul might alsa create laste-salisfying pure consumption directly, without passing through a capital phase first? Such a thing is possible in math, but notin economics. Since capital is foreseen eventual exhaust, exhaust not drown from capital in place wanld be implicitly foreseen. This is the ip side of the deadweight loss rule. Teanamics is a rationale: of thiicess, and neglects wnfarseen laste satisfaction as unable Lo influences dices. Those unforeseen and hence coslless satisfactions are called "free goods”, and ignored as ouside be economic purview. They why nolignore [ree growth oo? Growth is roughly foreseen aud factored into choices, for one thing, even if am the first since Mill to foresee it as free. For another, even unforeseen events ase of economic interest if they affect means or choices after. Free growth does Costless satistactions leave no trace, Note In any case that the tatal rerum truisin (3.2) through (3.3b) does not depend on this Inference. Thase cquations fiescrlbe: creatian of value, nat necessarily af capital alane. Gulpul wxhiaust wiht he adie both bo output and W exhaust and woull dissppeac io their difference. Chap 3: Foundations 111/16 17 Basic Glossary Juse standard terms whew | an find them, aud coin new ones like “aims” and “ends” when | can't. But even standard ones are ambiguous. The vocabulary of economics is not settled. Look up “capital” or “output” ox "cash flow, for example, in any economic dictianary. It will show ranges of meanings, and appreciably different anes fram ane dictionary 1a the nest 1 enped by defining as {went along, and would have had to da the same even If this bank sere meant far ecanomists anly. Otherwise the ambiguities vould hae ef loapholies Definitions include: Aims: Intention lo maximize the sum of current taste satisfactions plus gift plus groveth in means of future satisfactions and gift. Capital Means of aims: husnan plus physical capital; present value of expected cash flows. Cash flows: Capital passed aul, in transfer or exhaust, Jess capital inserted from outside: Tiuls: Rationale of aims; Wiolgical imperative. Exhaust Termination of capital in Leste satisfaction. Flow: Any process measured in capital per uni time. Human capital; Present value of skill sets; capital whose outside operating cost is exhausted in taste satisfaction; present value of pay less invested consumption; present cost of pastinvested consumption less pay. Income: Rights to output: qual to output. Tovested consumption: Transfer into value of human capital. Masitnand rule: All behavior is maximization of perceived risk-adjusted output and velar as (ow anil a rate respectively. Nel lansfer: Trausfer oul less leansfer in. Chap 3: Foundations 111/16 13 Gutput. Creation of wealth, or equivalently of capital of either factor. Physical capital Capital whose outside operating cost does not satisfy tastes. Presentvalue rule: Capital af either value is expected cash How discounted at ur thn preference race. Profit: Output af physical capital. Pure: cansumglion: Same as exhaust Rate: Quantity meisured as a (ow over i stock, and equivalently is a pure number over time, Stock: Quantity measured in dollars alone. Same as capital, Tastes: Intentions whose satisfaction terminates capital in exhaust. Total return wie (or total return tvs): Output equals capital growth plus eash flow. Transfer in: Value inserted fram outside. Same as new nvestment from aulside Transfer out: Value passed out and recovered fully in other wssels eather than exhausted. Wage: Same as pay. Work: Output of human capital. Summary When [rst thought these foundations through, maybe 23 years ago, [was Just as happy Lo see hal ney held so lille ariginality. The vocabulary is about the same as in Adaon Smith, and the three furdaonental theoreons are well accepted. Any campaser knw Ura, originality shuld be incidental. Our musi: says what we think Chap 3: Foundations 111/16 19 needs saying, It does, that Lends 10 mean ted 1s new 10 Ue current conversation. It need not be new to the world. All three fundamental theorems are part of the daily conversation of investors and finance economists. They are nat much on the screens of micrasconomists and ‘macroceanom ists. There may have heen some originality In spelling aut the implicit axioms Dehind them, anit in generalizing heim into all capital including human capital if we trust those axioms: Cine of the mini-surprises was hat ill appeared in my very first equation. Cash Moy al the sce of the Lotal capital of the individual, where reinvestment cancels oul, simplifies to gift and exhaust alone. Obvious in hindsight, but surprising if we have been taught that economics is all about numero uno. | think itis about adults giving 10 the young to keep the generations turning. That sets the theme af this baok. 01d [deas wll Ind unfamiliar combinations and applicatians. Those sre iriginality enough. Mul si many litle stretches of the tried and rue can be hed bo ack. Economics needs a special and counterintuitive mindset. The guiding principle is the analysis of the diamond ring, Economics meaus taking our minds off the physical substrate. That goes Lo the corners of our eyes, not the focus. Capital is nol people and things. (tis present value of foreseen cash flows. Output is the ripening of these foreseen flows with time, and exhaust is the harvest eventually reaped. Economics takes us through the laoking glass to a place the same but different. Chapior 3: Foundations 11116 Py CHAPTER 4: MILL'S IDEA Mill's Paragraph It always seemed obvious to me that growth is free. Survival costs Investment in the next generation, but grasth costs nothing more. [t seemed to me that novation is the human specialty, that we pay ts cost every day as the cost of being huan, and tha growth happerss when genius or dren mstance somehiny gives i action spent most af mg life assuming that all economists, hut not politicians, thought the sme, sine Iearned Ural econnmists, fillasving Silas, teach something clase bul different. So guessed thal Thad hit on something nev. I hadn't, We read economic history to learn that our ideas are seldom original. Thomas Malthus, contradicting his friend aud rival David Ricardo, wrote something ike wy or Mill's fice growth theory in 1620, Chapter 7 of his Principles: says this in several ways. One cxample is When we have attained. inivased and steaiy profits, we may then begin lo accumulate, and ouraccumulation will then be effectual. But if, instead of saving fram incressed prafils, we save rom diminished expenditure; if, a1 Ue very lime that supply of commodities compared with the demand for bem, clearly admonishes us thal the proportion of capilal La revenue is alvely Loo areal, we 20.00 saving Lo add still futher of our capital, all generd principles concur in showing that we must of ecessity be aggravatiug instead of alleviating our distresses.” John Rac rencwed this theme fn 1834. Book 1, Chapter 10 of his New Principles includes “IF an improvement, for instance, in the art of baking bread were ettected, by which, with half the labor and fuel, cqually sand bread could be praduced, it wuld uk benefit the bakers exclusively, bul wind be fell sipally per the whole society. The bakers would have a small additianal profi, the whale saviety would have bread for the product of somewhat less labor, aod all who prinsiios of Flic Eom msds with Vist oid veal Sqpiiations = Stotoment of nme dew Fetnoies ote Subject af Politico Fcanony Chapier 4 MiL's lea 111/16 1 consumed brea, tha i, every member of society, would from (he siune outlay have somewhat larger returus. The whole series of instruments owned by the society would be somewhat more productive, and would be carried to an order of quicker returns.” the clearest expression, and probably clearest even today, came from Mill in 184. He put it that output growth can precede and explain capital growth as well as the reverse. Crediting Rag, he wrote: Ther rv alher cases in which the Laem saving, with the assaciations usually belonging o it, does nol exactly Gt (be opection by which capital is increased. IFit were sald, far instance, hit the only way 1b accelerate (he increase of capital s by Increase of saving, {he led would probably be suggested of greater abstinence, and increased privation. But itis obvious that whatever increases the productive power of labor creates an additional fund to make savings trom, and enables capital to be enlarged not only without additional privation, but concurrently vith an increase of personal consumption. Nevertheless, there is heve an inerease of saving, in the scientific sense. Though there is mare consumed, there is alsa mare spared. There is a greater excess of production over consumption. Itis consistent with carrectness ta call this a greater saving. Though the term Is not unabjectionable, Uhre is ne ther which is nit liable Lb as great abjudians. To cansume less than is prauced, is saving: ani that is the process by which capital is increased: nal necessarily by consuming less, absolutely. We must mn allows ourselves Lo be so much Une saves of words, as Lo bi rable lo use the wort saving in this sense, wilbaul being in tanger of forgetting that tb increase pital Were is another way besides consuming less, namely, lo produce more. “the words “accelerate” and “concurrently” show that Mill understood calculus, His autobiography says that he hadn't really learned it from his father James, sho had boughs a book and was trying to teach himself and the 13-year old son a the same. time. The son studied it in his later teens at school in France. He like me was writing for everyone, and preferred to Keep explicit math off the page. But the quote reminds us that the only alternative in ccanomics is Implicit math fn sentence form The paragraph implies the Y = 6 + 1 equation: output equals consumgtion pls investment. [go a tad farther, starting one chapter ago, by offsetting ny word equatians from the running text. These shaw equal signs and phis and minus and Chapier 4 MiL's lea 111/16 2 division and multiplication signs, rather than keeping bem inside the parageaph and writing out such words as “equals” aud “plus. These word equations are usually easy enough to read. My appendix will cover them and more in notation. Mill's equation suay be as old as economics, although | haven't found it put explicitly hefore Keynes wrote itn his General Titenty 1936. 11s nov foundational ta national accaunts ni maroecaninmics {Ue ark of Balan ng fall emplayment. with pric stability). showed why 1 agree only IF we add a couple of Imaginary asterisks. We havi Lo mean folal capital grawth and pure consumplion. Mill and tradition have meant. physical capital and all consumgtion. That Jeaves me with something like the heuristic problem of Halliday and Resnick. They started with Newton as something familiar aud accessible aud common scusical. will follow suit. 1 will reason as if Mill's cquation were right. My own argument is exactly the same ise remember the hidden asterisks, That saves us all the trouble af going through it tice. Chapter 4 well restate tin terns of total including human cagital just Ln ke sure. Nisan unsellling argument either way. IL unsellled Solow. Chapter 2 showed why. Weare probably tore comforiable to think of income is something known which we can slice into consumption and saving slices as we like. Less of one would mean that much more of the other, Thal would pul us in chicge. We can always consume Jess by will power. If less consumption meant more groveth, we could grove at will, Keynes shaved atherwise by invoking the old paradox of thrift. IF everyone put Money in vaults instead of consuming, cansumption would go dawn while money piled up. But the added money would ind ess output ta buy with i, as nothing new wns created fa campensate far the drop in consumplion. The value of the pile-up money would vanish in inflation, Saviog would equal investment in (he end because hth disappeared. The ¥ = C 1 [equation shows the math. Tsay at less Chapier 4 MiL's lea 111/16 3 HOUSE_OVERSIGHT_0109¢4 consumplion C means either more investment | or Jess output Y. I doesn’t say which happens. Investment, for Keynes, meant creation of nev productive assets. He was right in seeing that as the goal. But his analysis leaves too uch outside. What I miss is a wariable for iivestinent quality. Investinents in new productive assets in 1929 or 2000 yiehled negative: return. Money in vaults i eer. 1 prefiran approach whivh takes our minds off the ultimate goal in new productive assets. Trop all distinctions between saving and investment. Bither word means the other, Wha millers is ils intended and realized return, Thal is the missing quality variable. Notice that | dow't have to specify “risk-adjusted” return because Keynes and [are describing only at the collective (natioval) scale. Risk of all investments collectively is average risk. This can be implicit whenever | describe at the eallective scale. Weaynes' analysis andl equations appear in his General Theory. ee was mid essing Ue warld depression. & Une was thal housebwds tla mast saving, while businesses do ‘most investing, Banks collected be saving and made i availble for business to boreow and inves, But business lacked (he "animal spirits” 1 take such a risk in a slump. We saw the same story ater 2008, Keynes’ proposal was for government to do tbe borrowing and investing instead. That's pact of the “liscal policy” | described in Chapter L. Here we tend to agree. That would explain bis sevse of urgency as to new productive capital as the most dicect way to put idle plant and workers back to work. 1 prefer ta suspend judgment an what isa new productive assct and what iit, | think my way of putting Wings is both simpler and subller Uian Keynes’ although at sacrifice of bis explicit focus, Saving and investment, in my language, are the same from the start. The maximand is return. Consumption farvgane will anslate into Chapier 4 MiL's lea 111/16 p capital growth insofar as rate of return ictully realized matches the current norm, Less return makes less growth than consumption sacrificed, and more makes more. But colleetive retur can he: surprise. 00m years and bust years amive unforeseen. “The cast of investment in consumption given up, whether individually or collectively, ever agrees exactly with what It proves to Ie worth at market, Gunnar Myrdal, in 1939, coined he Lerrns ex ante ir the fest and ex post for thee secon. The bucking tironco describes the ex post picture averall Ex ante (al cast) ani ex post [al market) investment acer when mackei-real ized return bolds unchanged. Lower return means thal ex post outcomes fell short of ex ante cost and expectations. Higher return means the reverse. That gives the context of Mill's idea. And he clearly jsut talking about growing or declining by random luck. His prime mover is "whatever increase the productive power of labor.” He knew. that this meant iovative ideas. Can we dial them in as we like? All he says is that they ced cast nothing in consumption missed. Then hv ight that war? Gross and Net Investment Keynes, accepting the ¥ = 1 + C equation, defined saving $ as gross income less consumption C. 1 draw the impression that be implicitly defioed output as creation of economic value. So do, He defined gross investment | as gross output less consumption. Gross in both cases meant gross of depreciation. He knew tha income. and output are equal, at all scales, since the fist means tights to the second, and gave both the symbol ¥ 2s | do. It followed that saving and fovestment ace also equal. The meaning was that actually realized saving, a distinct from consumption restraint in hopes af saving. had to he realfzed fn investient This is the hame truth which [accept but prefer ta rephrase. Thave traced Keynes’ argument and language on these poiots because 1 thiok itis ns generally actepied by Keynesian and 2 ati- Keynesian and nea-Keynesian schools dike. That's why © hiok my own interpretation differs from 4 general Chapior 4 MiL's dea 111116 5 consensus rather than supports one schoo] over another. | think iis he consensus view, as well as Keynes’, that his “attempted saving” means gross saving (gross income less consumption] uot invested in new productive assets, That can be written os Keynesian attempted saving - transfer pagments = Keynesian nel saving = Keyriesian nel investment, alan scale. Taccepl Keynes’ definition of lrunsfer payments, snd | recognize be importance of his distinction of those [rom investment in new productive assets which put idle plant and workers to work. My interpretation, even so, is that it is better to Jeave them idle than to put thems to work unproductively. Keynes made his opposite view crystal-clear with his brilliant tongue-in-cheek parable of money huried in mineshafts and ide workers hired ta dig itup. lie had a sense of theater as well as a great mind. And he just might have: beeen right. ful think my way of putting ings enompsses that possibility. This orineshal scenario works if il somehow ‘maximizes return in the big picture. Mylanguage differs from Keynes’ in several ways. | prefer Mycdal's ex ante - ex post dichotomy. published three years after te General Theory, Lo Keynes' equivalent artempted-realized one. Like Myrdal, and unlike Keynes, 1 apply it to investment as well as saving, That's why [ reat them as synonymous. And | prefer to recognize Iman capital explicitly. Keynes surely understood the concept. He was the star pil of Alfred Marshall's later teaching career, unless he shared that distinction with his lifelong persanal friend and professional adversary Arthur Pigau, and Marshal and Pigau both describe human caital in principle. Marshall wrote that he neglected it ws something outside wha he saw as the main sequence ending wilh consumption. Keynes could have agree, ar could have mean ta provide far it implicitly by definiog outpul as investment plus consumption while realizing al Chapier 4 MiL's lea 111116 6 some consumption is investment in human capital.) said whi think (bis overlooks {seli-invested work) and what it forgets to exclude {recovered human depreciation). My 03M veay OF pUTTing things ight strictly need the terms investment or saving except to translate my ideas into the language we all know. That translation is essential IN hope to he understand. Iwill first take account of the Fact that Keynes meant investment snd saving as b> physical capital any, with Tabane or human capital 10 arrive exagenously as an outcome samehaw of consumption. That led to the ¥=14C equation Quipul - investment + consumplion. [BY] Gross and net versions of (+.1) meant gross and net of deprociation. Thus FOSS OUtpUL = grass investment + consumption (4a) ami nel oulpul = nel investment + consumption. (41h) In the General Theary, where (1.L} appears in his Chapter 6, (1.1] i meaus the gross version unless otherwise specitied. prefer Use opposite, and mea the nel version 2.16) unless otherwise specified. My ex ante investment corresponds to Keynes” intended saving” through consumption restraint My “depreciation nvesanent’, or “depreciation plowback”, means just enaugh ex ont investinent to offset actal eprectation, not hoak depreciation, of physical capital. 1 assume ral we intuit roughly hos much this is when 1 say thal oplioum ex ate investment is depreciation plowback. Now let's cansiter his nal could bi rue. Chapior 4 MiL's dea 11116 7 Growth Mechunics Start with simplicity. Imagine a changeless world where people and things replicate themselves exactly. Chapter 3 showed that in total capital terms including haman capital, although neither Mill nor Keynes used them, depreciation of bath factors together, net of teanslors fram one to the other, equals exhaust in taste satisfaction. “Replacement Investment” ar “depreciation investment. is Just enough ta ten the generations aver as new (ne) output makes up he los 1 consumptin exactly. Ideas Told unchanged. That wouldit he tho far from the truth far aur millian years as ana erecta, vc pur millennia afl as hose sapiens until some 50.000 years aga, ar our centuries in Ube dark ages after Rane fell. Most of the uw norms we innovated, although nol all eventually repressed Lo the old ones. Next imagine growth of everything at a constant rate, Capital, consumption and outputall grow in constant proportion. Economists now call this “balmced” growth. Mill had described that possibility in 1844. Balanced growth isn't driven by camsumption eestrafnt, as consumption never lags. And ft sit driven by riductivily gain, meaning more pulput per unit capital, since pulput grows no aster What drives it? Suppose frst Wat there ace still no new ideas. we are pioneers in a new workl or empty niche, we might be able to increase numbers of exactly the same thivgs and skill sets until we reich niche limits. Then whi would pit for capital growth in that case? Zeno the Eleatic might insist that depreciation investment is never enough because it chases a moving target. But depreciation moves just as fast. Identical capital means identical in depreciation rates That means the ratio of depreciation {pure consumption) to capital. The two racers hold neck and neck indefinitely. Depreciation Investment is still cnwgh, Just as it was in the grawthlessness before. To alarical growth, as in standing sl, it is Une only need far af capita) replacement. Nave comes a taugher problesm. Niches in the eal world are typically more ar less full Vere old ies alone can't bring growth, David Ricardo, Thos Malthus and Chapier 4 MiL's lea 111/16 3g Edward West had written in 1816 thi in economies ready developed, there isn't ‘much room for more capital of the same kind. Its productivity disappears in capital glut and diminisbiog returns. There could still be growth when some of the neve ideas would need only redeployment of existing Kinds of capital, as in relocating Iroduction nearer to the market or cutting out the middleman. This redeployment was Solaw?s "discihindicd growth.” But growth alter that have: to come from capital my ir irl Trighasses ight ave Lo give plac Ly packet watches, or sailing ships 0 steamships. Those were Salow’s “embodied” growth. The apparent prablem here is tat novelty is expensive, There are blind leys and failure rates and learning curves hl rote replivalion avoids. This is rue somewhat even in disembodied growth, where redeployment is already a step into the unfamiliar, if depreciation investment is barely enough for balanced growth without new ideas, how can italso pay for the failure rates and learning curves? A tough question. And Mill was pasing an even tougher onc. The paragraph quoted is clearly describing capital acceleration. Capital us he describes iLis nol andy innovating vonsistently as it kewps up with cansumption, bul picking up the pace, worl sill Laking the innovation costs in stride. Ts that too much even for Achilles? Jtis uot, Charts aud tables show that the kind of growth Mill describes has proved the only Kind in every country and period where tests ae practical. IUhas proved the only Kind whether capital was growing faster or shrinking faster or anything between. The growsh bronco bucks, and the consumption rider stays on. Thisis what clearly happens, or anyhaw has happened so tar, despite So many reasons to think ft is Inpossible. What would explain it? First Lake the lesser pure, Balanced grant, where capital, autpul and consumption all grow a the same constant rate, must make do with depreciation investment. Haw can itin crowded niches where growth campels the cuss of inaovation? Chiapter 2 showed my inference Ural these are the casts of beiog human. Chapier 4 MiL's lea 111/16 9 We were paying hem as hamo hails wo million years ago, The cost weal wp, bul the value of innovation just as touch, when homo erectus arrived a lite later. Hoth rose again with the emergence of Ancestral Eve 200,008 years ago. Adaptation is the human specialty. Its What gets us through the day. Innovation is adaptation that happens to become new norms. It started leaving a record of embodied growth abut 50,000 years age. That doubled pace ahout 400 years aga. The casts oF being human are the sume Failure mbes and learning curves whether Ue payafTin adaptatian/ innovation cans faster gain In good times or slawer decline in bad anes. We rn al a stady stroke, ail gain against the shoreline shen au new ideas ave particularly good ones and the current is right, My idea, whether or not Mill's, is that these costs might be about the same for breakthroughs or meta-ideas or paradigm shitts as for modest upgrades, or even for holding even in a world of daily surprises. Ideas trade in an incfficient market. Cost dissociated from value, and cause is desynchranized from effect, by the vagaries of genius and the whim of circumstance. Naw the Loughe: puzzle. Tas ean cansunplian keep up with capilal even in accelerations? That's what Mill described, and Lal's wha happens. Can Achilles catch he Lortoise even when (be tortoise speeds up? Mul yous money on Achilles. Here itis Gunnar Myradal to the cescue. The appareat problem is that ex ante: depreciation investment is never enough in acceleration. Bul the chiels snd tables show unanswerably that ex post depreciation investment is. We sow the fst, but reap the second. Plowback of depreciation investment is up to us. Growth is whatever is added by genius or happenstance. The difference hetween market value and cost is sametlings luck, which neither Inses nar gas in the long run, but sometimes imagination. Mother Natur and Gunnar Myrdal simultancously say “Shazam”, and convert nev: ideas inl embodied or fisemborlied gross th withont surcharge for the novelly. Chapior 4 MiL's dea 11116 10 That still leaves he mystecy only Lf solved. How exogenous (sourced (rom outside) are the genius and happenstance? Can we coax them along by policy? That ssn't really my field. What seems reasonably clear is that groveth flourishes in secular tree arkets with solid infrastructure and rule of lw. How to get those things is the problem. {will suggest that the answers, whatever they are, will be developed outside the usual marginalist perspective af supply and demand The Free Growth Equations Naw back ta Mills argument. Notice frst thal he pul ital in the present tense. Modern growh economists biave prefered shat called the Tagged lows method: spikes in investment are compared Lo later ones in ouput. Mill here is substituting what called a concurrent rates method: he compares changes in consumption rite to changes in capital growth rate at the same time. He writes that “whatever increases the productive poveer ot labor ... enables capital to be enlarged ... concurrently with an increase of personal consumption Tels allay that, Mill's raotassumption is the Y = [+ € equation in its nt form 4.10). Put the ex post version a output - growth + consumption. 1.2) ‘meaning net outpal, growth of physical capital nd ull consumption. The ¥ rule says the same vith the hidden asterisks after growth and consumption. So it will continue for the rest of this discussion. {4:2} shows that less consumption implies more growth, ovless output, or some of oth. Mill was asking which. To show how to find out, frst arrange (4.2) as growth = output = consumption, “.24) again Iecauise terms can change shes if they change signs. Chapier 4 MiL's lea 111/16 1 Milland Keynes and tradition bold (4:2) and (4.26) as logical certitudes which hold constant over time, ] agree if we imagine the asterisks, Constancy over time would imply change in growth = change in output - change in consumption “3 Takes thes Lrvuble Lo flerive: this as a road [avert preferred tn Tllave, Twill reason Instead fn rates rather than lows. Rates, or ratios of flaws to capital, effectively cancel cagital from numeralar-and denminator, Thal frees them Lo shiny comprisun between smaller and rger economies among he eight Test, Mls ide, or anyhow mine, is that he catia of consumplion lo capital in all (hose counleies can hold constant, That is what the charts and tables show. “fo follow that lead, divide (4:20) by capital. This finds growth _ ouput consumption wn copital capital capital 2 Thal can be put more compactly as growl rale = capital productivily - consumption rte, 44) where rate always means ratio to capital. That needs a caveat because consumption. Fate ii macro means ratio to output, Capital productivity in this sonse is also called sate of return. For more compactness stil, detine thrift rate = - consumption rate. allawing (44a) to be restated as Chapier 4 MiL's lea 111/16 12 arovtl rate = capital productivity + thrift rate, {1.0b) Notice that we must change the sign before "consumption rate” to find theift, Change dosmward in consumption rate is change upward it thrift rate, and conversely. Further change in gros rate = chiang in capital praietivity ~ change in consumplion rate, 745) by the same logic as with (4.3). Save space again by reexpressing (4.5) as acceleration = productivity gain + thrift gain, (150) Finally divide by acceleration to reach moductivicy gain | _ thrift gai EW LL 26) acccleration acceleration if acueleration is nonzero. Reexpress as 1- free growth index + thrift index, (463) where indexes arc undefined if acceleration is sero, think this gets at what bill meant, and anyhow what | mean. We both describe acceleration 25 well 5 growth. One night think that his "whatever increases the Iroductive power of labo” is the apposite from my "change in eapital productivity.” Tt thes are alin the same. Beller mach ins make thef nperatars pore productive whether sills have changed ar not. Chapuee 426s ea 111716 13 {2.5) shows something about “balance” or the state where capital, consumption and output grow at the same rate. It confirms the standard teaching that balance is possible, although not compelled, when growth rate is constant. Italso shows that Balance impossible when gravsth vate changes. No ane disputes that capital roductivity {output capital) aways leads, and consumption ate Comsnnmption ata) shu lags, in scelurations up and dawn, Output gets the ad nes Mirstand the goad news frst What the equations leave unspecific Is where capital itself juins the sequence. That is whal the evidence in the charts and tables tll us. In the case where the Iree growth index equals one, for example, the above equations show thrift gait tori inden - —SIUED__ gyi Scceleration ~ change in consumption rate thrift gain = CREME i Grows Fate -0, and chioge in consumption rae = 0, or equivalently ; consuoption 4 Jr———— = ota 47 ” capital o i] iF acceleration is non-zero. (The reason for that qualifier s thal zero acceleration ‘means zero change in growth rate, and division by zero is a no-no) In the apposite cose where the thrift index is one, the same equations wuld shot {ree growth index « POGUE gan _ changeimproductityrate acceleration change ingrowth Chapior 4B ea me 1 implying output - ductivity rate = SE = constant, a, productivity rate = ES = constant {a.70) assumingagain that acceleration is nonzera. This shins Tow ta fim the: position of capital in the sequence led hy sulput, and how Lo test between res growth and Uri theories, The macket-valued capita denominator in {1.7) and (74), and the consumption numeralor in (47), can be taken directly fram national accounts data collected at Une Pikelly-Zuoman website, The oulpul numerator in (4.74) can be constructed as consumption plus current change in markel-valued capital. By (4.7), free growth theory (Mills idea) predicts a roughly constant consumption,capital ratio, even in accelerations and decelerations and reversals. Then capital acceleration would lag alongside consumption acceleration while output led alone. Thrift theory males the oppasite prediction of a roughly constant autput/ capital ratio, sa that output and capital would lead together while consumptin lagged ale. There is no need 1a measure ani Lest bath indexes, as el her is leflned ws ne ess the ather. My tharts and tables track the five avo index. They confieun [ree growth theory in all counleies and periods. Defining Free Growth and Thrift 14.2) through (47a) defined the free grove and thrift indexes, but not free growth or thrift themselves as Haws. Since | will use those terms often, [d better clear that up now. Define free acceleration = productivity gain = gain in rate of return, and thrift acceleration = thrift gain = drop in cash Naw rate, 50 that those sets of terns hecome interchangeable. Then (43a) can be put as Chapier 4 MiL's lea 111/16 15 acceleration — free acceleration + thrift acceleration. 1.55) Rates are Hows divided by capital expressing them. Then define the two Hows as tree growth = capital free acecleratian, and (49) thrill = capital = thrill acueleration, giving (49) growth = free growth + thrill @10) These equations apply equally in continuous or discrete-period time. Tn the latter, they leave Use periods of acceleration and growlh unspecified. Marginal or vurrenl free growth, as with the speed of a car, is the sum of free accelerations since some past origin shen growth was zero. So itis with current thrift. That need not place the origin with Ancestral Eve. Surprising as it might secm in the growth age, zero Joints appear to recur every few minutes ot the longest. Online stock inde numbers veverse direction at lcast that alten. They ass through zee each time. Debt claims on the carparalss seetar figure fa In less volatile, bul equity (stack) wes outweigh then. Then marginal free growlh means accumulate free acceleration, or rise in sate of return, since the last zero growth point no more than a few mioules 450 when return aod cash low were equal. Growth is (ree whenever cash lave rate rises or holds steady. ‘The Charts and Tables Mill Jacked data to test whether growth tends to lead with output when it changes, or to lag with consumption, or something else. So did all economists until national accaunts began reporting market-valued capital i 1996 or so, and recanstructing ft Nackvard aver a fow decades hefore. The equations tirmugh (4.7) show how 1a test room data in Lhe Piketty-Zucmian and Global Financial Dita websites. First dowsndaled the Piketty-Zucran tata far market-velued capital and consumption for all countriesand pears. chose reir “private weallh data for the Chapier 4 MiL's lea 111/16 16 former, | neglected “government wealih” net of national debl, which is small and often negative, as { don't feel that understand it well enough. ( took consumption as the sum of personal consumption expenditure (PCE and government consumption expenditure (GCF). 1 also downloaded real stock market rates of growth, dividends and return fram the Global Finenciol Dota website for the same years and countries. early change i capital in wach country gave wach year's capital grawth as a law. 1 added this to cansunptian to give what | call market-valued autpot | sald earlier thal Pikelly andl Zucnan shin logically have done te same. This gave the values for (4.1) sad (4.14). I then divided by year-end capital to give values for 1.3}. | next found annual changes in those three to give acceleration, productivity gain and thrift gain as shown in (4.5) and (4.5), and divided by acceleration to find the two indexes of {4.6) and [4.6a). The test frm Glabof Fiaoneiol Dota Wak fewer steps. Stock marked growth rate, rate aftr and dividend rte werw downloaied directly Took tein as carraspanding respectively Lo growl cate, capital productivity aod consumption ate in (3.34).1 found their anual changes (o find values for (3.44), and again divided by acceleration to reach (33a). This alloves tests of Mill's idea from national accounts data for all eight nations reported at the Piketty-Lucman website, and over their entire reporting periods through 2010. (he website also reports for Spain, hut only since 1993 and without data for consumption.) In cach year, for cach country, change fn capital growth vate Is campared ta change In cansum pian rate (consumption capital). 1 consumption rae rans fester Uhan cagital grow h rate ihile huh grove, or declines faster if bath decline, the free grovell index in hat year is greater Un one, f they change al the same pale in the sam direction it is one exactly. TT both change in the same direction, but consumplion changes less, the [ree growth index is between zero and ove. If Chapier 4 MiL's lea LG 17 either grows while be other declines, the index is zero or less; zero if one grew as ‘much as the other declined, and less if the change in capital growth rate was Luger than the opposite one in consumption rate. Interpreting the Charts and Tables Naw Ingk again at the charts captioned “free growth Index” inthe append, {wil sammmarize ther anil all other charts al Gables anly briefly here, anid save mast description for there. They cover all eight countries. Bach chart cavering free growth tracks three separate versions of the free growth index labeled @(X). v(K, ) and ISM). The one J have discussed so far is o{K}. o{K_) is a version including human capital, and g(Sh1)is taken from stock markets only. §(K, } will be explained fo the net chapter. The powerful spikes bath up and avn in Une free growth charts were described in Chispter 2. Spikes tel to he explained by Une fact that acceleration, the denaminator in both the free growth and the (rift index, is occasionally close Lo zero, Near zero denominators, whether above zero or below, can magnify tnismeasurements. Some charts report the free grovth index: every year, and show all the spikes, Others Alter out years where denominators fall below a chosen threshold, and spikes disappear accordingly. Uilteation is unbiascd in that fre growth index is corrected down as alten as up. What junias aut From all tase charts is that all versions of the [ree growth index p Muctuste around one. That means that the unshown thrift index Quctuates around ze70. We just saw that the thrift index vell show as negative whenever the thrift numerator and acceleration denominator disagree in sign, meaning that thrift gain coincided with deceleration (negative aceslcratian) ar conversely. Charts and ables show that thrift gain, meaning drop in consumption rate, calncides as ften with a Tower as a higher capital growth rate. Growth by tht is a theoretical possibility Chapior 4 MiL's dea 11116 13 which doesa’ actualy happen. The means of growth Mill describes in Ue paragraph quoted is the only kind that appears in the record. Evidence from Stock Markets Market valued capital, reported in national accounts since 1990 or so and assctnbled at the convenient Piety. Zucman website, fs measured hy a common staniard in principle. Measurement begins with stock markets. 1 should. The stick market Is the most exact source af ccananic information that 1 kno. With due reservations abaut cannivance and "stalk prices,” meaning outdated pries fram earlier days because Ue stds bas not ade since, ar anyhow nl enough for confidence, we kaow prelly well what tickets (bik stocks are worlh [rom tick lo tick. We vould know better if markets were perfectly efficicut. Proof that they areu't shows in medium-term autocorrelation or trend. Autocorrelation (in price} is tendency far markets to he up tamorrow if up today, and dawn IF down. Trend isa shorter word far the same. Perfect efficiency ought to show a “rand walk where prices change captures all current news, news caglures reality without optimistic ar ‘pessimistic hiss. und Lomorrow's price direction is as unpredictable as tomorrow's news. The only exception should be long-term uptrend with productivity gain through innovation. In this case itis not surprise in the news that brings growth, but radu gain in present value is a foreseen belter falure is less discounted as iL draws nearer. “here is chicanery as well as incficiency. Insiders, raving the legal risks, may take advantage of outsiders. BULLE not clear to me that insiders are keller to be sellers than buyers. National accounts follow prices of publicly traded shares collectively, where same chicaneries should ofTsel thers. Allowing for all this, T think matical accounts ave wise W accept stick prices as the best measure of undeying assels. Intangibles such &s patents or mackel advlages Chapier 4 MiL's lea 111/16 19 are factored into share prices because (ey are realities that would be valued as such by bidders for the assets themselves. It is a mistake, | think, to suppose that shaves prices would be less volatile if more descriptive of real value underneath. he existence of trends suggests the opposite. Trends would be expected from systematic underrcaction ta the news, so that reaction catches up later, while systematic averreaction aught to be followed hy adjustment in the apposite direction. This gradual rather than immediate digestion nf the news would fend 1o smaath out price response. Trends Imply systematic undorreaction, not overreactinn. Markel evident: shaws something near Wal random walk as a sual Full, implying neither systematic avarreaction nar systematic underreaction, hut will some episodes of the Later, Whitt would Use reason be? My fest guess would be something delaying the mechanics of price reaction when news is pacticularly surprising Our sense of whee prices should go right now seems not to get them there until later. Prefect reaction to perfect news ought to mean more price volatility, nat ess, trom day to day. Stocks are more volatile hen mast asses because mast ar: "leveraged * Firms may issue bands, and may barrow shortec-teem from hanks. Fixed interest on tase debt claims is paid fist, Shareholders gel the rest of et outpul, which itsell fluctuates aroun expected norms and is sometimes negative. a firm's net profil (ne output} is one willion dollars one year, and one dollar higher the next, net profit will have varied only one Len thousandih of a percent. Bul if interest payments take up he sane million dollars per year, every year, profit left for shareholders will have grown from nothing to one dollar, ts growth rate will bave been effectively infinite. IEthe frm cams twa dollars less the year after, it will have to invade capital to pay the terest, and owners take a one-dollar ass. Again the difference is trivial percentage-wise La net profi, hut diametric t oquity investors. The more fixed deh, thw mare surprise and valalility in whatever is Toft for shareholders. The ratio of debi Lo hal reonainder, called “equity.” is Whe leverage meant, Stock in this security sense means the sami: as shares ar equity. Chapier 4 MiL's lea 111/16 20 Mowe [11ry to pul this together. Stack prices collectively, meaning all shires al current prices, is called “market cap.” {Cap is capitalization.) Market cap does not ‘measure tae whole underlying value of the issuers, meaning firms that issued the stock, since there are debt claims that must be paid off frst. It measures the equity residue. It measures that imperfectly hecause some incfiiciency and ehicanery are Tiere to stay. ths more volatile than the debt labs because ts leveraged, hut roally less volatile, given the phservial reality of Lends sawing smoothed-put reaction of share prices to news aver Hine, than what wauld be bid for the underlying assets, including intangibles. subject Lo Une same debi claims tal mist be aie first, Mational accounts measure market-valued (physical) capital by beginniog with ‘market cap. They then add the matket value of debt claims on the same issuers, along with equity and debt claims on the rest of the business sector, and then the same for the housing sector. The sum is "private wealth Consumer durables such a5 cars and refrigerators are excluded as oipractical to price. Government wealth meLaf national wealth is tracked separately, and Lends Li shaw as slight ar negative. Findling the Free Growth Index far Stok Markets My concern in (his chapter is (he slock mkel as dala source for testing (ree arowth theory. Here (4.2) would read total return in place of (net) output, while rowsth would be in marke cap. Consumption in (4.2) would become dividend yiek! in the sense net of capital concurrently raised it new stock issues. Ihe Global Financiol Data website summarizes the history of world stock markets from inception in about 1706 far LK, about 1800 in 1S, and later clsewhere, A nice feature af this data source, and most ather sources fox stock and security perfarmance, is that market values are shown fram the start. This left on ned ta correct for the inewilable lags in depreciation acounting, which gels the news anly in purchases or sales. Chapier 4 MiL's lea 111/16 21 Global Finacial Data reports annual rate of return, prowih rate in market cap, and “imputed dividend rate” as the difference. Dividend rate itself is reported as something a little different, { made no attempt to getto the bottom of this distinction, just as | made none 10 allow or editorial bias in the Pikerty-Zueman website. | chose the imputed version for logical consistency. This hires infarmation obviates the dan of easing rom (4.2) la (4.3), and allaws me ta Jump to the latter. "Productivity gain” in (4.5) Is shoply annual change in reported rate of return, Aceleratian is anual dhange in reported market cap growth vate, (4.6) defines Ure free growth index as (heir ratio. p(SM), the green line, tracks it in the charts. It too fluctuates around the number one. Gains in dividend rate have caimeided as often with gains in market cap grasth Tate as with drops. This seems avly expound whl everyane knows. Of course firms are likelier Lo suse dividends in years of growth, aod cul them ia years of decline. [never claimed that free groveth theory does more than state the obvious. What is ade obvious by the daa is that a change in (otal relurn is (be prime mover enabling marked cap and dividend rate 10 accelerate or decelerate as a pair, What is made obviously wrong would be a thrift theory casting dividend restraint as the prime mover. Were that so, ‘market cap acceleration would coincide with lower rather than bigher dividend sates. This pretty mich completes my evident For frie growth teary. Dhave nol. fun ather pramising data sources. One is tantalizingly close tw han. There is nat much reason why corporate bond history is less transparent lo the world than corporate stock bistory. A qualified expert might reconstruct market caps of both, side by side, 10 show a picture of the whole corporate sector. Surely | am not the only person wha ‘would take interest. What is the history of leverage, and of total return, and its growth and yield componeuts, to debt and equity claims cap-weighted together? Chapier 4 MiL's lea 111/16 2 It would be nice to test from such a dataset, again starting from (46), to see if free growth theory holds again. Who knows? Meanwhile, | think, the case is closed. All growth at very large scales is free unsil proved otherwise. Where Docs Opinion Stand Now? What should we make: of this evirtence far free grawth in salinnal accounts and stack market data? Lawmakers would prabably demand a recount or an mvestigatinn. Tax lows discourage: consumption and dividends Lo encourage growth. Yet data show that lower consumption vate coincides s often with lower as higher capital growh tale for eight nitions over four to fourteen decades, They will show the sume for dividends when we come 10 that, Economists would be less surprised. Solow has prepared them for the news. In 1956 and 1957 he showed evidence that most growth is not explained by capita) accumulation, ar saving traugh consumption resteaint. 11is Nobel prize acceptance spec fn 1988 includes: <0 the bigming, (vas quite surprised at the relatively mor part the trode ascrined 10 capital oration. Five when this was confirmed by Denisin and uhers, the result seemed Contrary ta comuon sense. The fact that the steady-state rate of row is dependent of the [aves tia quota was cosy to understand; t orly required thinking, thesugh the theory. [Lwias harder i feel cortariable with the conclusion that even in the shorter run increased investment vsauld do very litle for transitory gee. he transition Lo a higher equilibeiun growth pa seemed after very litle leverage for policy aimed at promoting investment, The foreral mode) omitted one mechanism whose absence would dearly bias the predictions agaist iavestanent. That ts what called "enbodiaent.” the foct that eh technlogical progress, mayhe most of iL could ind its way into actoal production only with the use of nev: and different capital equipment, Therefore the effectiveness of innovation it increasing outpuTvould be paced by the rate of gross Chapier 4 MiL's lea 111116 23 vestmont. A policy to merease fvestzent would thus lead not only to higher: capital inteosity, which might aut mater much, but also a taster transfer nl nes teehnnlngy int actual production, hich wanld. Steady-state growth wuld not he affected, but iiterediate cn transitions vould, aud those should be observable. That idea seemed t corcespind Lo comu:on sense, aud it sill does, By 1958 was able to produce a model that allowed for the erzhodiment effect... If corrman sense vas eight, the embodiment model should have it the facts better than the earlier ane BuLiL cid ni Densinn (1985). swhirse judgment | eespect, came to the. eanclusion that there was no explanatory valle in the anbodimentiden. da nt Know: if that ud should be described as a paradox, but ros atleast a puzzle. Edvard Denison was another leading growth economist Solow consulted. Remember that Salow had defined diseinhodicd grawth ta mean better use of existing assets, as wher ships carrying coal Ls Newcastle ae inspired reserse the Business plan. [Lis easy ta see haw disembodied growth could come mare ar Tess for free. Bul Solow puzzled how embodied growth, which needs “neve and diferent capital equipment,” could artive without * a policy to increase investment.” It can for the same reason that Achilles can overtake the tortoise. Solow’s problem, | think, may have been that news and diferent capital equipment stands to embodied novelty a5 a new and different chicken laging a nev and different egg, We can see Ts Uh different capital might. cone rst Urigh saving from cansumptian. deferment. And ft secs clear that the cmbadied novelty could not. But ane of the Beauties of calculus is that it alls chicken and egg Lo evolve simu lancously. Neither navelly precedes the other at the instant of first embodiment. This lime iL is Newlon od Leibaitz Lo the rescue, long wilh te trusty Gunnar Myrdal, if] guess right about Solow's misgivings. Since he understands calculus and Myrdal far better tha | do, [ may guess wrong. So let me try another way. It seems to me that embodied growth is still disembodied growth at a finer and more basic Chapier 4 MiL's lea 111/16 2 scale. Instead of redeploying finished goods, we recombine raw materials, We aren't creating something from nothing. And growth is not so free that it needs no cost at alle still needs depreciation plowback. Net investment would mean any in addition. he charts and tables, a5 | read them, show steady smoke of deprecation plowback Paying for all innavation, embodied or disembodied, that capes as best it can with goad thnes or had. The steady stroke metaphor, showing how cast (the steady stroke) and grawth {against the shoreline) vould he desynchronize, explains the passibility of Tree growih. TL dues not explain why Une record shows no other kind. My best guess as an explanation would lovk to biology, The biological imperative shapes our lastes and behaviors for lineage survival in some sense of family or population or species. Other species crowd their niches. They canuot gain by consumption restraint for the two excellent reasons that there is no consumption to spare and no niche space it there were. Ricard, Malthus anil West all warned against role replication in econamics already duvwlopel, We must create means Lo make more from Jess. [suspect Ui we are up against that wall mare or less continually. [novation pushes he wall back when genius and happenstance are al heir best, und helps us survive the rest of the time, Jt costs the same either way. Consumption sacrifice is sacrifice to gods who work theic will Reedless of it. My implication that we have 1to consumption to spare could mislead. Rather vee have none safe ta spend. All creatures hold back reserves against agversity. Feonamies usually carry move capital, jreducing more cansuniption, than they need Tor awe, Tt bs a vay day fund ta bie dian dawn in lean times anid built back in lush ones. Many nations inde capital Lo keep up consumption during the warld wars une world depression between, and reversed course since, Bul we would be Tools Ly spend iL For return iver Lime when the next crisis might come tam rrow. Chapier 4 MiL's lea 111/16 25 What exacily do | picture as this capital reserve? Is it vodka distilleries thal might be converted to orange juice plants in a pinch? | don't really know. Human capital itself is versatile, Some retirees could unretire, and vodka plant workers migat convert with not much retraining. [will explore seme of this idea later. arrod's Knife Bdge Solas neaddassival growth mide] developed from ideas published a decals varlier hy Roy arrod. Harrod had described a "warranted growth path” given by the pace of techavlagical innovation. [ie reasoned correctly thal any ford Lo push investment faster must soon founder in the diminishing returns foreseen by Malthus, Risirdo and West in 1815. Bul how could we gel investment exaclly right? There was a critical “knife edge” with ttle margin for error. He was right to stress the dangers of overinvestment. do the same. But free groveth theory, and the overwhelming evidence that it i right, bring a new perspective. What Solos and other ccanomists teach today. judging Frown the textbooks | read. is more or less Tarrod without the knifis edge. We are taught 1o igure aul the warrant growth pth, meaning Une rate of fecholagical growth, and then invest just enough. ex ante, Wo exceed depreciation by (hat margin. Bul my charts and Lables show thal any investment beyond depreciation recovery is deadweight loss, There is no ceed to know the warranted growth path because opticum investment is nota. function of whatever it might be. Depreciation investment captures the whole of techuological growth, and further juvestment adds to more, (ts money left on the table. Optimum ex ante fuvestment, at the collective scale, is depreciation investment. Ex past results will reveal the warranted growth path What about Underinvestment? One indication in Une charts an Lables might leave us purzel. Lis easy bo understand be futility of ex ante investment (consumption restraint) beyond Chapier 4 MiL's lea 111/16 26 depreciation plowback in Light of the diminishing reluras described by Ricardo, Malthus and West two centuries ago. We might crowed our niche, like other creatures, and leave neither consumption safe to spare nor room for capital accumulation before diminishing returns set in. But to litle investment could seem a tougher challenge. No thrilt at all, meaning nat even depreciation plowback, would mean no growth atall. Then consumption rate wauld vary versely as capital acceleration, justas predicted in in iil teary. And underinvestiment, meaning Mowsback of less than current cost degrectatian, aught to happen aboutas often as overinvestment If cath year of underinvestment Lend to ithe preslictians of thrifl theory even a little, free gravih indexes should average something Jess tan ane io the end. Bul they dou, The index varies, bul averages more han one ss often asless in every country and period. “the explanation | suggest is already implied in that insight of tyeo centuries ago. fust as averinvestment and capita) glut diminish returns, underinvestment and capital Shortage augment them until supply of capital catches up ta demand. Fen if there: were na plawbiack al all in some years, higher returns Us capital alreaiy in place wan help Lake up the slack, There would be rval danger in sustained underinvestment or overinvestment, The saving grave is in market forces restoring equilibrium us investors mimic return. Sumanary This gives the outline of free growth theory. Ltis my best speculation on how to ‘make sense of the charts and tables. It olloves Mill more or less exactly, and risks the next step in the hold new direction pointed by Solow. My prize exhiliis are the charts and tables. Better this bank should shaw them alone, with an explanation af my Lesting equations and te data spurces, thar all the rest without them, They could birdly support free growth theory better hia if Mill and 1 nl rigger them. The canseequences are huge. We must gel rid uf the cor orate double tax ASAP, and raise the corporate lax rate enough lo make he overall Chapier 4 MiL's lea 111/16 Pl adjustment revenue-neulral, That shoukl help get both pasties on board, We must tax capital gains at the same rate as ordinary income. Dividend rates should revert 10 the 4% - 6% range typical over the centuries before the pro-investment policies Putin place after World War [1. We must do whatever we can to level the consumption investment playing field Obvious sualiers are wrth spelling oul. (4.1) and all conseruerces are meant lo describe atthe calleetive scale, where growth cannot be exphined by transfer, Free growth Uneary assumes ihepreciation investment, nol sera investment, My charls onl ables will never be exact, There ace inevitably ecrors wor judgment biases in the national accounts wd research assembled by Pikelly and Zucman, more adiled by them, aud more by me. These cautions will apply to later chapters us well, Chapier 4 MiL's lea 111/16 28 HOUSE_OVERSIGHT_011018. CHAPTER 5: BRINGING HUMAN CAPITAL IN ‘Human capital is labor measured as a dollar sum rather than as so uch per hour or year. (treats pay less juvested consumption as our cash flow, and finds our present walue (to ourselves) as expected lifetime cash flow discounted by our own time. reference rates, meaning what we would charge for delay. Measurement in this way usually finds ftas something near three faurths of al capital. Physical capital, much beter understand ease iL can be baught and sold as well as hirer, is uly thevlsible tp of the leeherg, The term human capital itself is touchy because ft ean suggest hat lik Hiss a price. Trving Fisher used it in quntatian marks in 1898, aleibuling it fo eacliar sources | haven't found, bub out in his wo great books on the topic in 19067 and 19077, Wikipedia is mistaken in allribuling the erm to Arthur Pigou a generation later. History of the Idea “The cancept began with Petty in 16641. ie estimated the aggregate pay of English worlkers, and divided by the discount rate he had modeled in A Treatése af Taves two yrs ua rliur. Chav not oad Verba Sapienti, hu have: read tea of bis later: versions of the same argument’, Petty'’s method wis criticized by William Farr in 18545, also in a paper { haven read. for neglecting what [ call invested consumption. Farr, if | read the right description of his argument, was both right and wrovg, Petty was modeling hun capital of aggregate workers, These were mostly adults, who no longer receive invested consumption if my mode! is right. That makes his method sound it principle for ‘measuring adult human copital separately. It follows that he underestimated the Iman capital af England, rather than overestimating ftas Farr clafined, by leaving ! Tie ature of Copii, ie Rete uf crt, tic Ariiurest 167) ani 2 mss fifo f he Weaith of Engtaod (164). © View! Stari. ChapierS Scinging Humar Capita. Ie. 113/16 1 out he human capital of children. Bul Faur deserves credit for polnting oul that human capital in general capitalizes pay less invested consumption. Keynes’ teacher Alfred Marshall agreed with Fair in 19907, As | read this passage, Marshall interpreted maintenance consumption as investment. So did i. . Kiker in 1960.1 interpret ftas exhaust i taste satisfaction enabling energy ta carn pay cancurrently, wahili preserving bub not increasing pay expectations in future, Tovested consumption would mean addition to human capital concurrently for expected rralizalinn with interest in higher pay later Meanwhile economists had developed Ue complementary ides of human capital is present cost of investment accumulated before. Adam Smith? in 1776 wrote the acquisition of such talents, by the maintenance of the acquirer during his education, study, or apprenticeship, always costs a real expense, which is a capital fixed and realized, as ft were, i his persan. The conversion of same consumption into Human capital was 4 Favorite Ue of Frank Knight a generation before Schultz. Only the rest is what Schultz called pure consumption eliminated from (he economy i sulislying Lustes. Becker added in 1954 that this luvestment must be expected to be recovered with terest, at least when paid by employers in job training, Schultz had also pointed oul thal buman capital depreciates, and invests sotne work in itself in the effort of learning to complement the exterior investment of nurture and schooling, Ben-Porath, expressing a Schultz-led consensus, added in 1967 that human capital growth is fnvested consumption {the nurture and schanling) plus seif-invested work less Tuman deprecation. All these ideas are now accepted everywhere In human capital studies. #0 Mistry of humm Gopal 1 earned of Far from Kiker. ie uit of Horians ChapierS Scinging Humar Capita. Ie. 113/16 2 Jacob Mincer seems to have been first in print with the post-war revival of interest in human capital, in his 1958 paper rederiving Irving Fisher's present value equation and stressing fob training. Schultz impresses me as the main idea man among these post-war contributors, lle usually avoided math, unlike the athers, and is Jrohably the best source For quates in plain Buglish. IMs paper fivestient fn Hanan Capital, published in 1961, includes: Much of whit we call conswmpion vanstitules investment in human capital Direct expenditures on education, bealth and internal migration lo Take advantage of better job opportunities wre cle examples, Earnings foregone by mature students allending school and by workers icquiring on-the-job Lraiuing wre equally clear examples. This use of leisure time to improve skills and knowledge is widespread... shall contend that such investment in human capital accounts for most of the impressive vise in the real carnings per worker. Measured hy what labar contributes to OUTpUL the productive capacity af human hings bs now vastly larger han all wher forms of wealth taken gether hes ere relating income ta age Lrends Lo be steeper far skilled than lor unskilled persons, Jovestment in vo-tbe-job raining seems a likely explanation. We can think of three classes of expenditures: expenditures that satisfy humau preferences and in no way enhance the capabilities under discussion - these Tepresent pure consumption; expenditures that enhance capabilities and do not satisfy any preference underlying consumption - these represent pure investment; and expenditures that ... ave ... partly consumption and partly investment, . 019621 he added: the investment In human capital can conveniently be dassified in (1) nurturcand higher education, (2) poststhuol training and learning, (3) preschav) leaning activities, (4) migration, (3) halt, (6) information, ami {7) investment in children {papulation]) ... 9 guest in Mn itl wns sani cams sn tion 1 tama pita Pit sos ond Resoares Opportunites ChapierS Scinging Humar Capita. Ie. 113/16 3 .. But unlike the wonderful “one-hoss shay,” the productive life of educational capital typically docs not go to pieces all atouce. It depreciates along the way, it becomes obsolete, itis altered by changes in retirement and by the state of coployment .. As already noted, educational capital, like reproducible physical capital, is subject 10 depreciation and nbsolescence. The established tx Lreathient takes accaunt of hath depreciation and obsolescence in the case of physical capital, but this accaunting is nnd extended Lo education capital... In brief, our lax laws... appear bn he all ut blind fo the Tact that educational capital entrails maintenance and depreciation, becomes phisolele, and disappears at death... These excerpls cleily show Shull’ meanings of pure and invested consumption, and of human deprecation. He says “pure investment” it place of my “invested consumption”, but 1 prefer to follow tradition by applying “invested” to physical capital alone. We also see his belief, with which | disagree, that substantial invested consumption continues after independence and physical maturity. For example, he writes “Direct expenditures on .. health and internal migration are clear examples.” interpret these outlays, when applied ta adult workers, as maintenanee consumption preserving rather than adding skills, and enabling current pay rather than invested for higher pay later. Tagree (hat self-invested work “to improve skills und knowledge .. accounts for ‘most of the impressive rise in the real earnings per worker... But | dou't share Schultz’ view that the "use of leisure time” accounts for much of this improvement, My years in plans and oilfields and offices have given me an fiapression of some study hy workers during lelsure tone, but mostly passive accumulation of experience and insight while Tully at work on the job. Practical Uses Orne obvi use of tne human capital dia is to compare the factors (man and radeable capital} in the sane dimension. Capital anil [shor Gannal be added, is Pety kai, since capital is measured ir dollars where labor is measured in dollars ChapierS Scinging Humar Capita. Ie. 113/16 p per unit lime. Bul Petty showed that tbe ides of human capital ss discounted cash flow measured in a money sum allows the factors to be summed together. The revival of interest at the Chicago school soon inteoduced the term physical capital for land and man-made things that can be houghtand sold, and total capital for the sum. Physical capita) is a misnomer in that we are physical too. But | have used it throughout so that ccanaists can fallow in and general readers can piek uj some of their ngage. From the ¥ = C+ 1 Equation to the ¥ Rule Chapter 2 summarized my argument adjusting the Y= 1 Tequalion lo Ure Y rule. Chigpler 4 spelled oul We former in (4.1). The ¥ rule made tbe hidden asterisks of the ¥ - C +1 equation explicit. said in both chapters that the free growth equations ave the same for both when we allow for the asterisks. Let's go through the derivation of the ¥ rule again. {4.1) shows output = investment + cansum pian. 1 genevally mean Une version of bis where ex post net” is understood before both “output” wad “investment”. | said that this idea is implicit in the Mill quote, and is probably as old as econotnics. Net output, here or anywhere, means creation of value, Then he equation would be guaranteed by the truism, at the collective scale, #f vet investment meant growth of all value existing, meaning total capital, while consumption meant climination from total capital collectively and nothing clse, But netex postinvestment os meant throughout this hook, and anywhere in macro, means growth In physical capital alone. Consumption includes Schultz: vested consumption transferred inta human capital as well as his pure consumption eliminated fram tala capital as a whale, Wha the Lruism guarantees is rather out pul = total growth | pure consumplin, [2] ChapierS Scinging Humar Capita. Ie. 113/16 g al the collective scale ind where "ex post nel” is gain understood before “output.” {5.1), but not (*.1), guarantees that terms are mutually exclusive and exhaustive. otal growth means this ex post et investment {growth of physical capital] plus growth of human eapital. The latter would have puzzled us hefore the contribution of fien-Parath. Fquation (4) In his 1967 paper, summarizing the first three, shoves nan grawth = Invested consumption + scll-vested wark ~ human depreciation, “2 using my terms rather than is. Chapter 6 veill argue that this equation nceds to be clarified. { gave a preview in Chapter 2, and will update it now. Work is the output of human capital, Output is not always positive. It is negative whenever growth and cash flow sum to less than zero. Anegative sum of these two shows unrecovered decapitalition (also called deadeicight loss). That would include unreeovered human depreciation. If (3.2) cant all including negative sel invested wark less all ind ding unrecoverd human depreciation, it would subtract uncecovered human depreciation lice. Then iL must be corrected either lo buman growth - invested consumption + positive self-invested work = human deprecation, 3) or equivalently ‘human growth = invested consumption + self-invested work ~ recovered bumau depreciation. (3:33) Itis clear that Ben-Porath meant (5.3), os other ceidence shows that he treated Iman depreciation as unrecovered. So docs all tradition, mistakenly | believe, with Chapior s ringing Humar Capita. I: 113116 6 the partial exception of Becker, vill generally prefer (5.34). although (he wo are identical in meaning Schult’ analysis of consumption found cansum tion = vested consumption + pure consumption 54) This plus (5.1) and (5.3) cabin for autpul= total growth | pure consumption ~ investment + buman growl + pure consumation = investment = invested consumption + self-imvested work ~ recovered buman depreciation + pure consumption = investment + invested consumption + self-mvested work ~ recovered buman depreciation + consumption invested consumption = investment = consumption + self invested work recovered human depreciation. i55) “Fix past net”, as always, should be understood bfore bath “output” and “investment”. Chitpter 6 will revisit Wis logit once again, and add a secon way Lo Une same conclusion. ‘The Growth Equation Under the ¥ Rule 15.1) can be arranged as Total groveth = QUEUE - pure consumption. (5.12) asa counterpart ta (4.14), Tatal growth means growth in total capital, My argument continues asin Chapter 4. Since (4.2) was blind alley. skip 1 {1.3 Thil now becomes ChapierS Scinging Humar Capita. Ie. 113/16 7 Wlalgrowlh _ oulpul pureconsumption Ga tol capital ~ totalcapital (ob capital © _ which can be written as total growth rate = total capita) productivity = pure consumption ate, (5.60) as with {4.3a). Since (5.64) is always Lue, and nt oaly under acasinnal circumstances, we also get change in tal growth rate = change in total capital productivity ~ chunge in pure consumption rte, {5.7} This parallels the logic of {4.1}. Again save space by reexpressing this as total acceleration = tatal productivity + total thrift, (570) wher "otal" mens "af Lota capital”, Now divide by fotal acceleration Lo reach the counterparts of (45) and {1.50]. Iwill sometimes save space. from now on. by expressing these arguments in he equations of Chapter 4, as for example in leaving the words “total” and “pure” smuplicit if the context shows that | mean them. ‘The Slave Pacadox Say that Phil enslaves Bill Bills maintenance consumption had heen taste-satisfying pure consumption to Bill when Bill was fice, and so was nat deducted from his pay to find Hiss gross realize putput as valued by himself. Nut BFS maintenance camsumption satisfies 10 tastes of Phil. Cash Naw is gross realized output less owsback from revere less new investment from outside, for either factor, while ChapierS Scinging Humar Capita. Ie. 113/16 3 nel output is gross realized oulput less depreciation plus proprietary output. Both drop by the amount of Bill's maintenance consumption on Uhil's books as a slaveowner. So then does Bill's present value of that cash flow. “This noi thought experiment is worth thinking through It shows that even if slavery were legal and cannon, its market evidence would neither shaw the value oF armas ca pita ror refute the Fact thal human vapital is inalienable [Lis nalicnable for the reason, anc other, that our maintenance consumption satisfies an ae elses Lastees. Phil did not acquire Bill's human caital. fle converted it to livestock worth much less. Another useful point is that assets in general tend to be worth more 10 their owners. his does not contradict the convergence axioms, We buy or build to taste. That difference is particularly important as fo assets not meant to be traded, such as productive plant | suspect that this is what the national accounts missed in adjusting depreciation. Maintenance Learning Ben-Poralh argued, persuasively [ believe, thal both kinds of invesiment in human capilal must end when not enough ime remains for recovery with interest, Those two are invested consumption, including schooling, and self-tnvested work. | Propose thal invested consumption substantially ends al maturity wad. independence, Self-invested work of learning continues long after, as there remains no other adequate explanation of age-wage profiles. When does it stop? Learning fescif continues to the end, Yet if fien-Parath is right, and he is, self- nested Jearning stops well before. What continues, [hink, is what 1 call “mainbenanie lesrning. Lis defined as Jearaing bs keep up pay now rather than Lo eniance pay liter, AL) ages, we oust learn the names and trails of new clients und coworkers and suppliers anid regulations continually 1a do whal we are paid far. ChapierS Scinging Humar Capita. Ie. 113/16 9 This observation helps clarify my hypothesis thal job learning costs no lime (hal ‘might otherwise have been spent earning pay. My deeper meaning is that invested learning and maintenance learning are the same process costing the same time bur with different ceonamic ctiect, Iouch as with invested and maintenance consumption. Tiddence tal hourly if rab yearly pay rises until retirement, br very near, would refute Ben-Porath's claiin If human capital ended at retirement. Bot it continues thevugh relivement hcause imputed pry does. Milland 4 few economists before him acknowledged “productive” and. “unproductive” consumption. The productive kind wis what | call maintenance and invested consumption. Unproductive consumption meant any written invested for higher pay later nor supporting survival pay now. That veould give JUTE CaRSUMPON = MAMEENaN CE camSUMpLian + unproductive consumption (38) an consumption - invested consumplion + pure consumplion = invested consumption + maintenance consumption + unproductive consumption. (5) Investment and maintenance consrast in human capital as it a firm, Investment is valued only in the expectation of future maintenance. No maintenance later, no value now, To COUNT MATNECNANES 25 New Investment ould count par of the ald Investment twice. Where the accounting treatments differ bs in disposition. Maintenance in the hrm is recovered in pay and products. Thought before that the sume was true of human capital, Thanks (b the parable of the boss wot her secretary, Trane [think i is haustend in satisfying aur taste for linkage survival. ChapierS Scinging Humar Capita. Ie. 113/16 10 Restating the Three Fourths Rule Petty, neglecting human capital of children, measured total capita] as about 25 times physical capital in 1664, Most estimates since have run higher. { myself model 4:1 075005 0 Pastapproximation. The ratio of human to physical capital might hold to some such lasting norm for the same reason that number of shepherds should Todd fn proportion ta number of sheep. They own as many as they can manage. Mirman capital means vi af skills, including skills i acquiring and employing hysical capital. IF the valu of physical capital changes, so should the value of its management. There is truth behind the old doting Wit a rise in Uy productivity of Tabor explains growth in value of physical capital, Bul old skills can ulsa be mare in demand when inprovements in physical capital productivity can gel more good oul of them. Drivers are worth more when there is more valuable freight to be trucked. Arise in either kind of capital tends to vite a vise in the other. “The Yatia oF pure to invested consumption is unsettled in human capital studies. | Just shaved why 1 think Schultz gave the right chuc in 1961 when he defined invested consumption as an outlay Lo be recaveered with interest in consumption aver the future, nd pure consumption as an outlay bringing taste satisfaction now, Wis the sume distinction as with investment and operating expense in the firm. A profession's meals and doctor bills, and even his subscription Lo trade journals, are expenses needed to keep his earning power intact rather than Investment to raise it over the future, seems to me ial once we are physically mature, the only avenues of investment in skill building, not exhuiast in skill maintenance, are self-iovested work and fob training or other adult education. And | argued that there is probably nat much adult education. Only a few go hack to schoal. From what I've seen, job raining is concentrated fn aur first fess months. when schanling is over and full-time wick begins. That's why T think tat the rise of pay wilh age, implying a rise in skills mirketed, is expluined more or less entirely by selFinvestead wark in the mainly sublimin accumulation of job experience, (Wark ChapierS Scinging Humar Capita. Ie. 113/16 1 means the output of human capital. id notbing in (be definition of output implies effort or even awareness.) Iagree with Ben-Porath that all consumption and all work should be modeled as sell-invested until independence and all-time job entry, given that madels must Spy. But] just showed why [model all cansunption after, ar anyhas after a few months of job raining, as Sehulls? gure Kind. Were [would Gaull. Miner and his pupil Becker, but nat Schultz ar Ben-Porath, far tao much focus on the patential of Jab training. I erxisbs and is ervicial. Rubi is so small a fraction of invested consumplion, udging from my experience, that prefer to neglect it in madeling, Job learning, conversely, seems Lo expliin all rise in pay with age. Biology might predict the same. Nature's plan is that we first develop and then reproduce. Some creatures follow shavply-defined somatic and reproductive phases showing iest ony development and then auly reproduction. A mature butterty dics nat cat. It may even lose mouth parts. Its tine fs spent 4 reproduction alone. Other creatures including us Hike eating Loo, bul ra bur gives them hat Liste for the: sakes of ie pow behind. Adult consumption, s [see i, is more ar Tess all purs cansumplion exhausted from totel capital in salisfying our taste for life and energy. Consumption by the young is invested because that is he big idea. Nature's plan is reproduction to maturity. Now suppose for simplicity that consumption is age-independent. Nobelists Milton Friedman and Fanco Modigliani, mentioned earlier for their opposite reactions to my banking idea, separately argued something like that in the 19505 for adults. My extension backward to birth seems defensfble whe we remember to include unpaid parental care: and then schinoling In invested consumption. Lmadel human capital as continuing aller retirement as present value af implicit pay by ourselves aul others for caring for ourselves and those others, Then if adulthood runs from ages 20 16 80, Use simglilying assumptians vend give pure wonsumplion as three fourths ofall consumption, ChapierS Scinging Humar Capita. Ie. 113/16 12 Jalso modeled human capital as three fourths of tote] capital. My tag for the two ideas together was the “three fourths rule.” The agreement of the two ratios as modeled is a convenient coincidence. If they differed, this baok would have to bea few sentences longer. Fach is first-order approximation any. The Free Growth Index for Tata Capital Given the three fiurths rule, the free growth Index for total capital is derived by reaning "pure and “total” before the works cansumgtian and caital in the equations of Chapter 4. Mow back to the charts and tables. Ihe free growth index for total capital is tracked in the ved line and labeled Ke). it too Huctuates around oue in each country, but in uch rr rower cane than dies Ue Blue line {K). The: reson is Ue hres Jousths rule, The thrill index, not shown in the clans id (ables, is one minus be free growth index. ltis derived in Chapter 4 3s thrift rate over acceleration, where thrift rate is change in consumption/capital ratio times minus one, by the three fourths rule, where pure consumption is three tourths of all consumption while total capital is four times physical capital, the pure consumption total capital ratio is only 3/16 (3/4 divided hy 4) the size af the consumption physical capital vatia. The yearly changes in these ralins reflected in Lhe numerator of the theif inde will hald fo the same proportion, The denominator is scoelerstion, whic is always (he same for physical as tolal capilal by (he assumption thal they hold in 1:1 proportion throughout. This explains why the unshown theift index, or numerator over denominator, is automatically 3/16 as large for total as for physical capital, and why the shown free growth index runs nearer one in consequence. Ihave just given an idea why it can be worthwhile to brush up the algebra we all Jearned in high school or before, and to suffer the nuisance of mathematical notation Ihave made a very simple tush, obvious in hindsight, seem complicated by making ChapierS Scinging Humar Capita. Ie. 113/16 13 do with swords alone. Ove less something neacer zero, whether (hal something ((he thrift index} is positive or negative, is nearer one, The wonderful books of Einstein {eth knfeld) and Steven Hawkiog, not to mention ¥ill, show that even calculus can be put that way. My task has been to follow their tough act. But [will now start to infiltrate notation where | think that that farm of shorthand should help mure then ithurts. Summary The daa Tor Une ree growth indie of tal capital (KU) in the charts and Lables di not represent a separate test. It is the same test adjusted to the three fourths rule. ‘that was proposed as a convenicnt rulc of thumb. | would have shown a true Separate fast if lew how. PUrc consumption might hecome separately measurable some day, but human eapital will nat. The Phil and Bil parable shows that nat even evidurice rom shave markels would bu an pint. Wma capital has na possible value lo any but its vriginal aener. Whether in words or notation, | hope to make the point tht Chapter 4 and the chitls and lables showing {K)are likely Lo understate the case for Mill, Those showing q(K,) should be nearer the truth, Physical capital and pure consumption ave less thin the vehale, My three fourths rule will never be exact because reality cares litle for the convenience of modelers. Proportions between the kinds of consumption will not hold exactly constant and will never exactly agree. Hut | don't think the three fourths rule is so wrong that the real value of p(K,] doesn't run nearer one than the real value af G(K). (The infiltration begins) then the data support free growth theory convincingly enough if we trust equation 14.1), as do all macrocconomists as far as | know, and probably move convincingly when human capital is considered too. Chapior s ringing Humar Capita. I: 113116 1 The cauions a tbe end of Chispter 4 apply even more. My charts and Lables for BLK, ) repeat the accumulated error and bias of thase for ¢{K), and aid the crue simplification of the three fourths rule. (5.4) expresses my understanding of what Ben-Porath means in equation (4) in his 1967 paper, where variables are defined in his three equations before. If (5.4) doesn't capture his idea faithfully, it ang how captures wine. 1kesrise ny 5.5) may or may nat do justice to Schultz. Some bot not all possible interpretations af what he might have meant give (5.5). Again, itis my helicf whether or no his What Farr, Marshall and Kiker have shawn, by declucting both invested and maintenance onswmplion (rom pity (o gel adult cash Dow discounted to preset value, is human livestock value Lo a skaveowner. [Us very litle. The parable of Phil and kill argued that Bill's maintenance is expensed on Phil's books, but treated as net output and positive cash low on Bills. said | can't prove that from axioms and definitions so tar, and will need the biolagical imperative. Chapior s ringing Humar Capita. I: 113116 15 CHAPTER 6: PARALLELS WITH THE FIRM My Owa History with These [deas For sheer shock value, at east to economists, the pay rule and the ¥ rule must count frst amount the surprises promised, Who would bave thought that human depreciation is expected to be ecovered in cevenue pay) and product value just as with plant depreciation? Heresy! Yet nothing is more easily proved. Either the ‘maximand rule or the deadweight lass Tule is enough. Freee granvh theary and mel generation theory give more scope and policy implications. Bul the pay and Y rules have plenty of those, aod my be new a the warld. Mill and Pelly beal me lo Lhe others. Ihave been arguing the pay and ¥ rules from the time { reversed course from Quesnay's idea some tive years ago. | will rederive both in new ways at the end of this chapter. My change of mind was a classical epiphany. 1 had heen resisting the obviaus for years. [showed haw my parable of the bss and her secretary gate on track. My depreciation thenry is a Jesser shock. IU nccnrred fa me over the Christmas lida this year. 1 contradicts the ralipnal accounts, whose Capital Consumption Adjustment corrects hook depreciation (rom linear Lo exponentially fling. That would make depreciation fastest al the start, and progressively less, No one hes objected because practical experience seems to say the same. If we resell a new car or house after only a few months of use, we tale a big hi. we resell a new factory, which would have been atlored to aur unique husiness plan, we take a bigger one. My counter-argament is that premature resale reflects adverse selcetion. The usual moti for premature trade is had news and pressire sell, not pressure: from others bu. Chapier G: Paral swab Frm 2416 1 1 point instead to (be millions who dou't sell. [argue (hal depreciation and amortization are the same in essence. Loan payments are all interest at the start, and all amortization at the end, by infecence from the present value rule. My risk theory is a mini-surprise, I shits focus fiom the risk of the asset to the risk aversion of the owmer. Another mini-surprise is the feature of my growth truism Iti OU that deadweight Iss wicans negative unrealized ouput. Twill revisit these toples fn more depth alter | caver the necessary groundwork fn comparing the axcauntancy for human capital and the firm. Assels, Owners and Revenue Assets means examples of capital of either factor. Their owners are all members of the reproducing population assumed in the axioms. Each, (rom newborns up, owns human capital at least, Value and growth and cash flow and output are properties of capital. Tastes, ais and ends are properties of owners. Human capital reads its owner's aims, and manages both factors to realize them. Positive cash flow is outflow Irom assets to pwners, ta exhaust or reinvest ar give away as they like. in thas twa cases, Ue owner is mediating Lrnsfir aul. She also mediates transfer in rom reinvestment or gil receive, “Think of capital as source and present value of foreseen cash flows, Owners are te foresees, the recipients of positive cash Hows, the exhausters of some in taste satistaction, the deciders of the time preference rates giving present value, and the ‘mediators of transfer outand transter in (negative cash How). In the case of the diamond ving, the psyehic positive cash Haw arrived withaut mechanics. The mare typical ease reaches the same outcame indircetly. {Net output of an asset is its value added, or ercatian of value. Gutput ein he realized as outflow Wo ovsners for reinvestment or gifl or exhaust, ar iL can be lef in as growth. The part let in is proprietary or unrealized ar sellneested autpat. Chapier G: Paral swab Frm 2416 2 Qutllow Lo owners can aso include decapitalization from capital already in place, is in withdrawals from a bank account, | say decapitization, rather thao depreciation, because the appropriate term might rather be amortization or depletion or liquidation in sale, depending on circumstances and the nature of the asset. The sum ofthe realized output and decapitalization can be called “gross cash tow, meaning gross hefore deducting plowback and negative cash floss (ransfer in]. Then gross cash flow = cash flow + plowhacl + transfer in = realized pulp 1 recovered decapitalization. 1 Here | specify recovered decuptalization because | (real deatweight loss as decapitalization too. Cash flow as accountants and businessmen use the term usually means gross of plowback, although net of transter in. My meaning, net of both, is the one always applied in finding total return and present value. Althaugh cash flow might be in kind as well, {will follows convention by treating it as if realized from salc in cash. The pwner can then spend the revenue an exhaust {pure consumption) or reinvestment or gill as she likes, hut night alsa plove some ar all back inl ne originating ssset. The genveal principle is positive cash (ow gross cish flow - plowback, ®2 In simple cases, revenue measures and equals gross cash flow for each asset. Bur revenue as the term is actwally used is likelier to sum contributions from many assets and owmers. To kee that usual meaning separate, define this asset's shave as “earned revenue’. Then gross cash flo = carned revenue [) Anather sway Ln pul the same ied is Chapior 6: Pacales wits he Firm 24a 3 revenue - collective gross cis flow — collective ened revenue (64) fom all contributors to revenue together, Then revenue and carned revenue would be the same if there are ho other clams. Earned Revenue and Cash Flow A classical illustration of revenue generated collaboratively is the firm, The firm Joe can be interpreted as a single asset of physical capital ts typically many owners agree fa hire lside management, meaning autsile themselves, Lo contrac, onl rede on their behalf, The firm through its oranagers hires the other employees, contracts with suppliers, wad generates & joint product representing all its own ross cash low plus any contributed parts of gross cash flow of others. The product 5 sold for revenue fn the collective sense. Revenue is first applied to satisty claims on it by those outside contributors. Claims recovered include current purchases from suppliers realized in sales. Others ave pay to management and other employees, along with rent, interest, utilities, other services, and whatever is due to the tax man. The principle is 1a inclule all witlays by the fem need o secure reenne naw, ax distinct from autlaps invested for he sake of nore revenue later. The shiace of revenue due the firm proper is any residue aller all those prior claims are met. Then acoss cash low ~ revenue - prior claims ~ earned revenue (65) gives the connibusion of the firm proper. Famed revenue mag ov may not be passed to owners. Management is typically authorized to plow back any part as reinvestinant, say in replenishing inventary ar cash ain Buying new plan andl equipment. Any reve lefL over aller thal plowbick is transferred oul lo owners as dividend yield. Chapier G: Paral swab Frm 2416 p Megidive cash love, or Lrussfer in. aways means new investment added from outside, Ployback from revenue is excluded, as it i already recognized as a deduction from positive cash How. kor the frm, the only source of positive cash flow 5 proceeds trom new shars issucd. With this understood, cash Daw = grass ash lave - plawbaclc~ mansfer in ~ eamed revenue — plasehiack - manster fn = positive cash low ~ negative cash Naw, (66) where ‘positive cash (low - earned revenue - plowback, and negalive cash (low - lransfer in. 67) Fioms uso the tor gross cealized output to mean the same thing as what call gross cash flow. A common definition is gross realized output - realized autpot + depreciation Naw we come ta the subtle paint allowing for deadweight loss. The total return ras sh thal oul equerks valu grat plus cash Nave, Then ouput is negative wherever the sum of growth and cash ow is ess tian zero, Natural disasters and bad investments can make them so. Those unexpected setbacks are examples of deadweight loss. amounts to unrecovered depreciation, meaning depreciation not recoveced (realized) in positive cash flow. ll get back to that soon. the point at preset is that the equation above really means gross realized ougpuE = realized ouput + recovered depreciation. Tere Lao prefer the generality of “decapilalization” over “depreciation”, and define ross relied output - gross csh flow = realized auipul 1 rexovered dcapitalizatian =varned revenue | recovered decapitalizaon. (68) Chapice 6: Pacales wit be Fim 24516 5 The terms gross cash How, earned revenue and gross realized output will be used interchangeably, “Realized” and “recovered” will likewise be synonymous, as will be “proprietary”, "unrealized and self-invested” {AGT} allows realized output = cash flow + plowback + transfer in = recavered decapilalizailin. (6.14) Detine unrealized output = output - realized output = growth + cash flow - realized output =growth plowhack transfer in + recovered decapitalization, 69) hy (6.12) and the total retumm truism Proprietary Output and Deadwelght Loss Unrealized or proprietary vr selF-invested oulputof the firm is creation of value nol vel sold or nol meant to be sold. This can be something as workaday and perfunctory and automatic as output to inventory. Uther illustrations could be where «construction firm builds its own offices, or a car manufacturer makes cars for its executive fleet. (6:9) shows that it includes all growth not explained by plowback plus transfer i less recovered decapitalization, This implicitly includes all fee growth, Judging hom my charts and tables, ree growth seems to mean all of growth at the collective scale. What effect might it have on the firm? Freee growth includes andar win Fal gain and deaweight loss as ell as the averal upward tren expressing new ideas, Deadweight 1655 is unrecovereid dusapitalization, meanirsg not recovered in cash i, Thal makes iL negative output Chapier G: Paral swab Frm 2416 & she sum of growth and ces flow, ind specifically negative unrealized ouput Then deadweight loss = unrceovered decapitalization = negative output = negative unrealized output - max (0. - output] = max (0, - unrealized output). (6.10) Also ‘positive uarealized ulpul = mix (0, proprietary output), 6.11) and output = unrealized output + realized output. (8:12) The Growth Truism Tn general, growth = capitalization from oulside 1 capital ization (rom inside ~ decapitalization. (6.13) Here capitalization from outside - negative cash flow — transfer in, and capitalization from inside = positive vrealized output + plowback. Also decapltalization = recovered decapitalization + unrecavered decapitalization = recovered decapitalization + deadweight Inss. Then growth = iransfer in | positive unrealized vulpul 1 plowbick - recovered decapitalization - deatweight loss, {61m ar more simply Chapior 6: Pacales wits he Firm 24a 7 growth = transfer in + positive unrealized output + plowback - decapitalization. (6.19) 6.144) can also be expressed as growth = transfer in + unrealized output + plawhack = recovered decapitalization (6:14) Far convenivnce, define gross transfer in = transfer in 1 plowhack, So thal (6.14) through (5.14) can be pul more compactly as rowih - gross lransfer in + posilive proprietary output - decapitalizailon = transfer iu + unrealized output - recovered decapitalization. {6.14¢] Any of these versions of (5.14) can be called the growth truism. The new term gross teanster in will help shorten equations tor human capital. Management as a Quasi-Owner Qumers (shareholders) typically allaw management wide latitude ta cope with needs 1 stands in place of owners. Aceminting taritian, and this bok 1a, reasons ant Ue steps fram revenue Lo dividend yiuld as i managenent fell sere he owner Qberwise there vould be little Lo say. From the sharehokler viewpoint, revenue is simply dividend yield But the bottom line is the same. The maximand is output, or growth plus cash flow. Positive cash flow, in the sense net of plowback, is dividend yicld on both the i's Books andl the shareholder's. Negative cash flow on the books af shareholders Individually is purchase of any shares i the sain firm. On the hoaks of shareholders collcetively, where sales and purchases of existing shares aMfset, it shoplifies to purchase of new stack sues alone. This toa Is ust as on the baoks of the em. Chapior 6: Pacales wits he Firm 24a 3g My purpose in this unalysis of (he firm his been 1o derive equations valid for aay capital of either factor. The firm is a good model for several reasons, ts accounting teaditions ave centuries old, and have been well thought through. Itis rich in possibilisies hecause it has to be. [t must describe firms of many kinds, Jt must allow for contingencies whether or not they apply. For many simple assets, say the firs shares as opposed 1 ftself revenue and positive cash flow can be the same, But the campleaily and versatility of the firm ilself, and the persan-likeness addi by ils Internal management, wake ita useful model far any and all capital of either Factar. Not thi [client follow sccountivg tradition closely, ar even to understand it closely. Tun even less an accountant than so economist. My erms and concepls ten to be idiosyacratic. The main thing is for the logic 10 hold together. Human Capital by Analogy to the Firm tis reasanabic to define pay as the revenue of human capital. Eamed revenue for the fie Is typieally less than revenue. There ave prior clalins to offset contribution hy worker and suppliers. The counterpart in human capital, | said in Chapter 2, is maintenance consumption. T believed for years thal this cast counted as a prior claim an pay, just as will the Rem. Toy have been Ue only person Lo think so since Quesnay nd the physiocrats, although Mil and Srala might be interpreted thi way. Buz who has thought what doesn't matter, Questay's idea is a mathematical possibility thal must be addressed. 11] get there soon. Human capital is inalienable, bat means that its decapitalization simplifies to Iman depreciation. The rms added possibilities of depletion and liquidation dm'tapply. The output of human capital 5 called wark. Then (6.1) through (6.8). applied to human capital, give earned revenue = pay - prior dats - gross realized work = realized work 1 recverial human depreciation. (6.15) Chapier G: Paral swab Frm 2416 9 ‘The pay rule argues (hal prior claims are zero sad that «ll human depreciation is expected to be recovered in pay and work products as a norm. Chapter 2 offered two logical proats of the second point. The alternative to recovery is deadweight loss. Capital is discounted foreseen cash flav, and cash flaw is realization in transfer or taste satistactian. Deadsicight loss, or uncalized depeatialization, is therefars implivitly unforeseen. Winman depreciation, like plant depreciation, is foreseen from the start. Aging and mortality come as no surprise. It is therefore: foreseen as realized in pay. The second proof, stated in part by Becker, follows (rom the miiomnd rule, All behavior is maximization of perceived risk-adjusted return 10 the individual's total capital. This follows from definitions, not trom axioms. There are no exceptions because there are no square circles. The rule says that no one invests in anything without expected recovery with interest. Recovery means recavery of depreciation We da invest in human capital, af ourscives and our children, and cansequently expect recavery of human dupreciation by ourselves or them. [Cs Ural simple. Glber proofs looked to evidence and experience. [offered he parable of the bass aod ber secretary. which had been decisive in converting me from Quesnay's view. Lets go through it once more. Assume that investment in each has ended before the Just year for each. First take Ue possibility thal neither maintenance consumption tbe supposed prior claims) nor human depreciation is recovered in pay. Then work and cash flow for cach have simplified to realized work and pay. Human capital of cach is remaining pay less the time discount. At the begining of the last year, itis something less than ane year's pag. If pay incasured work, yetum to cach {ork human capital) wold be something over 100% per year. It would rise ta 100% per day al the beginning of the last iiay, and 100% per secand at the beginning of the last second. AL Ue eoi of the last second it reaches infinity. Yel the otfolin asses of each reve Uneir rales of ime preference (return) as val 2 few percentage points per year. Chapier G: Paral swab Frm 2416 10 This is enough to rule out the idea that pay recovers neither maintenance nor depreciation. Does it say which is recovered? It does if we look at the cases of the boss and her secretary separately. Kach earns the same pay throughout, and the Doss cars ten times more. By the beginning of the last day, the human capital and wark of cach Is negligible. Pay bs all depreciation recovery if Tam vight, ar all miatenance recovery iF Quesiay was right, ar maybe uth, Th biss's ay, anyhin, remains ten tines higher. Is that because her malntenance Is ten tine more, per Questia, or hearse her depreciation is? The answer is easy. | concede thal the higher-paid usually consume more, But nol always, and anyhow ool in proportion and not becuse they have 1o. [learned in the quartermaster corps that the consumption needs of the general and the private ave not much ditfercat. The commanding officer, in the field, is expected to be the last to eat, the last to sleep and the first up in the morning Maintenance consumption, as opposed to the rest, Is what we need t keep up strength and vitality and perfarmance. We can't make fa with Jess, Mare pay is more mative, hu need nd be spent on more consumplion unless by chaice. The boss und ber secretary are paid lo apply skills, They are In trouble if the worth of those skills doesi't cover their maintenance needs. But they wil sap saviugs i i doesn't. Retisees need no money motive to consume. All hey need is the mes. The source of skills applied is human capital. The application is gross realized work. The difference between its human depreciation and realized work components matters because the maximand is net output (work) rather than gross. But itis nota ditference in ind. SKI applied is skill applied. Pay is all depreciation at the last second far the same: reason as with the martgage payment. There is no balance lo to warm interest. This argues strongly Ural human depresiation is recovered in literal pay and transferred bo work products. IU also argues at maintenance is oot, The problem is Chapier G: Paral swab Frm 2416 1 in the exact 10:1 proportion required throughout, Whatever was contributed to pay by maintenance recovery, on top of depreciation recovery, would have to hold the same ratio in order for pay to cover both, Experience shows this as alikely in avy case, let alone all cases. The boss and her secretary probably couldn't hold ‘maintenance consumption to that ratio if they tried Anather strong argument against he hypothesis af prior cain an pay is lack ofa source. The claimant would he whaever other than the worker had paid fin the: maintenance consumption and needed Lo be mare whole. Thus the emplaging firm wall bold valid claim iit bic provided the maintenance consumption in order (o enable the work, Thal would pul the Arm in the position of « farmer who must feed the livestock and must earn enough profit to recoup the cost, We went through this in the parable of Phil aud Bill. But the employer firm does not advance the cost because it has no motive to do so. [¢ knows that the worker will pay it anyhow if means allow. Where incans don't allow, as in retirement without adequate savings, the warker Inoks t transfer payments from society generally rather than from the firm alone. Mow comes tbe evidence of age-wage profiles. This evidence is the substance behind the parable of (he boss and her secretary. The evidence ts pl, Wage generally means hourly pay, while *eacuings” means yearly pay. Wage-eamings profiles show rise with age, bul peaking and reversing as workers reach (bei fifties or so. The reason is that they tend to work fewer hours, | consider pay per hour a better ‘measure of humat capital than pay per year. JE someone is worth $30 per hour half time, my impression is that she would be worth S30 per hour full time. IF she prefers 10 stay homie, her leisure must give her that much psychic pay nstead. Psychic pay cuts justas much fee with in. My bass and secretary were cases preferring to work full ime. Age-vwitge profiles hear put the scenario imagined for term. They illustrate the logical certainty thal human depreciation is expectenl (0 he recovered io pay, and support Ue Chapier G: Paral swab Frm 2416 12 convergence axioms Leading (rom prediction 1o probable outcome. More than thal, continuance of the 10:1 ratio through the last day tends to contiren that no ‘maintenance consumption is recovered alongside human depreciation. (ft were, age-wage profiles show that it would have to hold the same 10:1 ratio throughout. [Exhaust Pay The present values ane mim Laisa Tin tra al including human depreciation s expected ta be recovered in pasitive cash fives Positive cash flow Is transfer out plus exhaust. In Bum capital i is pay Jess plovback, Might same human depreciation he realize in exhaust? Tthoughtall was when Taso thaught misialenance consumption wis recovered in pay iad work products. The boss and. secretary parable turned my thinking round on that. But it doesn't follow that none 5 Some pretty clearly is. argued that cven suicide expresses the maximand rule. Deliberate scil-malming exists and expresses It again. Just as Citizen Kane destroyed rs shmwcases because: Ue twas on him, anime destroy thie bares. So long as the destruction is intended and compos ments, L counts as economic behavior. Are there sunnier examples? What about voluntary unpaid vacations and voluntary retirements? What if the boss and her secretary eater convents in mid-career? ‘These choices surrender human capital on the fice of things because they surrender literal future pay. But the psychic pay of leisure makes up for it. Otherwise we would have stayed on the fob track. ‘Then some human depreciation is exhaust. Cal the Dsgehic pay for it "exhaust pay”. sens mercifully sill in the big pletare. {end to neglect it in marcling for that. reason, fst a vith invested consumption ater full-on ob wnley. Bul | dined opie certitude 1s Lo expected recovery of human depreciation io pay. Ud better nol eave Toapholes, There arse none. Some of the pay is psychic, and sami of the Lastes: satisfied are not prelly. Chapioe 6: Pacales wia be Firs 24016 13 Tweaking the Axioms My last argument reasoned from experience that we need no money motive to consume, and that pay tends ta cover pur maintenance needs. But that wasn't strictly in the axioms. 1 assumed a mortal and reproducing population strategizing To rvs Lo satisfy Gastes, and more generally ams. didnt say aul Jou tat Une Jopuation in fact survives. Now | do. et’ specif that the papulation has motive aml means for lineage survival, whether ina group selection ar kin selection sense. The mens can he specified as skill sets, as ao adult norm, sullicient 1o varn ‘maintenance consumplion needs for themselves and invested consumplion needs for their young together. As 0 motive, 1 will specify at list that maintenance consumption is exhausted in satisfying our taste for survival. | already as much as assumed this in arguing that ve need no money mative to consume, THIS aSSUMPHON AF Motive and means amaunts t the biological imperative. itis hardly mes Ln connie. Us the essen af Polly's averlapping genoratians model al1662 in A Treatise of Taxes [Us the wssence of the equilibrium wage theary af Senith in 1776 and Ricardo 1817, where pay converges Lo Ube level holding he work force intact. is he essence of Malthus’ population principle of 1798 and 1801, chosen by Sewior as his first axiom in his Outline of 1836. [tis the essence of the productive consumption theory developed (rom balthus through Mill in 1848. Jt lapsed trom attention with the marginalist revolution beginning with Jevons and Menger in 1671, ironically the year of publication of Darwin's The Descent of Mon, because the marginalists treated explanations of tastes as frrelevant. | happen to he a huge fan of the margioalists. Mt they ve marke thelr point. The micrasconomies they founded isa rich ard mature science. TL nveds mo assumptions as W what explains our Lastes. Bul macro is not doing so well. T believe thal it must start over, anil that. grasp of matives helps. Chapier G: Paral swab Frm 2416 1 Quesnay’s Jeu What Quesnay wrote, in his entry for “man in Diderot's Encyclopedia of 1750, was “Those who make manufactured commodities do not produce wealth. shey spend their receipts in order to obtain their subsistence. Thus they consume as much as they produce. and no surplus of wealth results ram it.” Questa, Tike Petty a century before, came Lo economics fram medicine. Me was personal physician ta Madame de Pompadaur, and then ta the vagal family. is argument was Liat value is adie in agricul re alone, nat in manu Facies. is conclusion that only landowners can afford Lo pay tases did nol enchant the landed acistocracy of Versailles. Mills éssays- includes “as much as is necessary to keep the productive worker in perfect health and fitness for his eraplagiient, may he said to be cansumed productivity. To this should he adcled what he expends in rearing ehildren to the age at which they bec: capable of producive industry.” Mills Prices of 1845, which Tyuoted eae, said the same: “What they consume in keeping up their health, strength and capicilies of work, or in rearing the productive laborers to succeed them, is productive consumption.” Sratta’s parallel idea is expressed in his 1960 paper Production of Commodities by Means of Commoditics. My impression is that, Quesay’s "surplus af wealth” means value added, ani tha hi: thought maintenance vonsumplion shoull be deducted from revenue in finding it Mill can't hisve meant shat] think Quesnay did, in view of Mill's evident belief that output is investment plus consumption. Rather, when [Like Guesnay argued that 1 oy on Soe tnesihd (poston of Poked Feomomp (114171. Chapier G: Paral swab Frm 2416 15 maintenance is recovered in pay work products, | tought Mill and Srafla might have reasoned partveay there, My hlief then that human depreciation is exhausted is satistying tastes seemed defensible then. } argued, sensibly to a point, that getting older meant surviving. | suppose 1 might still arguc the same but for the parable of the boss and her secretary. Anather Look at Depreciation Theory My pay rules, illustrated in the parable of the bass and her setretary, depends on my dei thal depreciation nd umorization we the same, Capital means present value of a typically finite series of forseen cash flows. As each year pisses, present value of the most distant and most discounted one is lost, Depreciation famortization is that Toss. It begins at a maximum, and rises steadily as the end point nears. IHaulted national accaunts tar projecting an opposite trajectory from evidence of actual sales. 1 suggested a second look at likely circumstances and motivations. Depreciable assets are mastly steuedures and equipment. They tend to have ben designed and modified for vrigina users, Original users typically expect Lo own and aperale ther Lo the end. Then what is the likely driver of exceptions? Are secondary des of plant and equipment likelier Lo be driven by pressure Lo buy or pressure to sellz Human capital, anyhow, is exempt from both pressures. We're struck with what we have. We can fovest more, as a homeowner might add a pool room, but we cannot sell. The years Toll by, and present value of the mast distant one’s pay is lost. Consider what happens when the expected cn point changes. Say that the hos and er secretary, at Le beginning of what was Lo be Ure Just day, are both persuaded to re-up for another five years al the same pay. Human capilal of each jumps from ttle Tess ran ane day's pay to present value of five years’ pay. Bul human depreciation of ech is sharply reduced! AL be begioning of what seemed the last Chapier G: Paral swab Frm 2416 16 day, it was substantially Lo be the whole of pay. Now it becomes present value of day's pay five years off, Another Look at Risk Theory 1niade the paint that the bass and her secretary reveal their time preferences in the scenrity portfolios they assemble, and discount their pay at the same rate of return 10 evel their human capital. 1s tat Loa simple? Das iL overlook risk, ar athes factors? Targued thal human vagital is ie risker sod higher-return factor because its exceptional versalility makes il as risky as we like, and because itis owned disproportionately by the risk-tolerant young, Does that make the bosses’ or secretary's human capital viskier and higher io ceturn than her portfolio assets? It docs not. She molds all capital to her single risl-preference lovel at her current age. “This is mot to claim that ages the only determinant. Gender seems to count too, with ‘males usually mare visk-tolerant Bab Trivers tells us why. And there i a wealth effect. We Lend Lo tolirate more risk shun wealth lees us mare: cushion against setbacks. Rut each of us, in present circumstances, has just so much tolerance. Tastes ure properlies of owners, nol of assets. We assemble and modify assets of both factors Lo suil them, Human capital is nol inberently riskier. [Ls riskier al the collective scale ouly because it is owned disproportionately by the risk-prone young. Each cohort, from youngest to oldest, molds it Lo suit tha cohorts chiwactecisic risk profile, The boss and ber secretary each molds all ber assets of both factors to ber single visk tolerance at the time. Tweaking the Life Cycle Model Tconsider Ben-Porath's lif: cycle made af 1967 the ast fmpartant pager in 20% century ecanarmics. Lage with all of iL more br less. Kew it needs darificaion and completion. Chapier G: Paral swab Frm 2416 17 A studies of human capital, as fur os know, effectively (real human depreciation &5 deadweight loss. Ben-Uoraths model seems no exception. How does he model pay? He multiplies human capital by a productivity factor, and then again by the fraction ‘marketed for pay rather than self-invested. That gives what | call realized work. Pay, Hf Lam right, measures grass realized work. That is the main amendment | would Iropose far his model. Ten-Parati's first three equations summarize what | call the grawth trulsin (6.14). Tn my Lerms, ant his, he models ‘humn growl = invested consumplion + sell-invested work - human depreciation. He means positive selt-invested work in the form of learning Meanwhile the inalienability of human capital leaves its depreciation as its only avenue of decapitalization. Javested consumption corresponds to grass transter in as meant in the growth truism (6.14¢) while self-invested work is the sane as proprictary output. Then (6.4¢) applied ta human capital could shaw as ‘human growls = invested consumplion 1 positive sel-invested work - human depreciation, ~ invested conswmpliva + sel -invested work - recovered human depreciation, confirming (5.2) and (53a). Logie also seems to agree with Ben-Porath's incerpretation that self fnvested work continues lote into careers, and that it PIUSE stop when time for recovery uns out. Tut [would specily that invested cansumptian stops, far modeling purposes, at fll fine job entry or a tte later a allow for initial job training, This needn't follow from my adjusted axioms 11's just an impression from whl [ see. Tort agree with Schullz that outlays on medicing ar worker relocation ane investment. [see them as maiolensnce consumption preserving skills, not Chapier G: Paral swab Frm 2416 13 investment building skils, | don't see much avenue for investment in adult bum capital except through textbooks and tuition. Some happens. | went back to school at the Conservatory myself, and I buy lots of texcbooks. But {just don't see enough of it around me. Models must simplify. Mine would end invested consumption at Independence more ar loss. Twin also anlel adult selves works subliminal and tostless job experience. 1don'tsec itas taking a secand away from work for pay. This again bs meant a describe ie usual rulk only. Ben-Paraths mode, | think, allows an impression thal workers can chause hetveen warning and learning by allocation of time. The quotes [rom Schulte in Chiapler § described hat us common. [just don't see much of it happening, Rather we tend to work fewer hours at the end of careers, not the beginning or middle wheu time for recovery of self-nvested work remains. 1 said that Ben-Porath's equations imply pay = rualized wrk Twould substitute the pay cule pay= gross realized work ~ realized work + human depreciation = wok self-invested work + human depreciation, {6.17) asa norm or expectation. [tisn't a guaranteed outcome becanse deadweight loss happens to human capital too, We may be Rit hy a hus, or lose our jobs in a samp, ar he sent ts prison ar drafied into the army. The pay rule means that recovery bs foreseen. I7(6.17) were stated in terms of outcomes, "recovered" would have to be inserted hefare "human depreciation’ Chapior 6: Pacales wits he Firm 24a 19 Tbelieve thal the case for tis rule is very strong, The deadweight loss rule and the argument from the maximand rule give logical certitude that buman depreciation is expected to be recovered iu pay. The convergence axioms would then give actual recovery as a norm. The rule disallows the prior claims hypothesis, or possibility that maintenance is recavered too, row an accumulation of implavsihilitics that led me finally ta rule them put by adjusting the axons. The life cycle mare] should also specify that human capital cantinues after retirement. Ladmil that Us rules aul the sinplicities assumed in the boss secretary arable, 1 continues because we earn imputed pay uolil the end, anit human capital remains as ils present value, Ivwould also model in my depreciation theory. Vay, like the mortgage payments, is all realized work (intorest) at the start and all human depreciation (amortization) at the end. No other explanation of age wage profiles will hold water. ANew Approach to the Pay Rule Treassaried 1 the pay rule from Ue maximal and desdsweight Toss rules Another approach can reach (he same conclusion. “the total return truism finds output = capital growth + cash flow, 16:16) expressed Ben-Parath's equation as human grawth = invested consumption +scll-nvestod work ~rvvovered human depreciation, Cash (low 3s the flow discounted to present value, Tradition, since Farr in (be mid- nineteenth century, has seen humans cagital as present value vf future pay less what Chapior 6: Pacales wits he Firm 24a Py Teall invested consumption. | ped in Chapter 3 that this tradition is sound, although not logical certitude. | putit as human cash flow = pay invested consumption, (638) Wark is defined as the auput of human capital. Summing 6.16) and (6.17) now shows the pay rule wrk = pay 1 self-invested work - recovered human deprecation, aller cancellation of invested consumption. his says that the pay rule is not so exotic after all (thas beeu staring us in the face since the Schultz-led consensus, with Ben-Forath, figured out the human growth equation a half a century ago. We had effectively recognized human cash How as Day less invested consumption since Farr a century hefore, without putting ft fn thse words. The Latal return truism does the rest ANew Approach to the Y Rule The marginalist tradition, which has dominated economic hough! since its introduction by Jevons and Menger in 1871, has treated all consumption as the end point exhausting capital in satisfying tstes. doesn't follow thal macginalists were unaware that some is invested in human capital. At least three of the leading ones understood human capital well, That includes Leon Walras, a third co-tounder of the ‘marginalist revolution in 1874. alsa mentioned Marshall. wha agreed with Farin disputing Petty, and Irving Fisher. But all thie, and marginalsts in general, preferred to locate human capital outside the economy proper. Whether they spake af labor measturvel in dallas per uni tine, or human capital measured in dollars alone, Une Jarger Geclor was Laken Lo active exogenously. [L provided ils services room usiche aml was pac) their market value in return, as if on he bavks of a firm. Chapier G: Paral swab Frm 2416 21 Marshall's pupil Keynes was thoroughly a marginalist, as are economists in general today and as am L. One of the features of bis General Theory of 1936 was a kind of double-entry accounting for national product. Product was output and equivalently income. Output meant the sum of prices of final products produced within the year, while meame meant the shares of that sum paid to the workers and investors Inducing it. [is double-cntry dea can he putas output = investment + consumption = income = pay + profit (6.19) Tshawed why disagree, Bul led us see how the total return truism might seem to have led Lo What inference if we leave workers or human capital oulside the economy, To treat them as arriving exogenously trom outside is essentially to treat the national economy as iit were a single firm. Output inside is simply profit, Output outside is work, meaning creation of value by the workers. This gives the truism output = work + profi confirming thal total outpul is the sum of feclor pulputs. So far, 50 good. But vow Mill and Keynes aud most tradition slip by acguicg that pay equals and compensates all of work and nothing else. That's why (6.18) equites output to pay plus profit, Schulz and Ben-Porath and other students of burma capital correct this in part by recognizing some work as self-nvested rather that ‘marketed for pay. My pay rule adds that pay recovers human depreciation as well as realized work. (6.19) should have reasoned autpul = incwme = work + prfit = pay | sell-invested work - buman depreciation | profi. (6.20) Chapier G: Paral swab Frm 2416 2 Where Keynes and Kuznets and macroeconomic adition biave been sight is in reasoning that pay and gross profit, meaning gross of depreciation, sum to the “expenditure” spent on consumption aud gross investment. This fact of arithmetic is the logic behind Say's law: pay plus profit are alveays enough to buy what is Iroduced. We saw that this truism gives cold comfort when calamity or misjudgment make prafit negative, as with the subprime hauses of 2008. What it certifies, anyhow, is expentiture: = pay + gross profil = cansum lian | gross investment. (6.21) We can sublract depreciation Lo reach pay + profit = consumption + investment. {8.22) Now (6.19) can he corrected as a whole ta shove inca: = pay + profit + sell-invested wark - human depreciation —utput = consurmpling - investment 1 selCinvestel wark ~ bumen depreciation. (8.23) My main goal in (bis book bas been 10 further the work of Solow in exogenizing roth, and also the work of Ben-Uorath in endogenizing human capital as something produced wishin the economy. Jt was in that spirit that | derived the Y rule in Chapeers 2 and § by putting human capital inside. I reached UTE = fnvestnent + human capital grave + cash low. Tere “ex post net” is understood before palpu and investment, so that investment, means physical capila] growh. (6.16) applies the growth truism lo bumin capital. “The cash ow truism shows that cash ow is nel transfer plus exhaust realized in Chapier G: Paral swab Frm 2416 23 ste satisfaction. These are ul) ex post descriptions of realized outcomes rather thin intentions. Together they give output = investment + vested consumption + positive self-invested work ~ human depreciation + net transter + exhaust = investment = invested consumption + sclf-vested worl = recovered human deprecation + net transfer + exhaust, 6.24) This much is certitude. 1 now apply (5.9), which includes cansumptian = invested consumplivn | pure consumption, 10 reach the ¥ rule in its general form: output = investment + consumption + sclf-mvested work ~ human depreciation + net transter. (625) The net transfer term disappears at the collective scale. Althaugh (6.24) is logical certitude infered fram definitians, (5.8) and cansequently {6:25) mre nol. Leannot rule aul the possibility of a third kind of consumption secavered in work products is per Quesnay. Thope (hal my interpretation of age- wage profiles 1 the lish of the buss-secrelary parable lis revealed that us improbable. The same holds for my derivation of the pay rule through Ben-Porath's equation and (6.18). (6.18), my inference that human cash flow equals less invested consumption, also trusts that all maintenance consumption is exhausted in satisfying tastes. Summary Accounting for rman capital is much ike accounting in a frum. Expected reovery of ‘human depreciation in pay is logical certitude ilusteated in age-wage profiles and in the hoss-secrelary parable. The pay rulk is not entirely logical vertitue, however, a italso asserts thal mainlensoce consumption is nol recovered, Age-wage profiles Chapier G: Paral swab Frm 2416 2 support this hypothesis (oo, as the constancy of pay differences Lo the end woukl atherwise be improbable. { made it the Darwinian axiom: maintenance is exhausted in satisfying our taste for survival. Ben-Parath's life cyele was adjusted to express these features, Factor risk theory: argued that hutan capital is the riskier and higher-returm factor because capital of any Kind ake on the risk charsaceristics of is ners and human capital is owned disproportionately by the risk-tolcrant young, The ¥ rule contradicts the ¥ = 1 € equation, while the piy rule contradicts the dogo hil output equals pay plas work. National accounts are founded on both. That means | can expect tough resistance. | have tried to prepare for it by adding a little more to cach argument with each chapter. “Uhroughout this chapter, and throughout this boak, | have bent over backwards ta distinguish Iogleal certiturics fram falsifiable hypothesis. Feonomies needs bath. But ited to knows which is whith. The pay and ¥ rules, or example, ar uch certitude in part, The certain part is Une herwtical one, The present value and ‘maximand rules follow from definitions. and compel expected recovery of human depreciation in pi. | then relied on he convergence axioms (0 infer actual recovery asa norm, nota invariable outcome, and on the new axion: of the biological imperative, is well us evidence (rom age-wage profiles, 0 infer thal maintenance consumption is exhausted rather than recovered in pay as well Chapior 6: Pacales wits he Firm 24a 2 CHAPTER 7: PETTY'S IDEA How We Gol to this Pain 1 said that it had any sense, | would have left the veorms in the can by pretending to believe (1.1) as bill did and as the rest of the world seems 10 do. Charts and tables coufirm bis prediction in his and thei terms as well as mine. ut Piketty's argument was rightly criticized for leaving human capital out. Someone ight or might not have faulted mine on the same ground iF] had stopped at the end of Chapter &. Whether they would have: of Rat, every composer kins that the cite ta heat fs the ane inside, What tal critic oli me weas Uy garahle a case al realy wan, npn the Gin, ao follow the argument and worms wherever they lead. That's why toy Lille ‘promised other surprises. risked following it past clarification into digression when 1 argued the pay rule. since tried to justity the digression, if there was some, by showing how that rule could explain Piketty's data far pay/net profit ratios in the twentieth century. And | tried ta shaw haw the pay rule and depreciation theary combined, making pay all man depreciation an no realized wrk al the end, gives the anly consinging explanation of age-wage profiles showing Hsing or steady pay as human capital gran smanthly bo oro, Risk theory reinforve this argument by revealing Lim discount vates for human capital as those mare plain for physical capital wwned by the same ageing cohorts. Every slep was an adventure, and every step led 10 Lhe next one, But | opened other questions and cans along (be way, and the same critic tells me to follow the worms a litle farther. 1 5aid that the cost of survival is adult consuniption tar the sale of investment in the next generation, that pure consumption is more or less the same, and that we will understand the maximand when we unierstand pure consumption, These threads eae inte evolutionary biology, whith reasans how Uaits are selected for lineage survival. The faithful need uot take alarm, Although 1 mean natural selection, divioe Chapior 7 Bays dea 243010 L selection should probably do as well, We are all a peace with the fact that people and other creatures cave for their young. Economies and evolutionary biology ar much the same. Helen Keller, bom blind and deaf, might still have rcasoncal her way through much of both. (amlet would have laved then, [lave ther ost when they test the lnits of lagi, and consult the dais only at the: eid. The: theme: rom which bath reason, us Oerbert Spencer Laught nthe nineteenth century, Is shat he called “sural of the fittest Anather shilosapher, Karl Popper, found Faull with this ides a century later. Papper was one af those Trnentioned who disprove of truisms, 1 haven ead Popper, bul gather that he thought il improper Lo define fitness s polential survival, and then measure sta survival, That objection is close to being understandable from an anti-truism viewpoint. But the reason why itis not quite a truism is instructive, beasurement implies an “empirical” world of data in external and observable reality. Spencer's insight, cally his paraphrase and generalization of Darwin's, is nat quite a truism because it carries the hypathests that “potential” has an pirical meaning Aristotle’ idva thal patency precedes amd explains ac. is called cmsalily. Adam Smith's friend ani fellow Scotsman David Tume scarcely doubled causality, but argued correctly {1 think] that it cannot be proved either by logic or hy experiment. ‘The Rutest prove themselves such by surviving if tnd only if Aristotle was right, Natural selection simply meaus the untestable but itcle-doubted theory of causality. Spencer or Darvin or Gertrude Stein might be faulted for insulting our intelligence by stating the obvious. That shoe would fit Gertrude Stein. But Spencer and Darwin, Jike the little boy in Hans Christian Andersen's The Emperor's New Clothes, were stating the ohvlaus unseen. Andersen's paint was that intelligence was nat the thing Jacking ar what the little hoy supplied. twas abaut how tradition and mind-sets and in-groups might sometimes new a Inak from outsiile. Peer review is nal enough. Sometimes il perpetuates nonsense. The litle hay was nal peer, but be could ell clothes vehien he sav tem. (“Peer”, as any thenrist knows, means someone who pees on your theory.) Chapier 7 Begs dea 2316 2 J contess that this book casts me as that little boy crashing the economic party, and ‘maybe the evolutionary biology one too, in trust that outsiders might have better: chances to spot the obvious unscen. What else was the pay rule? | derived it easily fram doctrines already accepted, | think, and anyhow hard to refute. Those were the Total return turisin and flen-Parath's equation far human growth, The maxinand rules ar deaweight lass rks wauld pre ibs well. How sould Becker have missed that what halds for investment in jab training by enplagers holds for any investment hy anyane in anything? Now could sturents of the age-wage problem have missed he abvious solution? (nvestment implies expected recovery with interest, by the investor or a chosen donee, snd recovery means recovery of depreciation. | belabor this point because tradition dies hard, and naturally tends to circle wagons under attack. | doubt that my surprise attack will meet the resistance Darwin's found. Darwin's met resistance founded on faith. 1 took pains to show that my version requires only selection for lincage survival, and that a henign Artiticer might ordain the sane. Evolutionary Blology and Hamilton's Rule Economics, meaning any quanilative rationale of choice, normally describes humans and human choice. Thi goes for (his book Loo. Bul some Lreiments of economics including this ove ave meant to it other creatures as well, My axioms have kept that in mind. The mortal and reproducing population need nol be human. Much of the animal kingdow, | think, shows convergent tastes aud predictions or acts as if did. The biological imperative is meant to apply to all. All, as I sec it, own capital of both factors. ven protazaans own (“monopolize”) the nutrients they asstoflate and the space they occupy. mans are exceptional in their cultural accumulations of learning and techrialogy shiv in aur secular (lasting) growth, But Lid nol. mike Unise features axioms. Targued thal econmimics ended Lo reasun explicitly or implicitly frm the hivlagical imperative, meaning what [call “ends” in lineage survival, (rom Petty through Smith Chapier 7 Begs dea 2316 3 and Ricardo and Malthus nd Mill, unul the marginalist revolution shifted focus from objectives to the mechanics in supply, demand and price. Bioeconomics awoke a century later, largely it seems in response to the challenge of Hamilton's tule. Now Iwill look atittoo. My tenn "lincage survival” is unusual. Is meant not to take: sides between “kin selection” anil “group selection.” The kin selection idea vas anther wr for Mamiiton's rule from his dactarial thesis in 1964. 1t said that genes encoding investment in close kin sncarle nvest ment in likeliest sharers of Use genes. and should tend ta entrench and perpetuate themselves. is contition for investment wis £ibe. rhere meant velal edness: % for offspring or siblings, % for nephews or nieces or grandoftspring and so Forth, h meant beneht to the dome, and e meant cast ta the investor. The sign » means “greater than”. The cost and benefit were measure in Blass itsell, meaning chances Ln survive and breed. But Ul toa meant “inclusive fitness” where investing in kin counled as breeding when adjusted for seldtedness, The idea was that 1 give up some of my chances if] can increase yours 10 my nel genic advantage in the Jong run. Hamilton allowed for exceptions sncluding meiotic drive, which sometimes forecloses gene competition, His rue prevailed because iL made mostly good predictions, Humans and creatures in general usually care for thei oven young Hist, if they have any, and for closely related young it not. Tamifeon made ft clear that cost ¢ and benefit b fn his hurdle tbc respectively meant fitness given up by the investor and iliess grained by the invest He further made it clear that filness could be measured as R. A. Fisher's “reproductive value” V(x) published in 1930 and 1957, V(x) meant likelihood al age x of reaching cach successive age times expected oftspring ot that age. V(x). at Hob Trivers’ “repriductive success” RS, which simplifies V(x) bn expected remaining offspring, is implicitly constant at the population scale unless there is population arowth (Fisher's “Malthusian parameter”). For creatures other thau us, the Chapier 7 Begs dea 2316 I parameter typically fluctuates dround zero and group Rness bolds about where iL started, Hamilton's rule, applied to diploids like us where closest relatedness 1 absent inbreeding is ¥, forhids investment where fitness gained (benefit) is less than twice fitness given up (ost). 1 see no escape from the inference that fitness would double with each generating, or more Wy acount Far cases where relatedness fell below 1.1 seu na vellel in an Interpretation, say, that each successive generation cures this imbalance hy investing anly Walla ess af ils Fess and Telling te rest lapse. Fitness is likeliboud of leaving tlescendants of equal fitness. [Lis nol strictly conserved, because likeli is generally nol idealical to outcome. There is ex ante and ex past fess, But the ex ante kind is meaningless unless potency, in Aristotle's terns, is expected to converge to act. Hamilton's rule should not have escaped this critique for halfa century. It clearly has merit, but needs some diferent expression Such a reformulation might treat vh/c as a maximand within practical constramts. We can sew how iL might. he hy Tnoking at Une cantesst, Darr idea is # competition fin brevding success. This bivlagical imperative is a powerful predictar in nature. 1 predicts thi eats wre selected for successful reproduction (o the exclusion of all else Evidence is impressive, “Semelparous” creatures who breed only once and do not invest postpartum cave, like salmon and soybeaus, die within hours. An octopus mother breeds only once. cares for ber young a few weeks, and dies is they disperse. Nature is on a tight budget. Resources wasted soon become resourceslost to thritier lineages. Taifeon saw this. [e was ight i stressing the role of competition among individuals and individual heritable traits. Darwin did the same. One thing Thamillon's rule leaves aut, which is nol to claim Ut he overlaoked iL, is that Lraits aul their genes best al prioritizing sel-replicalion might for Wal reason hut chances of achieving it, We knows this happens. Duman edition everywhere resists aol punishes nepotism when it trusses a line, Jane Goodall reporied the same for Chapier 7 Begs dea 23116 s her chimps il Gombe. | think [ have seen it among (he pack of dogs, led by my father's favorite "Sean, at Sutton Ulace, That would count as one of the practical constraints. Too little support for family over equally deserving others is seen asa fault, and too much as another. The reason is ohwaus. Jacks ambitions for kin wil eventually conflict with 7ack’s, Just as with ambitions for food and nest sites and mating apporbanities. Not everyone's frsthorn can he king of the hil, Sactal creatures valve agonistic rules ty sete such conflicts peacefully. Losers in mating lous maments, ar in contests where males display and fernales chovse, usually survive W compete agin nest year. The contests in he group interest because (he \riils of strength and skill proved in the winner will be those passed on, Gur genes tell us to compete as best we can (or the sake of a fait test, and to stop when the verdict seems clear, And soon enough it does, “the quarterback rics his best tor three downs to move the yardsticks, but trots to the sidelines on furth dawn for the sake of another chance later. IF genes can encode this farsighted strategy for those other Kings of competition, why not for mepalistic competition 10? For decades, hiologists wondered why genes need so much selecting in species long, established. Shoulda earlier contests have selected tre Mutest genes once snd for all, with no need for further ones but to screen out recent and harentul mutations? Shouldn't the best trits have become clear millennia ago? Why peed males contest in tournaments or beauty contests every breeding season, with mostly the sane contestanss, when best genes ought to have proved themselves soon after the species began? Then there would be no genetic diversity except for recent mutations nat yet screened out. Population genetists such as Fisher, |. B.S. laldane ani Sewall Wright had written mathematical mods shsng that even the slightest selectivn pressures shaukd drive a gene Lo fixity, ani its rivals la extinction, within a few generations if selection Gavored it consistently, Their argument was Malthus” insights breeding sucess is geomedric. Yet Unere is ich allelic diversity wherever we Jauk. There are some gene siles in some species where he most common allele Chapier 7 Begs dea 2310 5 holds frequencies wider ten percent, and those (Frequencies are constantly shifting. The flux proves that losers are allowed mating opportunities too, though not as much, and leave young fo compete in the next generation. Tamilton explained why that could make sense in 2 paper published with Marlene Zukin 1962. Gearge Williains fn 1976 and John Toaby in 1980 had argued that Test genes in ne generation might not be fitest in the nest if niche pressures arid ta counter current gene choices. Toaby had painted to parasites and pathogens, particularly single-cell pes whase If: cyele runs less Urn an haur, They could evolve nev strains W oulank our old defenses and cal for new ones Hamilton and Zuk continued this there, They suggested thal genes might have long ‘memories, put in human terms, and might have seen the same parasites and pathogens pull such tricks befove. if some individuals in the host population still carried the antidote gene that worked the last time the same unexpected strain arose, or something clase enough to it, hosts collectively could weather the thrcat if that antidote: genc could be identitied and spread fast enaugh. Then how? Damion aml Zak proposer thal what sinning mals display in wntests of singing ar craaking ar agility or symmetry, or hight calors in the right places, was possession af Lhe genes needed to counter (he current stein of pathogens and parasites. Losers in the same contests carried genes thal had proved best against sirains of the past and might come back in the future, Nepotism practiced by winners would speed up the spreal of the current antidote, Bul losers carried genes that bad worked against other strains that might recur. A way had to be found to keep all those potential ancidotes somewhere in the medicine cabinet, Current losers had to he saved for later. Gene diversity was the key to group sureival in the long run. The quartertiack tats to the hench on fourth down because that is hetter for himself and the team than being carried to the hospital. Ne realizes tat other players are best ov punts or Geld als or defense until he gets the hall again. Selection pressures da ao favor be same (rails and genes every me. Chapier 7 Begs dea 2316 H Hamilton's Parasite Theory My take on Hamilton's 1982 paper, vehich | consider his masterpiece, is a blend of his thoughts, Hob rivers” from a decade before, Richard Alexander’s, and maybe mine. Mine sees a population arranged inlacal "demes” which intrabrecd in most cases far best adaptation to lacal pressures including pathagens and parasites. A Jawal strain bo which the local deme is adapted might spr Wo other demes which are not. ost in the tnvaded demes beeome sick. Female anes there intuit the degraded canditivs, breed Tess oilers, and breed mostly females (mothers an choose) hecause males with their vw lalate woli-parasite (histocampatabilily) genes will find few willing males, This begins the part from Trivers. [llcome lo Alexander's ter. Mothers in the source deme see an opposite picture, Conditions are not necessarily better than before, hut they are better than in the invaded dems. They intuit this, Iced are aften, and breed mastly males. The males migrate to thase invaded deme, carrying histompatibility genes pre-adapled lr the invariers, and find willing mates ere if Urey can shaw tie signs. The idea thal. mothers dhoose to breed mostly males in prosperous conditions is (be other half of Trivers ides. The Ket tht the invading parasite nd the males wilh antidote genes might lend lo originate fromm the same deme may be mine, That presupposes that females can trust the signs. Nature makes sure they cau. She provides resistant males with hav-to-toign ones to prove it. This was one of Hamilton's key sights. His idea has been called the "truth in advertising” theory: Symmetrical antlers, deep craks, accurate sangs and bright colors where they should be tell the Females whose genes can he trusted. Parasites and pathogens wal kes then i allied ost males if rey could. IU seers they can't Tamil, 1 helieve, had salve thre nagging puedes at pice. Why does nature waste resources on beauty displays hal seem al first glance Lo hinder filaess? 4 Chapier 7 Begs dea 2316 8 peacock's Ll feathers ace 4n encumbrance in running (rom predators, And why give the expensive displays mostly to males? Why do males exist at all iu species where they contribute genes but uo care? We just saw the answer to the first. Answers to the sscond two again build on an insight of Trivers in 1973. Males produce eheap sperm carrying genes alone. Females produce eggs prcked with costly nutrients. & mali Gin pass genes Lo many descendants through man mates if they approve his signs. That speeds up the fight ginal parasites. Nature evvlved males al their sell-promating signs and thei contests for Fastest spread of antidote genes Lo vale up 1 shifts in parasite load. Where Do Losers Go? Akey point in the Hamilton-Zuk theory is that losers’ genes iu the beauty coutest are typically not driven to extinction, They are driven to lowe frequencies until needed again. Kin selection, up to a point, helps maintain genic diversity hy preserving current lasers within the gene pao. Selection pressures punish and restraint kin selection when it conflicts with preservation of athe genes whose time will come again. met (millon ada conferene in Squaw Valley, where Bab Trivers had helped us atleact bio, and (old bim this reson why Thought bis 1962 piper helped complete nd qualify bis 196+ pape. He wis (he absent-minded professor perfection. Moody, distracted, profound. He smiled, a are thing for him, and said “IUs been a long search.” his explains what | mean by lineage survival or tituess. Much of this book assumes ts maxinuzation even among modern humans, who create our own urban environments fn place af the ancestral savanna for which we were adapted. And much of economic history, although written in cities by eity-dwallers, appears bo assume the same. Chapler 2 liste] same examples. Lets revi rem. There was Pelly’s of 1662. The similar equilibrinen wage theories of Smith and Ricardo expecta py Lo canverge bb the level maintaining al reglaving the work force, whichis trusted Lo spend it va both, Malthus’ population principle in 1798 nd 1601 Chapier 7 Begs dea 23116 b) added the mechanics, Nassau Senior made thal principle bis firs\ axiom in his Outline of 1836. The biological imperative lapsed from attention vehen the first generation of marginalists, led by Jevons and Menger, with Walras 500m to follow, thought it unscientific to explain or justify tastes. It reemerged a century later in hivceanamics, much of which Inoked far economic implications of (familton's rule. We will sc how it mifght clarify pure cansum ptian and the maximand. Enlightened Kin Selection Tamillon's rule needs cm pletion because te quarterback and his genes have Aggared pul thi thes bench is bette than the hospital. Wha really happens, 1 think, is along:range example of Bob Trivers’ “reciprocal aliruism” of 1971 4s generalized by Richard Alexander, Bob rote that creatures might invest in non-kin if the investment were expected to be repaid with interest. Alexander added that the repayment could be to the investor's kin with equal genetic benctit if Hamilton's Indic 1b>c were cleared from the investor's perspective. The quarterback yields 10 special teams on Fourth down, and they to the defense until passession changes again, far the best interests of each and all in the Jang run. The interest they receive in en far deferring W won-kin is Lhe cast af maintaining themselves on the bench. IU does pol accrue and compound because itis paid out continuously. IL is an insurance cost tha each lemporary winner dares nol rim. Group selection is enlightened kin selection, Three or four decades ago, this much acknowledgement of group selection would have met more resistance than | expect now. It shouldu't have. Half the beauty of the Hamilton-Zuc scenario is in explaining allelic diversity as a result af agonistic rather than lethal competition. Zack and Jack and their genotypes are rivals now because they are Leammates in the big picture. Kin selection is a help until it crosses the line and becomes a hindrance, Some. mothers in the sure deme will carry higher frequencies of the antidote gene than thers, They will tend to be healthier, and so able ta invest more energy in mare Chapier 7 Begs dea 2316 it Young, If dl mothers invest preferentially in their own. or maximize Hamilton's standard rhc , healthier mothers will produce more young with higher doses of the antidote genes, while sicklice mothers will produce Less with less. Here itis females Who compete to prove the same better genes that males ust proved in the tournaments or beauty contests. The race against parasites seeds up again with Trivers fine insight about healthier mothers chaosing to dial up the rata of sons to daughters “primary sex matin’), and 10 exgund the reproductive perind at bath ends with shorter birth sparing for more: male offspring still. (Sonne of this may be my idea rather than his) Mature proves best current genes vice, Falher prove bem by duking il out or sirulling their stuff, Mothers carrying the same best gees prove it by winning the breeding, contest against other mothers after. “The exantef ex post distinction counts as much in biolagy as in economics. Here it accelerates the selaction pracess. Offspring carrying the antidote gene to meet current. parasites will generally not on thal acount enst more ex ont invested consumption Lo vase, Tey are males, who can Lurn tat arfvantage in many allspring, the ex past value of thal same investment can be fue higher, The converse works for offspring lacking the gene, Their mothers can make (he best of it by producing females who will find breeding opportunities anyhow with mates carrying be gene, sioce she knows which they are and males ways bave cheap spec to spare, aud will so keep their own genes in the gene pool. Parasites got the last laugh by Killing Hamiltan on research in Arica a few years after met him, | never knew wel enough to call him Bll. Boh Trivers called him the deepest thinker In the ward. That cauldn't he wrong by much. Parasites and Demes Tirnst Mayr, Bab Trivers’ doctoral advisar at Tara defined a deme as a race or subpapulition (hal intrabreeds al least 95% of the time, | hypothesize thal it does so, Chapier 7 Begs dea 2316 u in some cases, lo maximize [requency of 4 histocompatibiily gene which is an antidote to the local strain of parasite or pathogen. This idea could complement the Hamilton-Zuc parasite model nicely. It would give a safe home to which both gene and parasite could retreat unt] thei times come again. Period of Production Theory Back ta economics. Chapter 4 ncntioned John Rag as a contributar ta what later dusulpual into Mills free growth Uneory. Rae's bouk, published in 1834, also Ineging what was called period uf production thevry. The ied was that production lok time, and that profil compensated the investor's patience over the production period. Senior, who had sent Rae's book to Mill, adopted this idea in his own better known Outline in 1836. Rae's book itself found few readers, despite its warm endorsement by Millis his own magaus opus of 1818. Jevens adopted the idea from Senior in 1871, and Boehm Bawerk from Senior and Jevons in his book of 1889. Boehm Bawerk soon learned of Rac's work. and dedicated later editions to hin Period of production theary thrives today in the Austrian School, which had heen founded hy Roch Bawerles teacher Carl Menger in 1871. (Menger was the guy who squab with Schnoller in Chapler 2) This found lite favor elsewhere, The pecion seemed impractical Lo define ar ‘measure, and so gave tlle predictive value, Joseph Schumpeter, a student of Boehm Bawerk who disagreed with bicn on this point, argued in 1911 that the period of production is zero; capital is present continuously, Frank Knight, who bad anticipated Schultz in realizing that some consumption is investment in human capital, argued as Schumpeter had. But the theary fs tru by definition. ny rate i the fverse or recipracal ofa period. “The inverse of 4% per year is 25 years. Return is the ratio of net output to capital producing it, meaning the rate of production, and its reciprocal Is the period af Chapier 7 Begs dea 2316 12 production, Where the critics were right was in finding a lack of clarity and predictive value in the theory, Where does it lead? itabbits and redwoods have different periods of production, at frst glance, bur should nonetheless agree in set ifin risk. Jevons wrote that he meant production of the “wage fund” as a whole, meaning the universe of consumer goods. But he pointed to wine and timber as examples to help pin down the erlod. Bach Bawerk picked nine years for io reson | can see. All went wrong by consideriog physical capital only. The factors blend into wach other; physicd becomes human capil (brough invested consumption, sad conversely when human depreciation is recovered in products, The generation length gives the replacement period for total capital if total capital is interpreted as funess and if all fitness of each generation is passed to the next. Jevans and Boch Bawerk assumed growthlessness for simplicity, and would have realized that they were modeling nly the replacement component in net aviput. Bahn Bawer k's cantribulian, anticipated by Pelly, was his insight thal lime prefercnee rate explains rate af return by pricing the capital denaminatar, and not the reverse. Thiss had nal hewn carr in Rae ar-Seniar or Jess. give all Tour high ‘marks for a near miss, Bul they vould have come loser. Remember (hal Seoior's first axiom had been Malthus’ population principle. He and the others would also have known of etty’s human and total capital idea, which was occasionally revived and critiqued. They didn't quite connect the dots. Next Generation Theory Petty wrote A Treatise of Teves in 1662. The whole title continues to aboutas many words, counting ampersands, as pages in the bank or pamphlet. is son tells us that Pell dictate his books overnight to seceutarics sh slept by Liens 1Uis sy 1 helieve that Petty did't need much sleep. Oe was a go-getter wha had safled to Chapier 7 Begs dea 2316 1 Ireland as chef medical officer o Cromwell's ironsides, stayed on o survey he Jeish Jand with which Cromvel] would pay his troops, and then got Parliament's approval 10 investin that high-risk land to make a fortunc, tis rare for a man of practical gitts 10 bea deep thinker £00. Pert, like my father, was both. His Vertum Sapienti of 1664 was first to apply the ancient capitalization formula to both factors, meaning wankers as well as tradeablc things, and sa ariginated the concept af human capital as present value. Te applied this insight there and is Politica! Arithmetic in 1676, and agaln in The Total Wealth of Englond in 1683, ta ncasure the tatal wealth af Tigard inuding human capital. Thal makes him the: father of national accauntss Tut bis gretestachieveroents, [ink cane in A Treatise of Tares. Chispler 4, paragraph 9 of that book begins with 19. Having found the Rent or value of the sus fructus per antuo, the question is, bow tauy veacs purchase {as we usually say} is the Lee simple naturally worth? If ve say an infinite number, then an Acre of Land would be equal in value to a thousand Acres af the same Land; which is absurd, an intinity of unites being equal to an infinity of thousands. Pety clearly recngnizes thal lime preference, meaning our laste for impatience, explains produdivily, or ralio of pulpui to capital, rather than the other way around. This powerful and counterintuitive insight is usually credited (o Boehm Baserk in 188, who showed that iis rue for man-made things as well as land. The utility or uss fructus being a given, we bid less for the land or other capital producing itif we ave Jess patient, and more if more. Bidding Jess for bis denominator of rate of return bids that rate itself up if the numerator is a given, and conversely. That's why riskier assets ofter higher return, Petty's reductio ad ebsurdam ot a hypothesis of infinite patience is abvious in hindsight, but may not have been written down hefore Petty continues: Chapier 7 Begs dea 2316 u Wherefore we must piich upon some limited number, and that [4pprehend 10 be the number of years, which | conceive one man of ity years old, another of twenty eight, and another of seven years old. all being alive together may be thought to Live: that is to say, of a Grandfather, Lather and Childe; few wen baving reason to take care of more remote Posterity: for ita ‘man be a great Grandfather, he bimselfis so much nearer his end, so as there are hut three in a continual line of descent usually coexisting together; and as Some are Grandrathers at forty years, yet as many are not til above sisty, and sie de cteters. 20. Wherefore 1 pitch the number af years purchase, that any fand is naturally warth, by be Ue ordinary went af thru sich person their lives Nave in Tingland we estecn three ives equal To one and twenty years, and cansequently the value of Land, to be aout he same number of years ‘purchase, Possibly if they thought themselves mistaken... (ss the observer an the Bills of Mortality thinks bey are...) 21... But io other Countreys Lands are worth neacer thirty years purchase, by reason of the better tiles, more people, and perhps Lruer opinion of the value and duration of thee lives. 23. One the other hand, Lands are worth fewer years purchase fasin Ireland)... by reason of the frequent rebellions... = ‘The "other Countreys™ could include France and especially Holland, then models of Irosperity. Petty had made his fortune in Irish mortgages, and knew the years urchase there. Tout the argument isa pul. There is focus on Tongevity ard mstality, as if the geverations are providing for old age. But Pelly’s uverlapping generations mote] canool be much like Paul Semuelson's of Uhree centuries later, where « generalion of productives leaves a nest egg for retirement. Samuelson’s productives are replenished exogenously, with childven Left to the imagination, Why would Petty have mentioned their ages? And retirement at age 50, as a norm, would have made no sense to Petty or his readers. The grandfather wil stay in harness. Chapier 7 Begs dea 2316 5 The one and weal years could mean remaining life expectancy al age 50. Bul Pelly could easily have spelled that out, or the implied 71 year terminus. He does spell out the ages of the three generations, Their average ditference in age rounds to 21 years, Petty’s readers, like Smith's and Ricardo's after, would have taken it for granted that cach generation provides for the next. “Few nen having reason to fake eave of more: remote posterity” vould have registered in the contest of thal priision. “Pasterity” usually meant and means descendants. His description, ike mine, is incomplete. He may mean that life expectancy is dso factor in calculating the years purchase. If so, he apparently leaves that thought to be followed up Jater. There is also 100m to atgue that the grandfather looks two generations ahead, sa that the years purchase hecomes 42 years. Hut that would give the usus fructus at 2.3%. Al the rates Petty yepnrts elsewhere fn the tract are much higher. One gencration length is what ie stems ta apply. My reading is that thw grand Father provides far the grandsun by passing all ta the san. Pelly’s overlapping penecalion insight hss heen one of his least noticed, just as wilh Mill's on output growth preceding and explaining capital growth. ) first red of Petty's idea in a collection of Lionel Robbis’ lectures at London School of Economics delivered in 1979-1960, but published in 2000. {learned from (hese lectures that Gustav Cassel had published the same idea in his The Nature and Necessity of Interest in 1903. | hunted that down. Robbins misremembered in telling his students that Cassel had arrived at the idea independently. In fact Gassel and Rabhins both quate the same excerpts from A Treatise af Toves that 1 ust did. Cassel inferred Uhat Interest rales cannot stably Ine Jess than 26 per year Chapier 7 Begs dea 2316 15 Jarrived at the same idea independently, anyhow, and published itn Sociol Science Information in 1989. To date itis my only publication in a refereed journal, and remains uncited as far 3 1 know, Alan Rogers, a biologist at University of Utah, published almost the same idea in 1994! and 1997+. Neither of us kneve of Petty or Cassel or each uther. Both of Rogers” two papers are included in my appendix. Petty’s great idea has otherwise remained unnoticed as faras maw. TTT A A Tes Ho om Torts Ee pL Aad Sunaerian temples knew how evaluate and as well as mortgages und annuities by discounting to present value, ln tbe simplest case, where cash lowe is expected 10 ‘hold constant forever, the logic begins with the definition cash low ate = S000 capital Algebra allows cash flow capital - ——— 7.1) PH eh owrate 4 Years purchase, given those shplifyng assumptions, meant Tn h 7.2) Las Sh flowrate” l Ye vation of Vo ror Sunn nd Hino Chic aver To Chapioe 7 Psa apart uv Suppase for example hat cash flow rate is known Lo be 4%, Using (7.2). we would figure yeu purchase = Lo Je year Ivews pe Pofyerr 4% 1/100 ¥ “thatallows (7.1) to be reexpressed as capital = {cash Naw) x {years purchase) 3) Wiha cash ou ancl cash Now rate are assanmen constant over Lime, Urey butome Klentical lo profit and rate of return. Sumerians realized! (hal return is the universal ‘minima, theee millennia before Turgol wrote thal down, and thal competition tended to equalize it to a current market norm. Then it would also equal years purchase. Petty wasscarching tor the rationale of years purchase, and found it in the generation length. Perty’s idea | think, and mine anyhow, could hegin with wapital = means of accomplishing goals= means of lineage survival= fitness. (7.4) Nature's way is transmission af all filness, meaning total capital Tor humans, Lo the: next generation. Nature cares just as much for later generations, bul trusts each generation of immediate descendants to knows best whal their own imediale descendants will need for that long-range goal. Each passes the baton and retires. We invest everything iu the next generaton precisely because we care about the ones after, Hamillon's rule reflects this reality. Grandoffspring are only % related Lo Chapior 7 Bays dea 243010 1 donors, while offspring are % reluted. Hamillan thus predicts srandoffspring to seceive investment only when benefit fcost ratio is double. My own analysis allows more role for group selection, without saying how much, and shifts attention from ho benctts to when. Petty’ fdea, if understand hin, Is ‘years purchase = generation length = 2tycars, 0) which would give ash fawrate ——— = 4a (7.6) I Generation length 21 years This woukd tally well enough with rates of return and interes! rates as Petty knew hen. I would adjust Petty’s estimate of the generational length, Petty's primogeniture model may have been true to law and custom for land inberitance, but ti vot true to biology. | prefer R.A. Fisher's? method equal-weighting al births from first to last, and soual-weighing ages of both parents at cach birth, We have some evidence that the maternal gencration length in recent decades. by that method. has run near 26 years var recent eendes: 1 fathers ane five years older on average, Fishur's method wad rive a 28.5 years. Rogers found 26.9 years rom other sources. Then (7.6) would ive cash owrate= 1-380 on I TVR £ hw nest Thvenyof Marre Setscnian (150), Chapioe 7 Psa apart 1 Al his his assumed bias assumed constant cu flow indefinitely. Thal would imply zero growth, Only under zero growth do output and rate of return simplify to cash flow and cash low cate. Now let's model growth in. { divide the ¥ Tule by total capital, as in Chapter 4, ta get output _ total capital growth cashflow towlcapital total capital total copital ar more compactly rte of return = growth rate 1 cash flaw rate, i] At the collective scale, cash ow rate simplifies to pure consumption rate. That would be written Fate of FELT = GOW Fate + pure consumption rate, 7.9) asin Chapter 4. Then {7.6 through (7.9) allow Tate af retum = growth vate + 3.5% year 10) al the wollective scalk. £7.10) willl be wrang if growth ale were a function of cash fos cate. Usa that, politicians, and even economists lo « degree, teach that faster growlh needs consumption testraint first. Thal carrespands Wo cash flaw restraint in (7.10). Free Chapier 7 Begs dea 2316 ES row theory says such restiainl doesn't happen, Data say be same. | apply tbe same idea in next generation theory. My 3.5% is a ough estimate. What counts is the generation lengeh, The length was rohahly higher, and the rate lower, before medicine and sanitation lowered mortality rates, and let tw or thice births per cauple meet the need for papulation replenishment The cash flows or pure wonsumgion rake modeled at 3.5% might also vary for reasons wher thi changes in Whe generation length. My charts show the pars consumplion/iolal capilal rate as higher in the mildle part of the Uventielh century as people drained capital reserves Lo keep up consumption in times of world-wide depression. Il say more about these reserves. First Interpretation Next generation theary says fn effect that R. A. Fisher's versian of the generation Jength, nal Petty's primgeniture version, gives Lhe periar of praduction of tolal capital. We would miss the point ifwe Focused on the periad production of human capital separately. Tot capital is our means of incage survival. This reinforces my theme Lal human capital daes nol mean humans. 1 means skill sets priced at present value of foreseen cash flow, Skill sels are not enough for linexge survival We also need things. We should not fall into the tea of surplus value theory, which had been taught by communists for decades before Karl Marx joined their ranks, in supposing that skills make things. It is only halt the truth. Skills plus things make skills plus things os the generations repeat. Nar should we make the mistake af supposing that the generation length begins and els uniquely fram birth to birth, sa tha the remaining period of production gives shorter uver aul Life and the Lime discount rate steeper, The period fa cycle Js the sme al any point. The young, simyly by maturing, are alrvaly investing in their Chapier 7 Begs dea 2316 a counterparts in the nex! generation. Each cohort (sume-age group) invests effectively in its immediate descendent. Eight-year-olds are investing in the next generation of eight:year-olds, and so to the end. That's why Fisher's version of the generation lengeh is best. It priovitizes each cohort and gender without judgment as to which matter more. The period of production gives our patience horizon The Trizon and its reciprocal, the pure cansuiptian vate, Both hald the same at any age. Cash Flow and Risk The msi mam] rult oles thal ime preference and return vary with risk. Return is rowel cate plus cash flow rate, Ts variance with risk captured mare in one of these two components than the lker? We might ineuit that riskier and higher-return assets grow taster on average, over enough time for the bumps of risk to even out. But if that tended to be true, the miverse of assets would grow progressively riskier aver the decades and centuries “That fs not iy reading of history. My impression is that smanther and rockicr perinds come and go without wverall trend. Tn the world we know, then, iis cash Mow rate rather han grat rate Lat varies from ase 1o asset with risk, For lusiration, consider fictor risk. | argued that human capital (igure Lo be the siskier and higher return factor because assets tend to reflect the risk appetites of their owners. The young are more risk- tolerant, and own human capital disproportionately, this bigher return were reflected it bigher growth, rather thar. in higher cash flow, the ratio ot bunian to physical capital would tend to rise steadily over the millennia. Most readings have tended to see it the other way around. | myself favor the neutral assumption that the factors Keep pace. Then cash How rate Becmnes higher far human than physical capital, with 3.5% the cap-weighted average. Chapier 7 Begs dea 2316 22 Consider also Whe history of corporate leverage. Equities are riskier because bond interest is paid first. If equities greve faster, however, leverage would constantly decline. That is not what we see. “This inferred concentration of visk premium in cash flow rate is convenient for testing Grawth and return are to of the most dasely allowed vartables in ecanomics. We have no iret mesure af the pure cansumptian rate, or cash low rateat the callective scale, Nor have we any direct measure of grawth and return to total capital al any scale. Bul we have s gan idea ol average return and growth and cash flow Lo securities and business issets. By the naximand rule, return to human capital should be the same bul for differences in risk. | model hum capital as somewhat riskier, for reasons just given, and human capital is the larger actor, hen if Lan right in placing the risk premium within the cash tow component of return, and in estimating average-risk cash flow rate at 3.5%, cash-How rate to the business sector as a whole should be somewhat less. Next genuration theary predicts at the volledtive: scale. Collective return is implicitly average return, and thal means average-risk return. My rearing of history, which rules oul progressive growth of higher-risk ussels dt Ue expense of ower-risk anes, simplifies (hat Lo average-risk cash low plus whatever collective or average growth happens to be atthe moment. Don’t Grandparents lovest? Next genevation theory assumes that each generation invests all fs capital of both factors in the next within the generation length. We expect it to do the same in tum. We care about grandatfspring to, hut serve them best hy Dusting and enabling thelr parents anly. A first reaction i thal this denies the obvious, Humans Ltay, io advanced countries, mvrmally live ta nearly ree Limes the generation length. (3 x 26.5 = 85.5). Fven retirement 4l age 65 comes eight years aller twice (bal lenglh. And job number one Chapier 7 Begs dea 23116 2 for grandparents seems Lo be helping Lake care of grandchildren, Doesn't that Celsify next generation theory? Note quite. Retirement typically means dependence on savings or subsidy. The parental generation subsidizes both the young and the old. Retirees can he Interpreted th some extent as hired though willing caregivers paid for by parents. That explains part. The rest [dhink, is hest explained as replenishing a capital reserve. Nature bills up reserves in god times and depletes then in bad limes. 4 rise in longevity from whit is normally needed for lineage survival is a rise in ‘human capital reserves, Human capilal is Une most versalile ind. We geezers have Jost a step. Bul we remember how t's dove, We particularly remember howe parenting and homemaking are done, since those change least with technology. Julius Caesar's nanny, with a tew pointers, could probably fll in as a nanny today. Jt the parental generation were pulled away to fight a war, ar rehuild after a catastrophe, we nldsters could keep up the home front Free growth teary, abundantly proved in the da, is essential lo next generation theory, Whal each generation invests in the next is all its fitness (total capital). All ex post growth, up or down. is added or sublracted for (ree, Catastrophes and windfalls ave the random kind of free growth, Tech gain is the accumulatiug “secular” (of ges) Kind. | wouldn't put it past niture to have learned that sustined growth meats rising risk. She could adjust with reserves, We may be selected (a nicer word than programmed) to build human capital reserves intentionally, whether or not sceing nature's motives for the huildup as distinct from out ow, when real wealth doubles with every generation. Thal. intentional or ex ante part would pean investmen in Ue reserve, (List Tacgeted Lo the grantalfsprivg generation, because bey aren't expected Lo draw i dist unless nesaled. All the rest of Une bul of human capital reserves in lifespan prolongation is best explained as random free growth if my interpretation holds Chapier 7 Begs dea 2316 2 water, Nex generation (heory is not contradicted because i describes cash flows only. Lt treats all growth at the collective scale as free and exogenous. Testing Next Generation Theory “The proxies for the pure consumption rate (Schultz pure consumption over total capital) in security markets sould be dividend yield for cquities, and Interest for dub cain. Thbatson Assuciales’ STI (2012), Chapter 4, shows average real interest un TLS. trporate bands as 3.0% aver the peria 1926-2011. Real corporate dividend yield rate over the period can be estimated from the same source al shout 245%. Jeremy Siegel's Stocks for the Lang Run (2002), Table 1-2, reports data extending back to 1802. Real return over the period 1802 - 2001 is shown as averaging 3.5% for long-term governments, and 2.9% for short-term goveraments. Corporate bond returns would have run somewhat higher. Ginbat Financial Date shows stock market information for 95 countries. Data for UK. 1S, Germany, Australia and France begin feom 1701, 1801, 1870, 1663 and 1896 respectively. My charts and tablos, and my website Free Growth ond Other Surprises, shows this infirnation along with evidence for [ve gral The eighteenth century is represented by LK. alone. UK. hea showed ceal price return, dividend yield and total return at 21.4%, 7.9% and 29.3%, Volatility of dividend yield was exceptional. From L8U1 forward, UK. averages for these flows Were 229%, 42% and 6.4%. LS. tigures from 1601 orsvard were 2.9% 3.3% and 83%. Globe Finenciol Dot also shows collective flows far Europe and the world since 1926. flere the Nigures were 3.365, 3.9% and 7.3% far Furope, and 3.5% 3.0% and 7.3% tor the world. Miduling of the puree cansugm pian vate before the emergence af security markets could refer 1b the histary of interest rales alone. Interest is tle of return lo senior claims. Rabe of return Wo any claim is realization by investors nel of all expense Chapior 7 Bays dea 243010 25 Jvestors as o interest mens lenders, nol borrowers, Interest rates published historically are rates borrowers are contracted to pay. loterest rates realized by lenders are less fortwo reasons. There are friction costs of due diligence, contracting and collection. Detavlt costs, slight when tines are good, can he catastrophic when times are bad Homer and STi describe normal contracted rates, nat realized rates netof thase casts, as 10% = 40% in Sumer and Bahylonia, 65 = 1855 In ancient Greece, 5% = 24% in Tigypl, and 4% ~ 12% in Rare and the: Byzantine Fan pire Aller higher ates in the dack as, Bu rapean martyages and cammercial loans faund the rnige 7% - 25% in the thirteenth and fourteenth centuries. The range selled down lo 4% - 11% in the sixteenth century, and (0 3% ~ 10% by (he seventeenth and eighteentl’. The authors comment" interest rates declined during much of the laser Middle Ages and Renaissance, “The earliest short-term rates quoted were somewhat higher than the last and highest of the western Roman Legal linits. They Were nat tao diferent from carly Greek rates and were within the range of Tahylonian rates... The later Renatssance rates were well within the range of moder: ates and the lowes were (ar below modern rates in periails of credit stringency.” Merchants of Venice in Shakespeare tine and lang before barred room banks, nol frm Shylucks, and al rather lower cost han merchants of the twentieth centucy. Economics and Biology Biocconomics has meant economics informed by biology. 1 argued that this descrihes much or all of classical economics from Petty through Mill, then lapsed when the marginalists preferred to do without any explanations or justifications af tastes, and revived a century later Wo explore Hamilton's rule. 0 istry of oreaesi ates Wotgers, 1996 “Tali 1, © id. Tables fan 7. # id Tabled. id. Tables 1 sd 11. # hid Chapter 10 Chapier 7 Begs dea 2316 2 1100 reason from biological axioms, and from much the same ones inplicit or explicit in the classical peviod. But { end up framing ideas of biology in the lauguage of economics rather than the opposite. | begin with Total capital = means of ends = means of replication = fitness, where fitness bs understood as a stack. The concomitant low and rate would be aut (ervation of fess otal capital) and return (ratio of the ten) Free growth (heary gave (he inference optimum ex ante output = optioum controllable output = exact oftsetof pure consumption, at the collective scale. Next generation theary specified the period af this exhaust and recavery as the generation length Consider Hamilton's rule in this context. All ex ante oulpul. continuing steatily al the generation rate, must be invested concurrently in the nex! generation or stored for Later investment within the deadline. {tis the problem of Brewster's millions. Adults must invest or store as efficiently as practical (the miximind rule) before the output meaus has slipped by. And the more stored instead, the more pressure to invest later wichin the deadline. Time lef for investment is another of the practical constraints on maximization of rhc. What sense bs a watering down of Haniliares rule ror what seemed Ingical campulsin a fev decades aga 10 samuthing more like a larget of agparlunity. A prediction msionizing thc bas proved its value asa useful rule of thumb, sagged why sume nepotism might be more adaptive ian nar in my reviews of the Hamillon-Zuk parasite theory. [Us about giving il genes a fair bu speedy (cial. Chapior 7 Bays dea 2310 ar The quarterback gets three downs, and the batter ree strikes, before they go back 10 the bench, Some nepotism directs healthier mothers to invest in more and healthier offspring, and sicker ones conversely, Jong enough to demonstrate which 7cally which. Males passing the test carry the Signs to prove it. Females choose them to spread the antidote gene to the whole population. 1asing genes and losing parasites retreat unt thelr tne comes again. Summary This chapler Lares my want ecanamist hal for my wannabe bivlagist one. Herbert Spencer called (nose fields the same al bollom. | never read Spencer, and know him mosily from Bertrand Russell's hooks on the histocy of philasopby. Spencer rates subchapter there. Yet he was an autodidact with less training io cither field than mine. He even had less training in philosophy than mine. He was a Philosopher al the same, by Russell's tough standards, and knew that logic comes first. Data eventually prove thelr worth when (Fs the to test. The data I've found fits net goneratian theory more or less What 1 really have: on, all the while, 1s my weangabe philasopher hal. Popperians make no sense. Are we supposed (o find Wal i rose is not a rose? Or (bal all reasoning from definition is as Lranspient is (hal example? Wiles’ proefol Fermat's last theorem ended a search that took some pretty bright minds three centuries. My best guess would be thal Popperians confuse the concepts of logic and question-begging, Uhey are opposite, Logic {reasoning from definition) means taking out no more than you put in, Tewism or tautology usually means obvious examples of the same, but sometimes includes subtle ones too. Questian-hegging Means taking GUT WHE YoU never put in. * Circulars s question egg which clans to take ou 3s ference WAS put in 26 assumprion. Assnmption-hat Socrates 5 3 13n ard fatal ren are mortal dogs nat confity EASE Socracas 5a an. conte that Sozrates fs mortal 4553s re sour Chapior 7 Bays dea 243010 Bs Spencer's “survival of the fittest’ doctrine would be a truism if we could prove the theory of natural causality. We can't by any means known to me. Science takes itasa working assumption. So did Hume, and 50 do I. f God intervenes only a little, so that Jaws of nature comes clase to reality most of the time, we're still in business. My critique of Samillonys rulk proposed Lal apalism nels resistance when iL canflicts with nepotistic goals af others. 1 prapased a mndus wivend through agonistic rules. Canillants parasite theory with Zuk, written 18 years later, gives he game plan. Nepotist, meaning kin selection through Hanulton's rule, is iu the common interest 104 point. It speeds up proof of best genes to beat the current parasites by testing female genes as well as male ones. Healthier mothers and sisters and aunts carry more fitness to invest m more young. And females in most K-selected species, eluding humans, perform ost care af the offspring and siblings and nepates {nephews and nieces] that receive 11 Male competition alanc dacs nat determine hist current genes Uy natures satisfaclinn, Female breeding com pelitian ani aepolistic investment help prove them farther. All agonistic rules are boul keeping (he contest fair and deciding when proof is enough. Long-term success against future as well as current parasites needs most losers, notall, to go 10 the bench flow frequencies; source demes in iy version) rather than to extinction. Most losers survived to enter the contest because they Te Dante is bent ILS i si oding Vie. chs Yok be ta ly conmgivers in retrial Ach such 5 aie baes. Chapior 7 Bays dea 243010 2 were winners once before. Their cost on the bench, or on the taxi squad. is good insurance. My version of Hamilton's parasite theory patched in some of Trivers’ ideas. One was that mothers intuiting selt-hcalth and goad prospects should tend to breed higher Irimary sex eatios and eanversely, Their male offspring ean then find willing mates I health carries reliable signs as Damillan proposed. Also the investment af insurance cast by winners in maintaining losers on he bench can he interpreted as Trivers’ reciprocal allcuism Lo be recovered when winnecs now become losers later, My discussion of grandparental investment let still more woras oul of the can. JLis clear that humans in advanced economies today normally live to nearly three generation lengths. J proposed that we are replenishing a total capital reserve, meaning mainly a human capital one, when recovering from hard times in the world wars and world depression. No one really kmaws. Chapier 7 Begs dea 2316 ES CHAPTER 8: BANKS, MONEY AND MACROECONOMICS Splitting up Banks I started to write a book on banks and money a year ago. | stopped when | realized that | don't know enough about the subject. | have some experience and have done some reading in those fields, but not enough to justifi a whole book. A chapter, or part of a chapter, is morc like it. Sumerian temples doubled as banks, nasty far agricultural laans to finance the nest crap. Tis fim ther recarils, in clay Lahilels, that we know they understood compound interest and We capitalization formula, Deposit-and-lend banks as we know them today emerged in Venice and other European cities in the tweltth and thirteenth cencuries. Chapter 1 said that equicy investors cannot be attracted at leveeage {eposit/equity) of less than 10:1, that even one tenth so much leverage is unstable in high winds, and that we rebuild the banking system after every systemic failure because swe blamed the high winds rather than Une rickety structure, said that the solution is ta split up hanks as we: know them into degosit hanks which invest in FTF un the ane side, aul lending hanks which raise funds from investors rather than depositors on he other, These entities would have separate stockholders, aod would not interact unless incidentally. Adiftercat kind of bane split-up has been urged since the 2008 crash. Repeal of the Glass-Steagle act had allowed commercial (depositand-lend) banks to aperate as investment hanks (Brokerage firms). Many blamed the erash on that repeal, and an investment hank innavations such as mortgage-backed sceurities. {think thase eritics are ooking in Une wera direction. The: problem, as with mast bank rashes aver he centuries, was overleverage encouraged by neady cosiless deposits, The salution is nol Lo peel off brakerags aperatians from the mix, bul Lb peel all epost. Chapier 8 Banks, Money and Macosconomics 2/8/16 L Tse no reason why lending banks should be separate {rom investment baoks, Rather the depositors’ money should not be risked in either. Itis also a mistake to blame Wall Street chicanery. Chicanery is a fact of fte, and Wall Street has more than its share. But] can testify, from a ringside seat, that many sound Rnanciors and strate cconamnists genuinely believed in the sub-prime derivatives they were selling. They were: prose 1s the rusts Tun. Turned therm die as a business proposition because [saw toa much complexity and no upside Tut ny react wars thal the presenters were sald themselves The problem is nol in the people. Us in the inhereal fragility of deposit-andi-lend banks. Then what would the world be like without them? The answer list needs a closer look atthe problem. Credit Risk is More than Leverage Some leverage is a god thing. Firms issue bands as well as stocks in order to attract a widur range of investors. Riskeavurst invostars may choase the safely of bonds, whose interest ulaims are paid first, while visk talerant pres may be happy with the flier bul mare promising equily remainder. Leverage in general is a way lo salisly both these constituencies. Credit risk rises with erm {duration as well as amount of debi, One of the most telling posits in Siegel's Stocks for the Long Run is that corporate bonds of 15 years or more have proved more volatile in real total return than equities have. No wonder. A corparate hond will have ample debt coverage (gross profit/debt service) at date af issuance, and an appropriate credit rating What will bath be Tifteen years from now? Homeawners also lypically borrow Jong-term. They expect 1b have children in local schaals, husbands andar wives in Tocal jabs, 2nd ather rots in the community. Bul Chapior 8 Banks, Money and Mazosconomis 2/8/15 2 who knows that husbands and wives will stl be married in fifteen years? Who knows that if they are, their careers will not have taken then to another city? It seems to me that reducing the dangers of debt means reducing both term and amount, and that the solution had hetter find ways that still accommodate the shart. term and Inng-tenn needs of finns and people. Naw let's lank at how deposit hanks might invest The Omnibus Fund Idea I were a couple of decades vounger, [would (ry Lo create something ] call an omnibus fund. It starts by seeming to contradict what just said. | said that fiems sssue both stocks and bonds to reach different constituencies. The omnibus fund would first erase that separation. In principle it would reconstruct the firm asa whole, ar put the picces hack together again, hy assembling proportionate shaves of the debtand equity clafms an it i a single portiolio. Suppose fir example hat the market vp (umber of shares mes current market quotation) for a firm's equity shares is one billion dollars, while Ue market cap ofall debt claims logether In half tha. Then the omasbus fund, in principle, would buy each firm's equities and debt insteuments in that proportion at current market valuation, In practice it could realize the sane effect in a simpler way. he omnibus tund would be a balanced index fund. Index funds are representative ofall the funds in an index, such os the S&P 500, weighted again to market cap. The omnis fund would pick a still more Inclusive index, say the Russell 3000 or even the Wilshire 5000. 1 would add in a corporate bond Indes, since balanced means mixing stocks an hands anil cap wright. the tw. The abject would hie lo mare] the publicly-traded corporate sector asa whole, The simplest way fa gel there would be 10 buy inde ETFs {exchange Leader funds) directly, rather than duplicating their work of assembling portfolios of the underlying individual issues. Chapier 8 Banks, Money and Macosconomics 2/8/16 3 Ifit stopped at that point, the omnibus fund would probably attract few investors. It would ofter the aggregate return and risk of the publicity-traded corporate sectoras fit had never borrowed or issued debt. Aggregate means average. No one is exactly average. Some like me and my Rather happen ta be mare risk-tolerant, and opt tor the higher returns that tend ta come froin higher isk. Soine prefer the apposite Taw ean he omsibus fund alr bath? The answer is derivatives. Derivatives are abligatians whose henefits depend on autcames imperfectly foreseen. Tsaid in the forwarsl (al I'm all in Gave of theo so Tang as we respect and manage the risks. Byuities themselves are he classical example. Mortgage-backed securities give another, Common forms include futures and swaps. the idea is about the same. Each typically picks an index, often the St 300. Onc party, the "short leg’, bets so much moncy, the "notional amount”, that the S&P 500 index will go down tomorrow, Another party, the “lang leg”, bets it will go up. The shart leg gets so much, say Libor plus 20 basis paints (hundredths ofa percent] of the notional amour, in any auleome, The lang leg gets the inex change, whether up or awn, times Ue same notional amount. Moone actually invests the nolione] amount, Ls called “notional for good reason. Rather each side (leg) commits a cash reserve, beld by the firm managing the swap or future, in (his case the omaibus fund itself, of 20% of the notional amount. The reserve is drawn down to meet payments required when market swings are averse, and replenished when favorable, When ir talls to 10% of the notional amount, itis considered unsate and the swap or future ends prematurely. Pacties are warned, and new reserves can he commited fn time. Monitaring of the reserve: is continuous during marked hours, Whenever the reserve falls Lo 10%, even in tbe middle of the day, (be account is closed immediately. This disciplin Jeteps Lhe niher panty safe Chapior 8 Banks, Money and Mazosconomis 2/8/15 E Risk-averse clients in the omaibus fand can (ake shor legs, and risk-tolerant ones Toug legs. Management of the omnibus fund can handle the mechanics of the swaps or futures. “The effect would be not less leverage per se, since leverage at the individual account Jewel Is substituted far leverage at the corporate level, The difference fs duration. Swaas and Futures are short-term cammibments. Three: months is Lypital. Futures rade: in active markets, for good measure, and can usually be liquidated in seconds a wuirrent marke during trading hours. So can BTR Uemselves. #Whal do these derivalives cost? Essentially nothing, Those who prefer safety und the short leg, are matched with those who prefer return and the long leg, while the ‘manager charges only for its time in working the mechanics, What About Asset Allocation? Where the amnibus Rand seems th violate comman sense is in merging out what had sewed 10 be valuable distinctions. Sa iL wild seem with the blending of equity anid dub clin, but farm optional wverlay vf derivatives such as futures Lo restore whalever risk and expected return we sanl. Many distinctions blended oul. including Ua one, have been important Lo principles of assel allocation and modern portfolio theory. They ace important because some investment sectors are less correlated than others, meaning less likely to risk ud fall in lockstep. Low- correlation porttolios are better because less volatile as a whole without sacrifice of return. That's why hedge funds typically assemble portfolios judged low or negative in correlation, and then try to reduce correlation still Farther swith an overlay of derivatives. The amofbus fund seems to throw away all these options. Nal really. One of the lessons of the 2006 crash is Ura everything bul Treasuries tens 10 go down io high winds, Anli-corvelation stralegies failed when we most nde them. The omnis fund isn really giving up sa much. lls exceptional diversity makes it begin wilh less correlation han specializing portfolios. And Chapier 8 Banks, Money and Macosconomics 2/8/16 s nothing would prevent a sophisticated investor in the omnibus fund from ‘manipulating correlation further down with derivatives as hedge funds do. Liquidity, Risk and Return Demand deposits in hanks taday can he withdrawn at ang time. Time deposits cannot he attracted withat either competitive interest ar quick Yguidity. This Tiguility reapuirement. his been akan in tat bank deposits are usually refined for years. Arun on the bank soon finds no cash lel t meet withdrawals. The runs came when the: high winds baw, and provide a coup de grace vn lap of high default rules. he omnibus fund meets withdrawals easily because itis invested only in the most liquid securities, EF trade in soconds at current market quotations. Any mutual fund shares that might belong to the porttolio trade at curvent close. ile mast fun, the omnibus fund would alsa mantain cash. 1ike some others, it wali "equitize” its cash hy exposing iL Lo swaps or futures. Fiitized cash leaves a fund fully invested in effect while adding instant liquidity aroun the clock. FTPs sive instant liquidity, bul only during Leading hours, Mutual funds typically trade macket close only. Asisk-uverse investor in the omnibus fund who opts for Libor plus so my bisis Points is more or less in the same position as a bank depositor today. She knows that her account will grow only by deposits and by interest [Libor plus basis points) Jeftin to compound. She knows that it will decline only by withdrawals. The investor who prefers the long leg in swaps or futures, or stays unhedged, will also see her accaunt rise and fall with the marke There are infinite graduations araund these thre simple choices. An account might he partly hedge and parlly exposed, or even over-expiosed W a notional wnount larger (ban Ue dccount size where law and markets permit. (They usually a) Chapier 8 Banks, Money and Macosconomics 2/8/16 5 PFayaent Mediation Banks effect payments from depositors’ accounts. An omnibus fund can do the same. Payments out are directed “redemptions” in the language of brokerage accounts, or withdrawals in the language of hank accounts, Payments in are “subscriptions” to brokers and their clients, or deposits to bankers. All these payments can Ie electranic. A payer, typically a customer, might swipe a card ar click a screen. A payee, typlally a vendor, typically must verily first that the account is authentic and overs the payment aller. An omnibus fund could be well suited Lo give this quick Lransparency. First, itis essentially an index fund. tis composed of a published ratio of index E1¥s and index mutual funds and index-equitized cash. Individual accounts ave then hedged or exposed to index swaps or future overlays administered by the ommibus fund itself. The fund can track all these indexes online, and knows from tick to tick what cach account fs worth. This holds ruc even Far volatile accounts where risk tolerant clients have: opted for lang les in swaps ani futures. So lang as management effects all payments in an oul, and constructs each account. of index exposures itself, and racks those exposures and piyenents in ceal lime, it knows account values exactly. Risk-tolerant clients will expect daly ups aad downs in account size. Thal means that they will have to carry larger accounts in order tobe sure of covering payments in the dovnswings. That would be a problem it accounts vielded zevo return, as checkahle bank deposits do. The gist of my answer to Milton Friedman was that no aniount af money 15 too uch I it yields as much rerum as other assets af equal risk. Accounts anc: hedged or leveraged to do so. Omnis land accounts burn ni ales in cet We do not pn one a sper, like a checking account, and Leal. it as a drag an earnings until spent, We own it as « fully competitive investment, and spend i reluctantly when bills are presented Chapier 8 Banks, Money and Macosconomics 2/8/16 H Why Invest in Indexes? The last section showed that index funds offer easy trackability over market hours. Whatare the other pros and cons? On saund miceocconamic principle, professional asset management will add value over Index results before deduction of ees. Otheritse they couldn't stag fn business. The same princiigle says Ural the fees will converge ta that pre-Tiex value added. Prices canverges to marginal utili (valuc). investars bid fees up when fecs are less, and din when they are mare. As rule of thumb, investars shaull expect to do erally well in mavaged or index accounts when fee costs are tonsideced loo, The mechanics of convergence is worth a look. Managed and index funds compete in akind of density-dependent flux like hawks and doves in game theory. It pays to be a hawk when the hawk/dove ratio is too low, and a dove when too high, When ‘haves have only hawics to fight, they will win only half the time. Fighting becomes a Jasing strategy when it isis more than winning stands to gain, More daves will mean easier conlusts. Sos wilh sel managers. Index funds {doves} avoid commitment lights) as lo which firms and sectors will outperform, This neutrality saves the costs of research needed for commitment {tighis). Asset managers (hawks) pay those costs, and secover bem when oulperformance results, Thil means outperforming (he index. But ifasset managers collectively managed the whole market; they would become the index, Some would outpertorm others, but the vehole group cannot outperform itselt Then it could not recover ts rescarch costs. Many would have to close their dno. leaving the Held to index funds which don't pay those casts, unt market equilibrium was restored. Then whl deterunines equilibrium? Is the critical variable percent of rades hy managed funds? 1 thought so far a while. Now [ think its percent of AUM (marke. value of assels under management). My sessoning now is Ul holds by port Coli Chapier 8 Banks, Money and Macosconomics 2/8/16 5 managers reveal informed opinion on securily values as clearly as trades do. Research cost is the same for both. Ifa manger neither buys nor sells, she tells us thar she thinks the price is right. The critical variable is not trade volume, bur percent of aggregate market cap controlled by asset managers collectively. The number of asset managers is much less critical. There must he enough for campetition within each specially or sectar of investment. Tou many is nat a cancer. Abler ones, an micracconomic principle, will displace the less able. That's why Dlerbert Spencer Laught that natural selection works the same in ecammics ms in biology. A particular reason for preferring index ETFs as omuibus fund investments is for cheaper liquidity, The omusbus fund must compete with banks in accommodating payments and other withdrawals (redemptions). Popular index EY1s such as spiders (SPR, for Standard and Poor's Depository Receipts] are baught and sold in sceands fara fec of a cauple of basis pots. Sa are Treasury ETFs. Thus the onnibus fund might da bust nat tn include acta corporate bond BTR in reintegrating the carparate sector, Treasurivs of vual value should do shouLas well at much lower teadivg cost, Easy liquidity is essential. Why Omnibus? Ouoibus means for everyone ius well us of everything, Lis all-inclusive either way. Individuals differ in risk tolerance, An omnibus fund provides for all The portélio of index exposures to riskier equity claims and safer debt claims is meant to satisfy average risk talerance as o whole. Individual accounts then choose short-leg hedges or long-leg exposuIe or anything between. An omnis portfolio best matches aggregate risk anit return to individual dlaiims on it ber approaches would work Loo. A broad-based equity index fund, targeting say the SEP 500 ar Russell 3000, could give: the same Lick-Lo-tick ansparency in individual accounts. Hedging would still be available W cater fo individual risk Chapier 8 Banks, Money and Macosconomics 2/8/16 b) appetites wilbis the risk-tolerant groups. A broad-based bond index fund would do the same for the risk-averse, It seers to me that the omnibus fund would do both fobs at once, and would attract ‘more clients collectively. Bigger is hetter for payment pracessing, The mare clicats, the more "two-sired” payments fram ane client to another. These payments are always cheapest. Waccaunts cast little or nothing Lo apen, vendirs would logically need no wring fa pen the, That agin favors the simplicity and economy and immediacy of two sided payments by including both buyers and sellers wilbin the fund. the omnibus tund is also for everyone asa javestor as well as a payer. Very tew people have the time or training to beat the market. | myself have not. What we have #54 sense of our degree of visicaversion. The omnibus fund gives the broadest and most exible coverage of risk appetites. It can poll and advise clients on visic preferences, and mediate hedges and exposures by suil How the Omnibus Fund Might Evolve J said tha if} were a couple of decades younger, L would start an omnibus fund. Not 10 worry, Ifthe idea holds water, as | think, someone else will. Jt seems to me that banks could not offer much competition, Demand deposits typically pay no interest, and process paynients no better. Omnibus clients offer an infinite range of returns accarding to clicat tolerance for ist. Tanks offer the advantage of federal depasit insurance (FDIC). 1 will not be crovgh. The anaibus fund carries mo leverage, and newls no insurance. Ax it grows, banks will ike notice, They can keep ws the uneven light, or they can join the parade. My warking assum pian is hat many will prefiar the Jatier. Ranks are well positioned to make the most of the idea, They bave Une needed expertise and systems and Chapier 8 Banks, Money and Macosconomics 2/8/16 it clientele in place, They can spin off their leoding opecalions as separate ventures 1o find funds from investors rather than depositors, IEthere were ho FDIC, there would he 10 deposits and no commercial banks. People canead the newspapers. Anyone old enough has lived through periodic bailouts. Tina free market fan sho dislikes FDIC. But we would he rash ta yank the rag from wnder binks by repealing it We shouldn't eve hint tha se might. The world we Knows is build araund hanks, and banks are built on FDIC. Lot It stand. Tass can anyone know for sure that wrmnibus funds ani independent losing banks vill di etter? think amanibus funds gare (0 win despite that advantage for biriks Lending Banks This is the area least clear to me. Banks as we know them begin with expertise, systems and clientele in the loans business as well as the deposit and payment Jrocessing business. That could pasition them to take the lead in bath if spun off separately. fending can stand alone. There are many lending ms other than banks. They raise funds from investars seeking returns, rather than depositors seeking Tiguidity, and somehow ange li compets with hanks day. Lending banks divorced from depositors could lo whatever they do. IEinterest rates must rise because investors demand competitive returns, some ditional borrowers will be motivated to arc equity investment instead. Corporations and other firms could phase out structural {long-terun) debt, and float new stock issues in its place. The effect would be to lower leverage, risk and return together. Investors could then tailor risk and retam more Hexibly by hedging or Jeweraging their individual holdings through professional services. the seme vise in inturest rates makes it impractical for newlyweds la buy homes, they can rent until their means improve. In ten or fleen years their incomes will diuble. They will kin iT they are still marrival, how much house they wed if sa, aol where theiv carvers have taken them, Meanwhile they might rent the same Chapier 8 Banks, Money and Macosconomics 2/8/16 u house they would have bought, They will uot have missed 4 sure-fire lavestment. The crash of 2008 showed that houses are risky too. The time to commit to huge and liquid investments, as houses are, is after ten ar fifteen years of business experience. 1sec no reasan why lending hanks should not make equity frvestinents too. foans, canvertible loans amd enity investments newd the same dus diligence, or research Into prospects of success and ret, All night serve the same clients. "Lending hanks igh simply bee investment banks. That's why splitting af invest ment banks aol commercial (deposit-and-lend) banks ay be 1 step in the wrong diceddion, The key is spilling off deposils. Macroeconomics in General Splitting up commercial banks into omnibus funds and depositless lending banks could change the nature of macroeconomics. Macro has meant the art of maintaining growth and money value stability at the same tine. This has proved mostly a tightrope wealk between inflation and recession. Tasy money risks thi first, and tight money the second, My ile is Wo disconect the problems of underemployment and ‘money value instability. [l oedicine for one has no side effect on the other, each can be treated more (reely. J would fsst dissociate money value (rom money supply. No supply is Loo Jarge if money earns competitive returns while we hold it, that was ote of the main ideas of the omuibus fund. Milton Friedman thought wy carly version of this idea was anathema. Franco Modigliani liked it ine, but asked tough questions. 111 try to answer some af them helow. My approach Ls the prablems af underemployment am Ue business cycle begins wilh phissing oul depusil-and-lead hanks as { described. | more ar less wgeee with Chapier 8 Banks, Money and Macosconomics 2/8/16 12 Ludwig von Mises and (he Austrian school thal slumps come from overinvestment enabled by overlending. In 19281, a year before the crash, Mises wrote: Sour ar later, the tris wust inevitably break nut as the resulL nl change i the comtuet uf the banks. The later the erack-up comes, Ue koner the period in which the calculation of the entrepreneurs s misguided by the tssue of additional dduciary edias The greater this addional quantiey of fiduciary money. the tore feetors of production have been fal committed oy the forur of investments which appeared profitable nly hecause af the artificially Tecuced interest rate.and which prove tn be unprofitable... Great Insses are sustained as result of isdivectad capital imestments. Many new structures remain unfinished. Others, already campleted, clnse down operations. Sill others are carried in because, after writing of losses wehich represcut a waste ol capital, vpevation of Ure caisting structure pays atleast something Here Mises, writing in 1928, describes the crash of 2008 even more vividly than the one in 1929, "Many new structures remain unfinished. Others, already completed, clase down aperatians.” These were mostly plant and office buildings i 1929, and mostly houses in 2005. Mises argued that ney should be backed by precious metals. Te was right in thinking hat it should be Backed, But precious meals pay na reture. The omits fund exrus competitive elurn al the risk level chusen In each account. Accounts wre awened for performance, and only incidentally for liquidity. No amount is so large as 10 tempt overspending. It did not accur to Mises that divorcement of deposits from lending might prevent the cycle in the frst place. Nar did he mention the danger of 10:1 hank leverage, and often mare, in amplifying consequences of har gasses. is idea was better governance af commercial banks. Mine is ending them Free prowlh eary iso belongs lo macroeconomics in that it predicts only at the collective scale, (t predicts that ex ante net investment, or attempted investment Souci Stabisciion wt (yetcal Pic. = lucked paper maw er. Ako 616d gocemment fo moves. Chapier 8 Banks, Money and Macosconomics 2/8/16 1 beyoud depreciation recovery, is simply less consumption wilh no rowih (0 show for it, My charts and tables shove that this bas been true wherever and whenever tested, in cight economies over 40 to 140 years, We crowd our niches lke other creatures, | Think, and have no 100i for growth except as innovation widens the niche. The charts and tables seem to tell us that novation costs no more in failure yates and learning curves that dafly caping docs. Macroeconomics and Keynes Magn emerged in the 1930s under the influence af Keynes. Simon Kuznets, the chief! acehitect of the U.S, national accounts, was one of the five economists Keynes invited 10 proof he chapters of is Geaeral Theory as he wrote lem’. National accounts were soon reorganized along Keynesian lines. “fo read the General Theory, a beautiful work, one vould think that counter opinions were led by his close friend Arthur Pigou. But Pigou was arcady in print with vecommendations much like Keynes’ sehen (twas published in 1936. Opposition came rather from Mises, the ther Austrians, Liane) Robbins ani the Chicago school. They argued Ul intervention ends W make ings warse. So tla many econpmists today. Keynes helieved in fiscal and monetary policy as I describe in Chipler 1. He favored fiscal policy. Chapter 2 said hit be made a basic distinction between investment producing new things and repurchase of things already produced. Only the first counted as real investment. The difference matters because only the first puts plant and people to work. Transters neither add nor subteact value. ven so, my own language counts all as fnvestment, and ranks (vestment anly by rerun. 1 make no distinction among Ineestmentadding new plant and equipment, ar nvestinent in stacks and honds alvealy issued, or in wxisting structures, areven under he mattress The overs sere lard, Seat, Jow Hohimsar: and Raph | ase. Chapier 8 Banks, Money and Macosconomics 2/8/16 u What matters is return, I dont have lo specify “risk-adjusted” return so long ss | describe the collective scale alone. Collective return is implicitly average-isk return, J prioritize it on the reasoniug that optimizing employment ot people and plant is imuplicit, and that optimizing micans Putting them to work most productively rather than over the most hours. I policy masini rate of return, al the collective scale, 1Lwill maximize true aut. perforce. Return bs output divided hy total capital producing it: Mare return Is more outpul ger writ capital. Pulling idle plant and praple la work, in a slam, is a ste in he right direction. Fut it dues gel the job dane unless they work productively: Even pulling money under the mailress is beller thaw investing il a loss. Zero return is better than negative return. | accept Keynes’ distinction between new investment and transfer payments. But | see the latter as part of the mechanics that ends up in the tomer. Maximize return, aud full enployment will happen, Keynes” appasitian is now mostly the Chicago school and ather “freshwater” schools Tredering Une Great Lukes and along inland rivers. Samehow the taste: or Keynesian intervention resonated best in “saltwater” seaboard school such as Tlarvard, MIT, Stanford, and University of California. Tis probably no coincidence thal the saltwater states are the “blue anes (ending Lo vote Democral, while the freshwater ones are the "ced" ones favoring Republicans. (1 call myself a free macket Democrat, whether or nol that's a contradiction in ers.) Freshwater views lend to oppose intervention, but accept Keynesian basic definitions acd equations such as the Y= 1+ doctrive aud the distinction between “attempted saving and fvestment. Itis these 1 question. Tort think much af his vies that intended saving (cansumption faregane) Becomes actual saving only if invested, and homes an equal amount of ghysical capital growh if itis. Then (actual) nel saving, nel investment and physical capital growth would become synanymaus. Txaid why 1 prefer language where saving aol investment are synonymous in the first place, Whal matters is cule of relurn. Chapier 8 Banks, Money and Macosconomics 2/8/16 5 Jnvestment (saving) under the mattress yields only the psychic value of liquidity. Actual capital growth depends on rate of return as much 3s amount invested. If return bolds the same as it was before, growth and net ex ante investment will be equal. Growth vill be less than consumption foregone (remembering the asterisks) return drops, and mare if return vises. Keynes saw shuns ss invwstiment defi, Use therm as rutin deficits, Keynes assumed uncritically, 1 think, that new investment is the path out of slumps Investment will come shen prispedts of retura do. Although the General Theory was published three years before Myrdal's ex ante - ex post distinction. Kevnes would have realized the same thing. think be made the understandable mistake of supposing that the difference would balance out as random noise. The eharts and tables show otherwise. The optimum ex ants investment target is enaugh to offset realistic depreciation exactly. Wetynues was a great Uhindker, a lively writer and a decent man, Uiappen to endorse some af is policy ideas. So dil my father Wien © asked hit what he Unought of fiscal policy, T expected something Like Havelrer's “crowing oul” argument: government investment preempls and prevents privale investment. | gol a surprise. My father said "When people are out of work, that's the time to build 2 new post office.” [Ls, if you need a new post oflice, because returns can be higher when contractors strapped for options bid construction cost down. But itis no disrespect to point that the General Theory was published 80 years aga. tend to SUPPOTE Keynes on some points, for example the uselalness of fiscal policy in relieving shims, but Lo agree mostly with Mises an hele causes in the fist place. Where 1iffer from bath is in Use fundamental anataeny. Chapior 8 Banks, Money and Mazosconomis 2/8/15 15 Stabilizing Money Value Modigliani's main critique was that money earning full competitive return, so that no amount was too much, would make monetary policy impossible in its usual forms. My best answer af the tine was that full-returm money ought to remove inflationary or deflationary pressures. But | agreed with him that money value might drift, cven so, and that same cantrol would bea safeguard if sameane could think nla way. The hist that neers fo me is continus revaluation of the dollar. Legal Leader las specify dollars, or other warrency in other counteivs, as he defaull means of ‘payment recognize in salislying money obligations, Laws could be changed lo specify real dollars instead. Rea] mews corrected for inflation or deflation. “this would have been impractical before the information age. The problem now scems less. Spendable money, called M1, now means carrency plus checking accaunts. Goverament publishes current inflation figures online. Ouniibus cepts could anus automatically. They might shaw values in nominal and real dollars both Aeount value would not change. Correaian fr inflation would show fewer dallas worth more ach, Correction for deflation would show (he opposite. Currency itself canuot adjust so elegantly. It would remain legal tender, but not necessarily a fice value. Currency would impose a translation cost on its spenders and receivers. Say for example that the change in legal tender laws was effective as of January 1, 2020. The real value of the dollar, whether accounts or currency, would mean its value of that baseline. Nominal value ould be that plas inflation since. Calewlators or tPads could keep track of the conversion rate. The cast and nuisance of this conversion shoult he manageable. Tut it would prabably reduce demand far currency where canis or the equivalent do as well, The benefits in encouraging Jang-lerm contracts wd saving "menu change costs.” Thal means costs of changing prices. There is na nel Lo change them on acount of inflation if prices are spec fed in real rather thin nominal dollars. Chapier 8 Banks, Money and Macosconomics 2/8/16 ” Price stability can eater, The United States his managed Wo avoid double-digit inflation since the Volker reforms of the 1980s. But the danger remains. Modigliani was right to worry. Alaw making real dollars legal tender might prompt better measurements of inflation. Many cconamists agece that aur offical mies overstate inflatian by allawing Lo ile for quality improvements. A Lexus ar Testa bs mola Madel 4. That was the theme of the Baskin Cammission report to President Clintan in 1995. The Taskin panel argued thal quality-corrected inflation es run abot 11% less an the numbers posted in the consumer price index (CPT). 1 think so tao, But making sed dollars legal lender, even by these imperfect measures, could still give more confidence in long-term commitments thi the status quo. Speeding Up Fiscal Policy Designating real rather than naminal dollars as legal tender would amount to an amfaniiliar and more direct farm of monetary policy. Meanwhile devolution af hanks into thei separa: degositand lending functions, along with emergence nf amnibus nds, need put no constants on fiscal palicy. Fiscal policy his prescribed Ls cuts aod government spending in slumps. It prescribes the opposite, at least in principle, i booms. A problem is that it has proved slow Lo implement, There is ws “inside lag” while government diagnoses the problem and calls tor a vote in the legislature. An “outside lag" follows until taxes come duc and spending programs ave put together and gradually put plant and peaple to work. The Insti lag Is unavoidable in a demacracy unless the executive branch, or an indepenient agency ike the Fer, is given standing limited authority ta diagnose early signs ol uvemployment, and to address er with Lax tls ov spendiog, And thre must bee enough au tsi ag, Uo make sure that the medicine has goo Prospects in rale of return, Retuco comes first, Chapier 8 Banks, Money and Macosconomics 2/8/16 1» Tax cuts can be Easter-acting than spending programs because they obviate the construction period. lreshwater economists argue plausibly that they are likely to prove ineffective. They foresee "rational expectations” of taxpayers as predicting eventual restoration of the taxes when full caployment resumes. This gives a Motive fa save the Tax cut rather than spend ft as tended. 1 see ita little differently. Most cans mptiar is maintenance or investment lo keep up human capital. We will need that canning passer when taxes are restored. say's Law Jean Bapliste Say, in veritings | haven't read, argued two centuries ago hal supply creates its own demand. The logic is sound to a point. I'he claims on output simplify t0 pay plus profit The asterisks don't matter here. Thus pay plus profit is always enough to clear that market. There could be "partial gluts" when we produced too much of one thing and not enough of another, hut nevera “general glut” where Iaduction got ahead of our cans th pay far it. A110 truv. Consumption plus investment walk pay plus profil. But the sad fact is thal profit can be negative. Deadweight loss happens. When it happens al (ke collective scale, even pay claims may be Jeft unsatisfied. Say's law gives no comfort except where outcomes ave as expected. ‘tax Considerations Schultz in 1962 argued that educational (human) capital is overtaxed. What bie wrote was: "The established tax treatment takes account of both depreciation and ahsolescence in the case of physical capital, but this accounting fs not extended to Imma capital”. fle was eight. ncorne Gx is charged on ne profit of Trans and pay of warkers. Pay measures grass realized work including human depreciation. Tax aves rw counter thal imbalance by applying laser les Lo ay as "eared income”, If we could measure human depreciation, or model iL wilh enough Chapior 8 Banks, Money and Mazosconomis 2/8/15 19 confidence, we would know how much correction wis enough, That's 4 reason lo take depreciation theory seriously. Market-Valued Capital in Macroeconomics Another reason why macro should he recanceived from scratch is that its defining equatians, written mastly over hall a century aga, leave aut cayital. Change In capital shows as nek investment, but capital itself stays wlside, Flaws are considers] sufficent for description. Piketty, a good ecanansic bistarian, Lells us Ural this did not have to be, [seems (al the largest economies hid good records of markel-valued capital since the late- ‘middle nineteenth century. Viketty does not speculate why macro aod national accounts ignored them when both took form i the 1920s and 1930s. Physical capital and its changes can he measured at market or calculated by the Derpetal inventory method used in balance sheets. {showed in Chapter 2 why that mutha i nol the best. Depreciation accounting assumes norms in the loss of pital value with ime, and gets the news of actual autcomes longer, National accounts reported pusilive rea nel investment, meaning growlh in capitel value, in 1929, 1930, 1937 aud 2008, They give ile clue (o reallly in years of surprise. “The neglect of markel-valued capital in micro wad the mations] accounts until 1990 or so may have to do with the influence of Keynes. The General Theory includes some hilarious broadsides on the fickleness of market speculators. He put more trust in the sober disciplines of accounting, Piketty trusts the market more, and so dol Ther why tows Pikelly track new investment, or diange in capital, by the accounting methods used in national atcounts? Thal seems inconsistent, My chits and lables track lat marked. [Uses 1a me iat nalivmal accounts shal tack it bith ways, Chapier 8 Banks, Money and Macosconomics 2/8/16 ES od let each economist decide which version is more useful, Mine, a least, correctly describes those same four years as losing ones. National Accounts Overall It seems to me that national accounts are doing nathing wrang except in modeling the depreciation curve from misleading sales evidence. Rvidence secnns to shaw: depreciation as Fast al frst, and slower later. Thal tends ba be Lrue she depreciable assets are actually sold. Structures tend to be customized for thelr ariginal pemers aml occupants. They fend fo be resald when results are disappointing, This disppointinent often comes when expectations are first Leste, When distressed sellers marke! illiquid structures customized for themselves, prices loo will be disappointing. Better to trust cvidence of structures intended in the fiest place to pass rom owner: to ovmer, as with many standardized rather than customized apartment and office and warehause buildings. Better still, fram an economists viewpatat if not an accountants, is W Lrust Ingic. Capital is prosent value of expected cash flaw, Ls loss af value with Lime, under simplifying assumptions, is Uhe present value af the mast distant and most discounted cash flow. Depreciation of structures we keep, rather than sell, is least at rst and greatest a the end. 1 is be same as with a level payment mortgage. National accounts are nonetheless a magnificent achievement. They need interpretation ust as corporate accounts do. That's where economies comes in. And national accounts are not resting on past practices. They can be congratulated on neluding market valued capital, even JE sixty years to late, and on extrapolating it Nackvard where practical. This hook could scarcely have: heen written if they hadn't Twould recommend the ohviaus next step. Yel investmenl should be shown alteratively as change in mickel-valued, and autpul as Ural plus consumption, Let ecanomists decidk which version is gaod for whal. Chapier 8 Banks, Money and Macosconomics 2/8/16 a National Wealth Including Human Capital By definition, pure consumption rate is pure consumption divided by total capital. this can be arranged as total capital = DUE CONSUMpOn 81) Juve consumption tate Nest generation theary mardcled the pure consumption vate as 3.5% per year. Mistorical data shawn dividend amd interest rates spore ar less in his gan since Sumerian mes. | model pure consumption as boul three fourths of ll consumption. I take consumplion ss personal consumplion expenditure (PCE) plus government consumption expenditure (GCE) per Ue national accounts. GUE includes government outlays, al all levels of government, on education and welfare. These are easily recognized as consumption. Lt also includes costs of a enforcement, natianal defense, ire control, and maintenance of infrastructure such a5 highways and water systems and government buildings. These too count as camsumption, even if rc mightn't have thought so. They arc part af the cast af aur survival. That's why 1 agree with Kuznots and tradition, although | didn't aba, thal consumption includes all of GCF. PCE in 2015 shows as $12.12 trillion. GCE is reported al $2.3453 rillion. Both are im 2015 dollars. their sum is $15.4143 trillion. Three fourths of thats $11.26 wilion. Then (8.4) gives total capita] = PUEConsumption | SLLAN 74 pypign, Pure consumptionrate 035, year in 2015 dlls. This vaugh estimate can be borne in mind when se evaluate te x base and the risk of national debt. US. public and private debt together has been Chapior Banks, Mon and Massosconomks 2/8/15 u estimated at litte Less than a fourth of this sum. My impression is thal this exposure is not yet dangerous. But it needs watching. ‘the best method to estimate aggregate adult human capital separately is ezty’s. It is present value of future human eash flow. That means pay less invested cansumption. IF Cam vight, meaning that Gare, Marshall and Kiker are wrong, invested consumption is negligible ambng adults. Then Pelly was right lo capitalize Jay with no deduction. And he was right to capitalize aggregate current pay, with no aed Wo pce the future, Growth of pay wil Lend Ly match growth of human capital. The discount cate Us find its present value is expected rated vf return. Rate of return ss growl rie plus cesh flow rate, Evaluating buunan capital as constant current pay discounted by cash flow rate alone will give the same answer us if we modeled in expected pay growth, but then discounted at cash flow rate plus the same projocted growth rate. Total human capital is adult capital plus that of the young, That part might he musasureed al current cast, | wan'Ualompl either of thase calculations her, sings they seem Lo cll for vepnomists kxpert in inter prwting mations] accounts. a Do List Books and papers on economics tend to lead to “policy prescriptions”, That means recommendations on wehial governments and mickets and educators should do. My list begins vith getting rid of the double tax on dividends, To get democrats on board, make the effect revenue neutral by raising the corporate tax rate. Dividend rates have been far tao lows for about 30 years now. They should average 5% to 6% real, as they did fn the nineteenth century. The result of low dividents has heen dangerous pveriivestimnt in the private sector, with grawih hampered rather than enhancer. Charts and lables make iL dear that ex ants investment beyond depreciation recovery is deadweight loss. Chapior 8 Banks, Money and Mazosconomis 2/8/15 z Twvould Lax capital gains ss much as ordinary income for the same reason, Level be playing field. Solow saw: most of the truth, but didn't go far enough. ll saw more. And even Mill stopped short, All we have to do is Jook at the charts and tables. Capital accumulation docs not exist, Ay aTEempt lowers consumption vith no growth to show for it Keep rack of matical wealth including human cagiial by my method here, aml alsa hy Pet's af 1664, 1676 and 1605. What would we think of corporate management thal added up nly Lhe smaller part of corgorate assels? We now cansider physical capita) only. Political parties debate whl tases and the ational debt should be without the key facts. Policy prescriptions can also aim at schools and what they teach, Macroeconomics should start over. It reached most of its present form in the "years of high theory”, in the 1920s through 1950s, without the concepts of human capital ar market-valued capital. itis founded on the accurate: Y = € + 1 equation and the concamitant heliet thal output equals pay plus profit IL recognizes ex ante = x post distintians anly crudely as 10 saving, hy taking Las wither invested or uninvested, and nol at al as lo investment itself. By missing the lag between make! effects and book reaction. it ‘misreads some of our worst years as our best and conversely. “the path forward is omoibus funds and devolution of commercial bunks. Bank reform along the lines | suggested should need no help from lawmakers, But for gosh sakes, lets not set up barriers against ir. Commercial banks and 10:1 leverage make slamps inevitable. Crashes are as sure as death and taxes until we phase them out Summary. Mateo has meant a lightrope walk between the risks of inflation and recession, Thal dies’ have 10 be. The problems are detachable. Rven today, 1 shall be practical fo redefine legal lender as real or inflation-corrected dollars. But (be deeper Chapier 8 Banks, Money and Macosconomics 2/8/16 2 solution is to devolve commercial banks into their separate deposit and lending functions, with separate stockholders and aul incidental interaction. tis best far the free market ta do this alone. The amnibus Fang could be the decisive pvatian. (toa fs passiblc today. It would offer clients full competitive retin, so tha. no supply wall be Loa large. TLavaud match bank deposits in ligidity and payment services with the Jaw service charges typical af other Indes Funds, while tailoring risk and reburn bo dient needs with essentially costliss ilerivalives, The intention sould be uhsolescence of bank ascaunts, and devolution of banks in resull Deposit-and-lend banks, inevitably leveraged at 10:1 or more, are the weak link explaining economic collapses about once a generation since the syste was founded in the Renaissance. Misdoeds and misgucsses and world events were only the proximate cause. Chicancey will he with us farever. Honest bad judgment will be with us forever. Supply shoeks, as when OPEC raised afl prices in 1973, will be with us Forever, Wars will bes with us frever. Setbacks for aur Lrading partners will be wilh us forever, These bring the high winds. Tons farvswe mach payout in frying lo dial down the winds hy upgrading bumin nature, The payout is in stabler siructures. “the big bad wolf buffed and puffed, and the brick house stood, Omnibus funds will carry no leverage. Accounts Unemselyes will be levered to laste, bul for short periods only. Futures trade in seconds. The fund as a whole cacnot become worthless until cach and every security in its portfolio does. High winds and leverage can wipe out the accounts of risk-takers who chose the lang leg, hut not of those wha opted for camtractual interest and safety. That's as it should he. Risk-talers may name their potsan. Omnibus mans farall, and all-inclusive, Derivatives are cenlra) lo the omnibus fund idea. Some see them 4s dangerous, They canbe. They are pase ful. Bul they have a good La record of perfarming as cantracted, Cash reserves, called micgins, have proved enough Lo escape default Chapier 8 Banks, Money and Macosconomics 2/8/16 25 even in 2008 und (he lsh crssh of 2013, Short legs hive been protected withou fail and long legs have got what they bargained for. The reason is that margin sufficiency is monitored trom tick to tick, Checking every few seconds doesn't rule out every doomsday scenario, but gives about as much confidence as we're going to find in this uncertain world Saltwater ard freshwater sehiols debate Une wisdom of sal and monetary palicy. Tt both sides frame their arguments in Keynesian language. | fd it wanting, The ida hal intended consumption is wither invested pr nal, and realized in equal capital growth if is, misses the essential mechanics. [L measures employment of slant and people in hours rather than in production. This is « good reason why macro should start again from scratch. Another is 10 recast its basis equations in terns of market-valued capital as well as Hows. Another is to accommodate buman capital for example by substituting the pay and Y rules tor the doctrines that pay measures work and that output is investment plus consumption. Nane wf those oar reasons refers Lo Une psibilty of amnibus funds, They are anly a glkarn in my eye. Tey tome pass, and succeed ws imagine, macro will have still more navelly Uo digest. If Urey lead to devolution into serrate deposit ail Tending banks, with te deposit banks operating «s omnibus funds, good riddance lo the L0:1 leverage that has brought down economies every generation or so since Marco Lola's lime. The Jagged flow method of assessing cfticacy of ex ento investment is outdated by the simultaneous rates ane outlined in Chapter 4. It should go to honorable retirement whenever market-valued capital is avaiable. Ie superimposes the Inevitable unintended lag of accounts themselves, even under hest practices, onto thw intended wav newled for the ness Lee planted W bear fruit. Ruth lags blur causality. Chapier 8 Banks, Money and Macosconomics 2/8/16 2 Some famous economists are Wougher on the current state of macro han (am. Recent books argue that it should no longer be taught, and should receive no Nobel prizes. My diagaosis is about the same. But my prescription is opposite. leconceive strom seratch, and teach it ight, Award Nobel prizes to those who help. My fist nominees would be Piketty and Zucman. Not that think much of Piketty’s arguinents But his website with Zuicman is as pawerful a new resource far scholarship and Une datatiase as national accounts were eight decals go. Chapier 8 Banks, Money and Macosconomics 2/8/16 27 CHAPTER 9: SO WHAT'S NEW? To claim originality in wy field is rash. [Us safer lo say thal some things in (his book ave new as far as 1 know. know at least what | can't remember reading elsewhere, | am more confident in judging what wil surprise in the sexse of conflict with what is taught today. There we need anly keep up with the current conversation. judging originality with confidence means having read everything botare. My surprises were nat all new. and my novelties {il such) where nota surprises. 4 few ides met both descriptions. They pay rule, and the equally heretical Y rule, ‘probably count as both although Becker came within a step of gelling there first, Depreciation theary is likely to be both. Uther possible candidates might include my observation that holds by money managers reveal prices as clearly as trades do, and. my hawks-aud-doves analogy inferring from this that index funds should outperform managed ones when aggregate AUM held by money managers, not trades by them, exceeds a critical percentage of the market to be determined. There nay also be hath surprise and navelty in my suggestion of monetary policy by establishment of real dollars as legal tender. Tn my wannahe hialogist role, 1 just may hive bon fest fo the point oul the gall in the math a Hamilton's rule. Froe growth theory takes Mill a litle farther by ruling out growth by thrift al the collective scale, should prove 3 cnajor surprise lo lawmakers, who incentivize thrift in the name of growth, and a milder one to economists already prepared by the msights of Solow. My possible originality here was in the simultancous cates equations | derived to test them, and the test itself accessing data for market-volued capital as well as consumption from the Piketty. Zueman website. My definitions of market-valued net investinent and net sutput, substituting for the book-valued wersians used in national accounts, were essential for testing | suppose these rank as Haveltics but nat surprises. Chapior 8:50 Waals New? prom L The advantage of the simultaneous rates test over (he standurd lagged flows one is great, It avoids both lags, meaning the intended one to allow more capital to show sts effect in more output, and the unintended one in the inherent unresponsiveness oF accounts to market citects on capital already booked, while also gaining from the superiority of market measures of capital growth over baok ones even when lags end. The method Itself is na surprise because the math is high schan) algebra. The shock is in what it reveals. Sul and Denisin were righter than they knew. There is wo such thing as capital accumulation at the collective scale. Risk teary is probably both margioal novell ani macyinal surprise. The part thal ‘might be new, alllough obvious in retrospect, is (bal assets luke on (he risk characteristics of their owners. We knew all along that people buy assets to lit their own risk profiles. There may be novelty in my idea that it works the same in the opposite direction. Assets once acquived ave modified to tt those profiles better. A family hae bought by a drug dealer might become a crack haus bringing higher expected rerum at higher risk af canfiscation by authorities The next step ss 1 connect risk profiles with age and gender, 1 sews voll estublished thal risk (olernte peaks in he eens aod Lwenlies, particularly in males. I drops steadily alterward for both sexes. R.A Fisher in 1930, und Bob Trivers in 1972, suggested why. Males, io humans, produce thousands of cheap sperm. Females produce eggs. which are few and expensive because they are packed wilh nutrients. Young males might ead up leaving dozens of offsprivg or none, Nature arranges competition to determine which. lemales ave reasonably sure to leave a few. They have less to compete about. As bath sexes get past their 20s, their remaining reproductive chances grow fewer and competitive ranking clearer. There Is Joss ta compete abaut. Risk tolerance grades steadily down with age, and capital wre reflect the change with Tower risk and velurn, This gives the basic theme. The next key information was tal human capital is owned disprapartionately by the young, We own little else until independence al age 20 or so. Physical capital Chapier 5 Waals New? 317416 2 builds fron (ben on, and peaks near retirement, Bul human capital arows quickly in the 205 and thirties too, as most human and other depreciation is concentrated toward the end. These are persuasive reasons to think that buman capital is the riskier and higher-return factor overall, The arganient becomes complicated in that most investment in us before independence comes from parents rather tan from sell nvester work, Parents havea a sirang say in what risks children run, so that parental risk tolerance governs Lio. Mui iL governs mosk in pre-teen years, when parents themselves are passing through their own risk tolerance peaks. And human capital is probably (he ‘most versitile of issels in adjustment Lo our lustes for risk al the lime. Cops can become robbers at will, and robbers can get religion. We should not slip into the ceror of concluding that an individual's human capital is viskicr than her physical capital at the same time. Both adjust to her current risk profile alike. That's why the parable of the bass and her secretary falsifics the notion thal ay eompunsaless realized work and nothing else. Thal wuld make return of ead in her burman capital a litle aver 100% per ay al the start of Une as day, and 100% per second it the start of the last second, even while their security port folios reveal their time preference rules as a (ew percent per year, Human capilal is not inberently risker, as hand grenades than nerfballs. Each cohort adapts all its wealth ofboth (actors, counting balanced security portlolios as single wssets, lo its single chacacteristic risk profile, There may be novelty, but not tuch surprise, in this projection of the owner onto the asset rather than conversely. “That parable helped contiem the pay rule and explain age-wage profiles. (t brought another surprise alang the way. [grew up being Lold that houses are safc: imvestments. But in Fact Uney are awed by about the same age group and gener mix thal owns the business sector, The publicly traded corporate sector is a part of the business sector hat has given up return for safiy by providing instant liquidity fo shrehalders, The notion bial houses are safe (ook a punch in the gut in 2008, The Chapior 8:5 Waa s New? 317416 3 notion tha they ever were rests prety much on evidence bolstered by government subsidies such as FHA and FNMA and EMAC which began before | was born. As itis, | don't sce enough evidence either way to assert whether houses or the publicly traded corporate sector, cap-weighting its stock and bonds, should be risker. But even that uncortainly is a surprise in view of what vee all were taught. Depreciation Unry is ane of my Favorites. IL doesn'L upset the applecart as much as the pay rule dacs, because litle ccanamic thears depends on ft 1 love it because it reverses Lradition precisely. Natianal accounts mae] depreciation as declining expanentially. [model iL us rising exponentially. Is the same vguation with a pus sign in place of a minus sign. [love its obviousness once we think boul iL (L follows when we remember the present value cule. Once we do, evidence for both factors ‘makes more seuse. Depreciation theory rounds out the pay rule in explaining how pay can vise or hold steady to the very end. And we see the same in businesses. Gross realized profit, analogous to pay, docs not tend ta decline as Hrms approach a date with the wrecking hall. My inpressian has heen that rents gn down when properties aren’Ukept up wr locations became unfashionable, but nat with age in itself. When it's time Lo demolish aod rebuild, premises are more typically vacated wilh trade sill running 4 norms, Gross realized profil is inevitably all depreciation on the Lust day, and would approach zero steadily if tradition were right. “There my have been mivor novelly in ty derivation of my (ree fundamental theorems as at least subjective certitudes following from definitions, and in ty idea tsclt of subjective as distinet from empirical certitude. A subjective certitude is one such that contrary evidence would falsity the convergence axioms. | have found little or no empirical certitude past the cogito. | concede that the idea of subjective cartitude bs impertinent. Taw fare we infor what people mist think? We dure when we infer from definitions. T began with the somewhal unusual definition uf capital (value) as perceived means foreseen laste satisfactions. The usual “means of production” is equally valid, but less suited lo my purpose here. | Chapior 8:5 Waa s New? 3116 + then pictured a furs instants worth of expected satisfaction. Its perceived value al that future moment would give its perceived value now save for ditferences explained by the time gap between. | adopted the old terns time preference or time discount rate to account for whatever they might be. There was no assumption as to whether the rate should prave positive or negative or zero, nar that the same rate should apply to other future fnstants. My goal was 10 leave nat even the farthest- etahied of Taophiles. TT have succeeded, the present value rule filluved as subjective certitude giving exact expectations, thaugh not outcomes, fir each future instant andl Uns far all together: Note thal my depreciation theory foflaws, bul with th cave at the version Thicve shown adds the usual nssumplion a lime preference is posilive, Thi partis nol certitude, allbough neither are we likely lo doubt Itveas not hard to derive the maximand rule as the nex: step. Once we define tastes or more generally aims as whatever behavior reveals, the rest follows quickly. {Remember that 1 have na problem with mymally circular definitions.) Therw were probably a few heuristic novelties, The parable of the has and er secretary might ilsell be new. So might tbe slave paradox with its parable of Phil and Bill Many including Adam Smith have pointed oul economic inefficiencies in slavery, ‘moral criticism aside. | can't recall mention of this most obvious one, Bill's ‘maintenance consumplion was Laste-salisfying cash low to Bill and capitalized in his present value to himself, tis pure expense to Phil once bill is enslaved. all but one of us vere enslaved by the one lef, national output would drop by substantially all maintenance consumption on the boaks of the one slaveawmer. There may also be minor anvelty in ny analogy between accounting for the firm and accounting for human capital in Chapter 6. One possible wxam ple is my use of the teem “decapilalization” 0 include depletion and liquidation in sale as well as depreciation. Tt simylifies fo depreciation in the cask of human capital because that factor cannol be alienated in reinvestment or ill ar sile, One inference was thal Chapier 5 Waals New? 317416 s deadweight loss, negative owpul, negtive realized ouput aod unsecoversd decapitalization all tean the same. This is obvious enough, but may have been left implicit before, Chapier 5 Waals New? 317416 5 CHAPTER 10: THREE PANTHEONS A few weeks ago | was being interviewed about ty opera "Usher House”, How would 1 like to be remembered? With a straight face, {said I would like to be thought the best composer since Mahler, the hest poet since Masefield, and the best economist since John Stuart Mill. The interviewer looked startled. Was she talking instead ta the successor of Dan Quixote, Finger Norton and Walter Mitty? Prohably. fut not to warry. Bantasics are goad things. They don't become delusions ntl we stark believing Wem, What belive is tat al least dorens of composers haves he krack, There ontist be hundleeds, considering the terrific film scores alteibuled Lo names neve (o me when [hang on for the credits, Bach of us, very much including film composers, gives the world what we think it needs, We like Lo be appreciated, bur we dou give a fig shat it wants. We won't always agree on what it needs. We'll defend to the death the other guy's right to his message. But we preter our awn. That's what my answier meant We're cach the best. But | do have the temerfty to init the lst to those few dozens or hundreds. Sormeane might alsw be surprised al my choice af benchmarks in versy and economics. Masefield and Mill? A consensus might have picked T. 5, Elliot, say, and. Lord Keynes. Muse{leld and Mil are likelier (o be remembered us old-fashioned fuddy-cuddies already outmoded when they wrote. But that's me. | am Don Quixote. Nota single idol in my puntheons in those three fields was born aller 1900, allbough that could change in economics. My pantheon in music is Hach, Becthoven, Schubert, Wogner and Mahler. Mahler, the Jast-hor, died in 19719151. What about Mozart? Clearly colossal. Listen to the slow mrvements af almost any of Wis plana concertos. Chililike simplicity, then a light surprise, Une arather, and all at nce we are nna rig rough the stars. Bul my Lop five show us more, Mozart is fo darned enigmatic: He is too dared voy. He is Tass tamed Unirdd-persainal. Anil 1 ike breaking a sweat. Mozart. is uniquely the Chapier 10: Three Panthcons 210716 1 realest al what he does within the bounds he chooses (0 sel, Bul Like answers «s well as questions, The five in my pantheon give me those, Mozartis unrivalled at what he does hecause no one clse plays the same game. What other composer has put such a premium on delicacy, on poise, an self-cffacement? That docsi't deny that he was a red-blanded mensch who Javed ijins and good times as ouch as the: rest al us. Wis Ronda alla Tren is one of many masterpieces showing that ste. But it only rounds aut the finpressian ara Nawless dinner Campanian. A maxim of dasicism in tne Greek spiril bs “nothing in excess”. Mazar’s exuberance wo bijinks were just the right amount, He wats the master of moderation. His operas put passion mostly in the mouths of clowns and villains such as Papageno and Osmin and Queen of the Night. His sympathetic sorts have feelings too, but keep them circumspect. The perfect companion cares first ahout aur feelings, not his. Mozart remains that even on our Journeys together through the stars. We ave kept safely assay fram the heat. We ave allawed 10 Feel ansiety ecamise the work is sa ar helow, That was half Ue point of th rip. The ther Ralls the happy ending as he leads us safely home. Ansiety, but notin excess. “hat shows hin as the master of levitation. Richard Steauss gives the example of Susann's aria "Voi che sapete® (you who know) from Figaro, an innocent ditty which somehow never kinds on the tonic (home note} until the end. The beginning of kine Kisine Nachtmusik (a little night music} docs this again. But the slow movements of his piana concertos show it hest. Mozart is not my panthean, even so. le is maderatian in excess. like the game the athe all play. [ike a sense af the first persia singular. The five in my pantheon also take us through the stars, Bul they ake us closer. We feel the heat because (hey dn Listen ta Backs chacamie for sola violin, vr passucagfia and fugu for organ. Listen to the eilige dankgesang {holy song of thaoksgiving) from Beethoven's Chapier 10: Three Panthcons 210/16 2 quisrtel opus 132, Listen to the slow movement of Schubert's Lwo-cello quintet opus 163, Listen to Wagner's licbestod (love death) from Fristan, or Mahler's adagietto fom his fifth symphony. This music plays for keeps. “The polar opposite to Mozart would he Verdi, Like Mozart, he is nat in my pantheon hut clase. Far Verdi, na passion fs tan much. 1c is the master of contrast, ie shakes our ematians hack and farth as a dog shakes a ral. Lull and storm are each given enough time th pack the most punch in the other. Te wants only appasites and extremes, Whit wuld the fatidions Frans Jaseph have thought? He would Have called he guard Somewhere between Apollo and Dionysus, between relativism and frenzy, lies the true path. The tive in my pantheon have found i. 1 seldom call myself a pact, since that's already a tad vainglorious. For hetter ov werse, In a Jack af that rade tan. The true pocts in ty panthean hegin with Keats ami Masefield. 1 havens found a clear choice far third. There are awesome ings in Milton, Blake, Caleritige, Tennyson, Family, Houseman, Robinson, Dawsan, Yeats and athers, Shakespeare, like Mozart, doesn't figure in the center of the picture. J take him as the. arealest mind and soul yel known, the greatest playwright, the greatest wriler in general, and all of these because he taps to the bottom of what poetry can be, "Who ss this whose griet/ Conjures the wandering stars, and makes them stand Like wonder-wounded hearers? Itis I, Hamlet the Dane”. Holy mackerel! Hut these are touches fn his plays. Poetry. in his time, meant samething toa cailted and pretty and mannered for my taste. You can take Venus and Adonls, the Rape of Lucreee, and the scanned That includes the petulant dark Lady sannels, which break Ue model of preciousness bul find nothing better. Shakespeare simply came along lwo early, 1 credit Milton, in *Lycidas®, fir discovering Use true vein a few decades Tater. Chapier 10: Three Panthcons 210716 3 Tha Jeaves economics. Here ) really have a one-man pantheon io Sir William Celly. | suppose that | a the only persou to have looked at his portrait alongside Isaac Newtou's, in the Royal Society which they co-founded, and seen the two as intellectual equals. Mill seems a cicar second, thanks to his superb paragraph on growth. The candidates for third sec well hehind. Maybe Jevans ar John Rac or Lean Walras. Time has not heen kind ta the teachings of Keynes. 1 would nove rank is echer Alfred Marshall higher, Tiki Myrdals magnificent is ante - ex post distinction. Baehin Bawerk and the Austrian schoal are underrated. The pantheon might hare rom fo hiro. Am] being (00 tough on later economists? We should nol forget Sciaullz and Ben- Porath. Schulz greatest achievement, unless Mincer beat him, was in spotlightiog human depreciation. hat left me to ask where this huge flow goes. The answer becomes inescapable once we focus on the question. gives the obvious solution to the age-wage problem. Everything in this book is obvious. Some af it, ike that solution, is the abvious hut nimaticed. Someludy, soaner or later, hrwaks he news ahuul the ein peror’s news cvthes. You'd think Don Quixote woukd be Lhe [4st Lo pipe up. No one in the world was mare devoted to tradition and beautiful creatures of the mind. But it takes i fool. He was that, and so am I, Der reine tor, There have to be a fev of us always, We'll get a few windmills before (hey they gel us. Chapior 10: Thro: Panthccns 210/16 po APPENDIX A: The Argument in Notation Output and Cash Flow My focus will be on absolute rather than per capita values. The usual custo gives capital letters for the former and lower-case anes for the latter, | will prefer the upper case for stocks and flows, and the lower one for rates, That need not bold true for Greek letters. The tatal retuen truisin can be natated Y=R.-F, aL where ¥ is autput, K, is total capital and I is cash law. Also. F=teC, and T=r,-7, iaLzy where © (tau) is vet transfer, © is transfer out, © is transfer in and C, is pure cansumption (exhaust n taste satisfaction). Cash flows Is the net of positive loss negatives compunents {define Uhm by E-T+C. Boz and FFF (41.20) at the collective scale, where transfers cancel internally, these equations combine for Y=K +C and F=F =C, (a13) Math reminds us continually that “equals” docs nat necessarily mean “is” {A1.1) and {AL3). for example, do Not MEAN that OUTHUL is growth plus cash flow oF growth plus APPENDIX Toe Argumestin Noution 3/7/16 1 pure consumption. Why? Output in itself means cretion of economic value, Mathematically, that could include what | called “output exhaust’, meaning value exhausted as soon as created. | ruled that out as "free goods”, which happen every day but are neglected in economics as unable to influence behavior either before or after. That's why "equals" cannot mean “is” in (41.3). And neither dacs it in {A13). Rather both state that sutput pravides cash flows affser plus total capital growth This distinction helps everywhere in econarmics. We knaw far example thal lranser aut may be din either from capital in place or fram coprarrent wulpul, The source of first kin is decaptialization . Bul decapialization also includes uther components than transfer out. In Chapter 3, and again just now, | excluded output exhaust as free goods possible in math but neglected in economics. That makes duapitalization D the any swurce of pure consumption C, . And nol al decapitalization is Lransfer or exhausL. Some is deadweight Joss, defined in (41.1) as any negative sum of capital growth K. and cash flow I. That can show in D=D_+D, and Db =D +C. are) Here I is recovered or realized decupitalization, U, is "\ransfer depreciation” nel of plowwhack into the same asset, and , Is deadweight lass. A Is fombda. 4t the collective scalk, where Lansfers cancel internally, (41.4) becomes n,=6,. (A144) the dispositions of transfor out may be reinvestment in other assets of the same owner, or may be gift donecs. Reinvestment can he interfactor as show in Chapter 5. transfor out trom fatal capital of any individual, net of internal transfers, APPENDIX Toe Argumestin Noution 3/7/16 2 simplifies (0 gift. Transfer in gine by the owner’ total capital, nel of the sume internal transfers, is gift received. ‘The math becomes =r. vey ov. B=r+C. Esp and Fey, (ALS) atthe scale of cach individual's total capital as a whale Tere 3 (garmme) is net git, y, isgiftand y_is git received. Divide (ALL) by K, tofind + - Bs & i ALS} Define these thee ferms as producivily or cate of return 1, total capital growth rate: and cash flow rate [Theo {A16) can be reexpressed as roger. (AL6a) (R13) cambines with (A1 6 to show: Y_§, €, ¥, “i «© . atthe collective scale. (A17) Define “pure consumption rate” «, as €, /K, and substitule to shove r-gtc,, atthe collective scale, {AL7a} APPENDIX A: The Argumest in Notation 3/7/16 3 {ALI (ALS), (AL7) aod (ALB) ae wliesnalive statements of the otal return truism. Tn general, define 8(Q)=4/Q for ay varishle Q. Note again thal g in this hook Means growth rate af capital g(K,) rather than output. gin macro tradition usually means growth of putput (Y). Tatal capital K, is the sum af human eapital 11 and shysical capital K. Theic outputs respectively are work W aod (net) profit P, Their counterparts Lo {AL1) nd (A164) we Wel FW), (M=g(i (0), P=KIFR) and r(K)=g(K) 11K), (A18) where E(H), f(H), F(K) and ([K} ace respectively "human cash ow”, "human cash flow rate”, “physical cash flow" and “physical cash flow rate", Present Value and Present Cost If there were na such thing as tne preference, present and future value would be the same. All economists knowin t me eoniile that sie prefer present gands utr anes, althaugh some like Joseph Schumpter have seen no good rasan why. 1 suggest a reason in vex geoeration theory. Present value theory, wterstood in essence by (he Sumerians, considers whal we now call future positive cash ows which are expected to be generated rom external investments (transfer in, negative cash low) made now or earlier. At the differential (infinitesimal) scale, we can write the associated future value as A¥VER) =F [£)dz zn at futare moment z. The basic idea of present value bY is APPENDIX Toe Argumestin Noution 3/7/16 E APY) F {ze “1 “da, 22) where is the appropiate Lime diseount rate. Note the implication Fe APY (Je, 23 showing that q is the growth rate that raises the value of dPV(x) to F,(z)dz over rind 7 Since this differential campanent af asset. value defers all positive cash ow until moment 7, and cannot in itself he allected by lator Lransfors in, sitopifies by (41.6) Ub rate of return. This was Boehm Baserk’s insight, although he was not mathematical, in squaliog lime preference rate ( rate of celurn 7, Thus {2.2) and [2.3} give APYCOAX=F, (el and F{Ae= dx" az4) where © 5s the appropriate rate of return and time discount cate equivalently. But what determines appropriate © in these equations? ltate of retarn varies with isk among different assets at the same tine, and varies aver tine with economic efrcomstances. Mast sources [have seen treat v In (42.4) as a variable to he integratent over (x, 7). [mgsel Tong believed the same. My view now looks 16 the conteal, The assel as whole will typically hive received ‘many differential investments before time x and may receive many alter. Bach al inception will bave been priced by the owner's time preference rate then, But ny. theme in risk Uneory is ial issels cn be traded or modified to We current owner's APPENDIX Toe Argumestin Noution 3/7/16 5 sisk lolerunce now, She discounts each expected (ute flow not by her foreseen time preference rate then, but by her time preference rate today. [t seems to me that the appropriate discount rate © in (A2.} is r(x). She will provide for anticipated changes in ber time preference rate by factoring costs of raging the assctif tradeable, or modifying it if modifiable, into her evaluations of future value ¥, (2)dz, and so from present value Loo. | consequently interpret (42.4) to mean APVG)=F (Ae Ode and E (o)drmiPV{x)e IE) 23) The vale of the whole asset Vix) at time x will be the sum or integral of present values of all foreseen cash Hows both negative and positive over (x, o J. where & {omega) she foreseen end paint of flows. o way be infinity o>. Thus Vix) =v()=J He Oe, xemzeme {a2.6) The teams value and total capital ave interchangeable, as are they natatians V and K,. Present cost G(x) evaluates Vix) as the sum or integral of carlier negative cash flows compounded at Tate r since moment of ivestNCNE Y, and not yet decapitalized in positive ash ow. The counterpart 1 (42.1) becames AIC) =F (ua and dPC(x)=dV(x}=dPV(x] nz) where IC Is what 1 call “investment cost”. The counterparts to (42.2) and (42.3) are AV{R)=F (we™ “du and F{u)du=d¥(xje ** {A28) APPENDIX Toe Argumestin Noution 3/7/16 6 hee equals some appropriate « by the same logic as before. Here again, we usually read futerpretations of (428) which treat the appropriate © as an integral of time preference or equivalently ProGuctivity rates aver the interim (ux). 1 Toever ste dV(x) as determined by current rate r(x) whether derived hy present cast vr present value ethan. If the priginal investor remains Uys current owner, aol vow (ins ber time prefecence rate different, she will have factored asset ‘modification costs into her original decision lo bid or ives. [f vol. she will have traded to someone whose time preference rate is better suited. My counterparts to {Az.1) and (726) become AVE = PU) =F [We ™dx aod F Q0du=aveen (a2) and Vix)=tex)= [Hue Cody, (AZ1Y) These equations stem the most stra ightforsard reconciliation of the masimand le, the canvergence axinms and Lhe wvidence supporting risk theory. They describe indivieual asses over time, svmelimes passing from one owner 10 another, rather than a given owaer's loll portfolio, We maximize return within current risk tolerance, recoguize that it will change, and deduct present value of expected trading or asset modification costs from future vale of flows while adding them to original value. This scoms true to life. It allows discounting all expected positive flows aver (¥,7), and compounding all past negative ones aver (0, ), at a single rate +(x) heeanse af thse adjustments value or cast of lows. Tradition treats the Moves as se givens, and Une discon rates 1 fanetion of nds time belo x and 2 or betsicen 0 and x APPENDIX Toe Argumestin Noution 3/7/16 7 My interpretation thal the lime discount rie /rate of return we naturally apply in evaluating both present cost and present value is our time preference rate now, sather than Some remospective or prospective average, might scem counterintuitive. Ipropose it, even 0,25 the "time discount rule”. Analogy to the Firm Tallow convention by eating all transfer out as compensated by actual or impute severe. The part exhausted In taste satisfaction gets imputed revenue paid by the consumer satisfied Noval] revenue compensates transfer out, as revenue is usally defined as sales proceeds aginst which prio vulside claims oust be satisied first These are ypically for labor and supplies io the case of the firm. Chiapler 6 gave the Togic in word equations. It begins with ppp. (421) where p is revenue, p, is prior claims and p, is "earned revenue” as « residual. Farmed revenue, also called grass realized output, is thus remaining share of averall vevenue earned hy the Finn ov other entity that performed the sales, collected the prices, and pail the: autsile daims an thn. What the the firm ar ather vontrilaitin gives up Lo warn the warned revenue is the sum of its realized output Y, and its recovered decapitalization D, . Remember from (#1.4) that D,_ includes any pure consumption realized by the omer of the source assed, although thal could not apply where the awner is taken as a firm. The sumof ¥, and D, gives its gross realized outpus. Then Yowss=p ~Y, 4D, 43.2) where ¥, gross is gross realized autput. In Chapter 6, 1 also called ¥, gross or p, “gross positive cash ow”, All mean he same, Twill usually leave out (he otition APPENDIX Toe Argumestin Noution 3/7/16 8 p, Tram now: on, and refer to gross realized autput ¥, gross alone. Positive cash flow is that less plowback from revenue. This can be notated H=Ygros p=, =D, po, (x33) where , is plowback. Negative cash flovr is transfer in, notated 1_. thus E=tandF [, F=Y,+D, pa, 7. (a3) Cash low F is the difference F=E M=YD, pf. 25) Gross output is gross realized output plus unrealized (or proprictary or selt- invested) output. This can show as Y,. = Yams ¥ =¥ 4D +. (A368) Think of the subscript s 4s meaning saved or sell-invested. As all output is either realized or unrealized, we have Y=Y+Y,. “the terms saved, selt-invested, vorealized and propeiesary will he taken as interchangeable. APPENDIS 4 The Argumcetin Notation 3/7/16 9 {3.6} combines with (A1.4) and (ALS) to arrive at =F =Yaros-p, {A37) at the scale of the total capital of the individual or any set of individuals. This fact will prove: helpful in adjusting the Ben-Parath model and in next generation theary. 1 should he borne in mind thal transfer out and transfer in ace bath implicilly defined as nel of plowback in the fest place, Thus iL would be wrong to suppose thal negative cash (ow is transfer in less plowback (rom revenue. That mistake would deduct plowback twice. The Growth Truism Growth af any asset of either factor is capitalization from autside plus capitalization from inside less decapitalization. This difference can ako be called net capitalization. Capitalization from outside is simply transfer in =. What are the other two? Qur fest intuition would be that capitalization from inside is identical to unrealized output. Here we must be careful. Output is negative wherever the sum of growth {net capitalization) and cash flow falls below zero. This “deadweight loss” is smyiicitly uncovered decapitalization, meaning not recovered in cash flags. To subtractall including unrecavered deeapitalization from the sum of transter in and mrealized output would therefore subtract the wrecovered part twice. To wake this lear, define positive and negative utp by Y{=0)-ma{v.0) and ¥{<0]=max(-Y0)}=2, APPENDIX A: The Argumest in Notation 3/7/16 10 where 2 (lambda) is deadweight Joss, Meanwhile negative output belongs in the unrealized compunent plaulpul Y, as with al effects an nel capilalizalion nol explained by teauster in or plowback trom revenue. Itis the random negative component in free growth. Then define positive and negative output and realized output more fully by Y[p0)—max{¥ 0], v(co}omax{-y joa, v -¥(>0)-2. (44.1) and V(>0)- max(V.0), ¥(<0)- max(-Y,00-4 and Yo V(>0)-4 (#42) There is also indirect capitalization from inside in the form of plowback from revenue, The grovwlh truism sums these inflows Jess outflows as R= 4¥ (0040, 0-7 +Y +p, 1, (443) recalling that D, shows recovered (realized) decapitalization. Atthe seal of the tatal capital af any individual or set of them, (A1.5) and (44.3) give Loa St i Ae {ae4) Human Cash Flow Although | can't recall secing the term “human cash flow” in any papers or textbooks of others, tradition defines the How discounted to human capital as pay less Schultz” “pure investment”. The flow so discounted is implicitly cash flow. | rename pure investment “invested consumption,” and write the traditional view as APPENDIX Toe Argumestin Noution 3/7/16 1 E=x-C,, [78] where k, isbuman cash low, 7 (pi} is pay, and Cis invested consumption. The subscript 5, as usual, means saved or sclf-invested. Pay x can he defined as the worker's literal or imputed revenue. Self-invested camsumption C, can be defined as any investment in human capital other than through self-invested work. This mikes C, all investment from outside in sense, But that does not mean that itis limited to transter in. There is also plowbacl from revenue (pay 7 ). a5 when we spend pay on texthooks or tuition. | model “pay plowback” x, as minor in Ue world we know, but definitions must acount for it This | defi C=t(l) -m, or iH) =C,-7,. 5.2) where (H) is “human transfer in”, This and (A124), showing ¥ = , give FH) =2(H) =C x, . (453) {A3.7) and (A3.2), analyzing the finn, derived pep, =Y,guss=Y, =D, For human capital, this can show as Tom, = W gross -W, +10, (#54) APPENDIX Toe Argumestin Noution 3/7/16 12 reading "pay less prior claims on pay equals earned pay equals gross realized work equals realized work plus realized (recovered) human depreciation”. Prior claims means outflow {transfer aut], from sources other than the diveet vecelver of revenue, which are recovered in it and owed hack to them. Maintenance carisumption can le defined as any Lransfor aul rom any wsel of either factor, outside the human capital af the carner, which supparts pay in the sense that any Js maintenance consumption would Fave realized less pay. This meets every criterion of prior claims bul soe. Maintenance consumption is the prior claims meantby x, in (45.5) itand only ifit is actually recovered in pay or so intended. Tze ny arguments that iis neither, bul s rather exhausted in satisfying our laste fir survival, in Chapter 6 and elsewhere. 10am right, (45.4) gives =O and AoW), Wars (455) 50 that pay would measure and compensate gross realized work. This is the pay rule. By (A33), positive cash How is gross calized output less plowback from revenue. That comes to FI), =W gross & =x x, (x36) Maw vee ave FO}=F) ~F0N) =7-7 ~(C,~7 )=r=7,~C +7, -7-C,, {A357} APPENDIS 4 The Argumcetin Notation 3/7/16 13 ‘as the application of (43.5) to human capital. This confirms the waditiond view {45.1} (AS.5) is right iv interpreting prior claims on pay as zero, 161 was wrong there, and Quesnay and the physiocrats were right, same ‘maintenance consumption would be recovered in revenue af its suppliers. Then [ should have written something like C=C +L, =C, , where “transfer consumption” €, was he value recovered by suppliers, This mathematical possibility, which { do not claim to have disproved, explaius why | do not claim that the pay rule is logical certainty as a whole. | claim certitude only For its mast surprising feature: buman depreciation is expected to be recovered i pay. The rest follows only IF (AS 5) is sight a3 1 think it fs. Meanwhile (43.5) also gives €=C+¢,, A38) where C is consumplion. Saved wark WE. neans the sulf-invested output of human capital. IL includes the sublininal and effortless work of ob experience ws well us the effort aod opportunity cost of Herd! schooling, und so includes any (ree growth of human capital. Then Wa HW (459) The grawth truism (A4.3) for human capital becomes HCW {5 0) =H) =, + W, ~ D(H), 43.10) Human Capital us Present Value Note APPENDIX Toe Argumestin Noution 3/7/16 1 1d x-C, 8(F|H }=g{r-C)=——"—(7-C)=—, [46.1] RFI }=sfm-C) Fe ge 61) and also FH) &-C = . JT I eR 16.2] an- 20 Lo fez) {25.5}. | take this as meaning all adult productive activity not self-mvested. Then the ratios & /H anid €, /H , lhe ralio of invested consumplion to human capital, might both be intuited as biological norms, like the generation length, which tend to hold steady aver time. Meanwhile the definition [TF /K, fn (A1.6) and (A1.6a) is applied Lo human pial as =F ==C, {a63) fan” ion Whal we want is Lo quantify [(H) in order \o reveal H [rom measured or modeled =, Next generation theary measures cash How rate of total capita, which simplifies lo the pure consumption rate. al 3.5% a year as a reciprocal of lhe generation length. | argued that the risk component in rate of return is captured in cash flow cate, vather than growth rate, that return at any given moment varies only wit isk, and that human capital as a whole should prove the riskier and ighr- return factor. Then f(H) should prove generally higher than 3.5% per vear. That could give the Key to quantifying collective human capital through (46.3). 1 vA not attempt that step here. A reason is that national accounts reflect pay mixed with APPENDIX A: The Argumest in Notation 3/7/16 15 Profi when reporting income of proprietorships. [would rater (rust an expert in national accounts to tease them apart, and to judge whatever pay should be imputed. 10 people in the household sector not lirerally employed. The Level Payment Mortgage (Az) gives he) =k Ha gy A7.1} Consider the level payment mortgage. F(z} is the constant level payenent while (x) 5 the constant interest rate Here (A2.5} simplifies to Ve =E] c= drake [Tear non] 72) 5 there 3s no self-invested output, aud io negative cash flow after foitial investment al time 0, decapitilization (amortization) simplifies Uo ~V(x). Thus ” d Fy wa | Fowd ow Foo 7. x)= -Vix)= wal oo Je wm {A73) confirming that amortization increases exponentially over the term of the mortgage. Depreciation Theory Depreciation can he defined as decapitalization which is a Fanction of time since capitalizatian alan. When assets change hands, depreciation continues unchanged. Depletion and liquitkation in sale, by contrast, ave aptivns available at any assel age. Amortization van be given the san definition as lepreciation, bul is customarily APPENDIX Toe Argumestin Noution 3/7/16 16 applied to paper rights such as the mortgage rather than lo physical or human. capital itself. Depreciation of those assets is not as simple as with the mortgage. Cash flow I and discount rater are typically variables rather than constants. Depreciation theory avoids that complexity, much as accountants do, by treating cach suceessive vestment in an asses iF il were separate assed depreciating in itsell. {AZ3pUhriugh (42.10) gave: present salu at Lime x ofa differential foreseen, sitive cash flow at future lime 2 as APV() F(a " ~N, any where the differential present value srase from a earlier or concurrent negative cash flow invested al lime u<=x . [Las shown (hal all of assel value PY(x) a any time x can he explained as a sum or integral uf such differential inerements evolving with tne alone from Investment ta eventual realization, Meanwhilk all autpul within the differential increment of dBY is self invested. Growth dPV can be understood either ws Wis sell-invested ouput or equivalently the shortening discount period, as each mens growth alate r. AUnlerim moment titis avy =sarv=pe n= CFE ee era ay JE hus present value rises exponentially aslong as the moment of cash flow is deterred. APPENDIX Toe Argumestin Noution 3/7/16 17 Atmoment z sell-invested oulpul ends and all change in value is explained by depreciation alone, (t equals the entire accumulated value of dP at fing] moment z. Thats, Dz =—dPY (zz =dPV(z) =dPVx)e (483) The following table shows sme ilust atians: Depreciation Factor ¢“"* * it z—x is 50 Years Interim a—x (years): [ 10 20 30 a0 50 lactorit (x)= 035: 174 247 350 497 705 1 actorif {x)= 063: 039 074 42 273 52 1 This exaclly reverses the analysis applied in valional accounts, which models (be factor as decreasing rather ban rising exponentially. Jt should be stressed that these equations and this table describe each successive differential increment of outside investment (transfer in), not assets overall or groups oF therm. (transfer in Were Constant and contingous fn an asset or geovp, other things equal, averall depreciation would shows as lincar. Free Growth Theory Ty te fatal return trvisen (A1 6), showing r= § 1 1, we derive g=r-f. dg=dr-df. and Ag=Ar-af. 49.1) dy or Ag Is "acceleration, de or Ar is "productivity gain” ar “free growth vate” and = or =Al is "thrift gain", Divide by acceleration to reach APPENDIX Toe Argumestin Noution 3/7/16 18 deal _drdu_dran_ + _f Ar de 0 _drdt dine Fp ar ar I) dy dg dg dg gg ay Ag de, or AC give free growth as a flow, while ~diR, or ~AJIK., give the fav of thi, Define the “productivity index or *[ree prowlh index” o (phi) as £/§ or Ar/Ag, and the “thrift index” 8 (theta) ws 1 /& or -AF/ 2g. (49.2) can then be puts o-6-1, (A920) in either the conlinuous time or discrete period sense. Free growth theory is the prediction that ¢ at the collective scale will average unity {the numer one), implying that 6 averages aero, When @ or 0 is measured for exch year or for shorter periods if practical, Thrifl theory makes (he opposite. prediction 6-1 and ¢ 0, The point is to compare simultaneous changes in acceleration and thrift, and then Hind the long-term average of these simultancous Ghscrvations, rather that compare long-term changes In the First place. IF free: growth Is ight, they will prove uncorrelated. That Is exactly what the charts and tables shave whenever data are available, Acceluration is as likely ta caincile with unthrifl, meniog increase in consumption rate C/K, ws with trill Division of (49.1) by acceleration was not essential to the logic. 1t added the convenience of index numbers totaling uty. “The test should he as fine-grained as practical. Ifthe Pikerty Zucaian wehsite showed quarterly ar manthly data revealingany byo of 1, ¢ and 1 would have averaged the largest number of shartest periods. What 1 iy to compare is ex ante. APPENDIX Toe Argumestin Noution 3/7/16 19 acceleration, measured as (rill ~Ac, and ex post acceleration Ag a Ube sume moment. Otherssise we dant have the clearest test between free grawth and thrift thearics. th agree that consumption ean keep pace with nutput and capital aver ime. Free growth Unvory msserls tal they keep pace continuously Correlations tell the same stary. Tables show tha coellicients between © and g run shoul 1, as with the free growth index, while correlations between [ aod & run about zera, 1 do mot claim that anyone but bill and ! has actually proposed tree growth theory, nor that anyone at all has proposed thrift theory as here defined. (tis my impression, not assertion, that mader consensus fits thrift theory given Harrods qualifier that attempted (ex ante) net saving (thrift) must not execed the technological growth vale (sar ranted grinsth path). My fimpression is tat Sula and madera Lradition agree, bul blunt Tharranl’s knife edge. Free grawih theory counters thi the same srowth acrives costlessly when ex ante nel saving investment is held ai zero, Nor do I claim that data shown in omy charts and tables prove free growth theory. Rather they demonstcate (hid all growth has prover (ree wherever measured o date. Saving/ Investment Unlike Lord Keynes and modem tradition, | define saving and investment as synonymous am the start, 1 don't strictly need either term. My “manster in”, “unrealized outpus” and “plawhack” arrive at the same thing, But {know must do my best Lo write in a language al rearly understood. Lill usually say “investment lo mean savinginvesiment, and will ise Keynes” notation T for hth. Keynes did not explicitly recognize human capital, although he very probibly understood it. He treated investment in physical capital only. { notate this |(K]. 1 also tral investment in Latal capital, ta be notated KK, ). Tach, as in Keynes, sums depreciation veenvery and “net investinent”. The latter, in my treatment is APPENDIX Toe Argumestin Noution 3/7/16 26 considered in both ex ante id ex post versions, The subscripts xa wad xp will show which, Fe ante nel investment car be mated I(K,),, and defined as identical ta thrifl Naw QIK, } or AIK). Its rate is the same as thrift rate ~df or —Af kx post net invesimenl is actual growth K, or AK. /at asa low, and § or AK, /(K At) asa rate. Free growth theory, supported by data wherever tested, predicts that theift or ex ante nes investentat the collective scale sacrifices cash ow (pure cansumption) with no growth ta campensate. My interpretation is that the aptimun callective ex ante vel investment. rale is zera, ve wquivalently hat optimum investment is current cost depreciation plac from both factors, Thin optimum xan net investment becomes IK, ),. optimum ~0, atthe collective scale. (193) {NeL) DulyuLY at Lal sel is lal capital gronsth (ned investment of both facies) lus pure consumplian. There ta we can distinguish ex aate oulput as pure consumplion plus ex ante investment, while ex post oulpulis pure consumption plus ex post net investment. (3.3) gives Y, optimum =C, , atthe collective scale, a0) where Y,, is ex aate oulpul, Since (gross) investment equals net investment plus makeu for decaptalization, while decapitalization equals pure consumption €, collcetively by (41.4a), we can show I(K,), optitoum =C, as an alternate statement of (49.4). APPENDIX Toe Argumestin Noution 3/7/16 2 Summarizing, TK, vptinum = ¥, optimum —C, , al the collective scale, {29.5} if tree growth theory is correct. Fv ante investment and output mean at cost. They are what we pay far. The practical importance of (49.5) is as a guide t macroccanamic policy. 1 says that we cannot row callectively hy attempting to produce mare thar we consume. We do best by paying fo produce just ss much, and fakiog free growth as il comes, {49.5} does not say that we cannot influence the growth tides. ft says that we cannot do so by thrift. It seems to be me that growth theory lies somewhere in the province of historicism and institutionalism rather than in the mechanics of supply and demand. Judging from history, old and nes, growth seems tind traction in free: markets where laws and customs welcome i. These are institutions shaped by history. Freee gransth heary and 1s equations predict at the vollective scale only. Clearly the Practical Pig can save out of the dissaving of his feckless brothers, while (he sndividual life cycle is largely a story of each generation giving o the next, Adjusting the Ben-Porath Model uman capital bugins at zero vai alcohard age 8. Invested consumption ¢ starts now, and is imnediately compounded by sell-invested work of se young, This means all work before pay begins a age of adulthood and independence A. As human depreciation is expected to be recovered i pay, that flow too is put off uatil age A. Then cohort present cost at any carlier age x, as detined in {AZ.10], is HEx)= le @e™ dz. of xem (a0. APPENDIX A: The Argumest in Notation 3/7/16 22 J argued that outside investment in human young, including the unpaid work of ‘parenting, night not be far from constant. School costs rise 2s parenting costs dectine. {A10:1) in that ase gives Hx} Cammy] fxm (A162) eh 1 “ ) AL maturity (A10.1) becomes HA)= Ce a (#103) Hin adulthood is easiest to model at present value rather than present cost, Human cash flows Is pay less €,. Discounted cash laws becomes Wep= "tr CHR dz, I x5=A, (A104) where 1{z) now is best understood as time preference rate. This is identical to expected rate of veturn, as shawn in the diamond ving parable. Note that there s na explicit agustonent for asset isi | argue that human capital is not uherently iskicr ‘han physical capital, ht rather adapts to the ik olcrance of es owner, It isin callotively hocanse avned disproportionate by the risk alerant young treat vik profil ns Function of Uh avers ng, gender ned wrath, (A104) desires cohort value, and so neglects individual differences in gender and wealth as already caplured in the characteristics of the cohort, Tmadel as negligihle In adulthoad hecause 1 see so little of it. That would reduce adult human cash How ta pay alone, and so simplify (A10.4) to APPENDIX A: The Argumest in Notation 3/7/16 23 Wh Ade Ea, G0 and 2A (103) Mov let's add some detail and bring in physical capital. Like most, | model inheritance as zero and physical capital acquisition as begining after age of Independence A. That can be modeled as age 20. AS human depreciation hegins then at ero, If deprochation theony Is right, gross realized worl (pag) simplifies at fist to realized work. This Lakes up all the new warker's Lime and attention, yet simullaneusly enables sublinrinl sell-investeel work in job perience. I seems reasonsble to model pay al job entry ws equal to the new worker's ‘maintenance consumption, on the reasoning that independence means reaching the ability to carn it. Thus nothing i left tor investment in physical capital at iest, But the quick buildup of job experience soon means pay left for investment, As L model no pay plowback, that means physical capisal acquisition. Thuman depreciation visas slowly while the self-invested wark of job experience diminishes, sa that overall growth in human capital peaks and then declines. Physical capital owned dos the same as we acquire Land thin spend iLon the Young, Young arrive, on average, 45 4 cohort reaches age 26.5 (ony estimate of he generation Jeng). The cohort of adults hegins divesting its capital of bath factors in nurture and schooling received by the young as invested consumption. ‘the young reach independence on average when the adult cohort reaches age 57 (2 X26). Some young will have heen barn after parental age 26.5, and will continue to receive parental Investment over the clght years remaining hetsicon age 7 and rutivermun. modeled aL aye 65. Bul my model canal account confidently far his eight year gap on the whole, ar for the retirement pertod allowing, sehich runs ovis Bang. My hy pathesis is thal retirees are uffiectively employes hired hy ruductives (0 help lake vare of he kis, while the eight-year gap might show a umn capital reserve againsL nasty surprises. APPENDIX Toe Argumestin Noution 3/7/16 2 Reticement can be defined in principle as the period vehen our pay, literal or imputed, no longer covers our majotenance consumption needs. Human capital continues, even 50, as long as we eam any imputed pay for helping take care of aurselves wd others. Maiolenance is nol investent ¢, and is nol deducted in finding our cash flow and its present value, {744} showed the growth truism for total capital ot any individual as Ko=7 4% 4p,-0, recalling that 7 is gift received, Y, is seli-invested (unrealized) output of both factors, p,, is plowback from realized output, and D, is recovered decapitalization. For the young under age A [model K.. asH alone, 7 as invested consumplion provided by adults, Y gross as sell-nvested work, which | model as all work, and I), as7er0. Thus (44.4) is Interpreted as Ky=H=C,=W,=C + W=C +H, lage <=4, (4105) Yeading directly to (410.1) For adults | model gift received yas zero. As physical capital acquisition is modeled as beginning al independence (age &), ¥, now becomes sel invusted output for bath actors. Fel Uhis show as I? far physical capital. p, means pay plnsback ples plowbisck from revenue of physical capital, as with the firm, Thi can show as p(K), But [model 7, as zero hecase | see sa litle of it. Rather Tallow reinvestment of pay APPENDIX Toe Argumestin Noution 3/7/16 25 into physical capital holdings. That can be notated =. 1 don't allow transfer rom Physical to human capital in adults, which would mesa invested consumplion ¢, afforded from property cash flow, because Tse sa little adult ¢, fadull education) on which lo spend it. That's why I model 7, as zero, Meanwhile realized decapitalizaiton is decomposed into its human aud physical components DT), and DK), . This adapts (A4.4) 0 K,=H-K=W_ +8 + pI), =x IH), -D(K], , iFage >=A (A106) aol specifically N=w nN, al Keg, Bip(K)L, DK), ifage>=A 167) Next Generation Theory “The perfod of production, as defined by Jevans and Bach Bavrerk, gave the reciprocal of rate of production (rate of return ¥ /K. ) if growth were zero, Output ¥ equals growth plus cash How. Then Jevons and Boch Bavwerk really meant the period needed for output th make up or 10sses to cash tow. | call this the “cash ase period” 1 , equal to the reciprocal of cash flav rate L That is, 1 T= ALY = (A111 Both modeled at the collective scale, where cash Qow under the ¥ = 1 + equation both would have accepted simplifies to consumption C. Adjustment to the ¥ rule corrects this to pure consumption ©, . That would specify (ALL1) as APPENDIX Toe Argumestin Noution 3/7/16 2 1 Tm + atthe collective scale. (A111) recalling thal «, is pure consumption rate €, /K.. Rae, Jevons and Boehm Bavwerk all got nowhere because they modeled physical capital only. Jevons, in particular, saw the productive cycle as the wage fund reproducing itself as it was used up in consumption per A11.1). He was close. {A11.12) madels ft as total eapital reproducing itself as itis used up in pure cansumption. My next generation they, really Petty's, pasits the generation length as he deadline far Leansimilting al) Fowss (tala) capital) from each generation to the next. The genevation length in ILA. Fisher's sense is average age difference between both parents and all offspring (rom first bicths Lo last weighted equally. [Lis « Dexible bialogical norm. It eas probably well over 30 years before 1900 or so, shen bigh inant mortality compelled longer breeding to ensure that two would survive to breed again. Contraception, lmawn since Roman times, was then less practiced. Jt Seems to Tun a ete under 30 years taday in industrial couric. 1 model tat 26.5 years. That gives T=2BSyears and c= = 035 year 112) {49.3}, inferred from (ree growth theory, already gives I, optimum =¥ optimum =c_, al the collective stale. “Chis Shows That the OUEUE vee actually COTO], MCaning ex nce Output, is aptimized at just enovgh to make up losses to pure consumption. Next generation theory specifics that the loss and make-up period equals the generation length, APPENDIX: Toc Argumstin Notion 3/7/16 27 Under the simplifying assumptions of the life cycle model adapted from Ben-lorath, we would meet that deadline by directing all adult gross realized output less property plowback p(K), to gift to the immediate generation of young received as their invested consumption. The young would add their part by compounding that autside investment into their human capital at the Fate of their cntire ex one ouTpUL. This would prae the mast stralghtfarsear strategy bo exhaustand replace all ital capital by the deadline exantly. This is justas in roy adjustil Ben-Parath model with the addition of the specified deadline. Here as there, L describe adults collectively and the young collectively. | will not attempt to model effects of kin selection in individual investment choices. But | have interned la Tay 4 groundsiark. Tnvestment, in Thamillon's sense, Leanslates Lo gill 7_ in economic terms. [Lis & (low of (otal capital (flness]) from donor (o donee, Al Ue individual scale, as weell as for the group scale, it equals gross realized output Jess plowback. Gross realized output tends to be a continuous tow, as we see it pay, rather than one easily sped up or slowed down. his gives an idea of the time constraints | mentioned in critiquing Haroilton's rule. APPENDIX Toe Argumestin Noution 3/7/16 2 Evolution and Human Choice over Time Alan R. Rogers! 1997 1 The connection between evolution and economics Tn ccomormics, ecquilibrin ime oflon found hy equating bo versions of he marginal rate of sii siiftion (MRS). For example. my MRS in preferences (the ratio at which I am “just willing” 10 xchange hwo goods) should egual the MRS in exchange ((he satio at which | can exchange them in the market). Otherwise, [ would have reuson to scll one good aad buy the other. At cyuilibrism (uz shown in figure 1} these two versions af the MRS must be equal. ‘iis analysis is ulso fumilin to ovolusionry ccologiss, ws shawn in gare 2. There. the indif- ference curves ave replaced by fionexs isograuns, which connect poiats of equal Darwinian fitness." Ta plc of u budget constrint, coulogists study » variety of ihr cansirainis. The principle, Fow- ever, the sane: equilibrinm eccurs a the pois where the two curves lune equa slope. These two farms of amalysis an cammct by something decper (hes analogs. They ace cone nected by a third equilibrium principie, which was first describod by Hansson and Susart [12]. These authors defi the MRS in fitness a5 the ratlo al which (70 £0ads can be exchanged without aftccting Darwinian fitness. “thus, the MKS In fitness mersurs ihe absolute slope of the dotted Ties in figure 2. The new equilibrium principle asseccs that, ac evolutionary equitibrium., the MRS in fitness must oqud that in prefercnces, A simple proof of this principle is shawn in figure 3. The new equilibrium principle adds an additional equation ro the arsenal of economics. ‘The MRS in profircnces must now ual that in fines ax well us Boss in exchange and production. 11 the hypathesis of evolutionacy equilibrium torn out 0 be seul, then this shout allow a more pawerful theory of economics, “Rescuch Cano. King's College, Conthridge CB2 IST, UK. Pisaoc address: Dept. of Actboposogy, University af th. Slt Lac Ciy, UT #4112, 15.4. Publishiod as pp. 231-252 in Characterizing Hiciuan Paychalngicat Adaprotions, sited By G. Dock 6. Cider, CUBA Foundatien Symposium 203. Joka Wily ood Ses. 1a rodels with Siscrecs gonzenions, Dureinia Anes is the conditionally expecta numer of in irdivibial’s affiping gio is gop. Lo modes wih oveuppio oecaion, wes mere hy K€. 3, fis 3] “Malas prizes” wi euces he asp: le of expen ncn sn warns of rs desce dns 21, 1 2 Na 1 A Figure 1: The Indiffaenee Dingram of Ticonowics An individual consumes 5 gency 577 af goo 1. und 79 of good 2. Ie ded indirence curves coed consusaption Luislles lo whic ie is iia. By laying uc selig, the canoes mes Jef or tinh along ths sid Audget fine. UN is asioizec, ut the point. hers th te fines base qual loge, or other words. Uh punt whee MAS MES. 2 Application to time preference Sappose that, in figure 1, good 1 refers to food that is consumed today. sud good 2 to food that is Consumed + lim wit later. With hi inlespretation, le iguee describes preferences regarding differear paths of consamption over time, or in other words. fe preference. To a recat piper £51, 1 developed an evalutianars theors of diane preference using the methods outlived above. “That paper steplifed the problem by assiming that changes in consumption aflect fines, solely via thei effect on susvival, ere, | extend that auslysis (0 iuvorporate effects on fertility 5 well. Tho pralysin proceeds hy deriving om vrprussion for the MRS in fitness, and seting dhs egual to well known expressions for the MRS in preferences and in exchange. | begin wich s srics of definitive. 21 Definitions The MRS is preferences between isnmediate and delayed consuaption i defined by Ni) Rida where he derivative is ken along s Fine of constant utility (i.e. an indifference curve. The MRS 0 preferences is often measured by 8. the marginal rate of ime preference (MKIE), which defined s k — Diewician 4258 increases with increasing vahies of cnametons 1% unc 4, und the dotted fitness isogrions which corabiutious of 612 0d 52) ae feasihi. Fine amy assumed consraint, te esolutonery problet is . ¥ wo xX ¥ v wih Tiguse 3: Why the MRS in fitness equals thal in preferences al evolutionary equiliorium Yitmess und utility each depend vn consumption of conunoditics 4° 7 md 4. TF the MRS in fitness did not cqual hat in preferences, then the saprarns of the fiuness function F would cross those of the wility Fanedion 17, 35 shown in the igure. Llicre would then exis consmnplion bundles, X and ¥, such thar X is proforred 1 ¥ slthaagh ¥ confers the higher ftmess. Lh preference ordering cannot he evolutionarily stable because # tention hit revved the preference between X and would be firvored hy selection. 5 by MRS wo? @ when: as betare + is the time that elapscs borwoen £7) ane 52, The MRS in excliange between pecsent 0d future consumption i the satin oL whith present and future consumption cup be cs changed by borrowing aud lending. Jc related 1 the inferuat ate § hy elt 5 MAS) = al at @ whore 9 is wealth an dhe derivative is taken along 2 line of constant wealth, hit is, along the solid market ling in figure 1. Tho MRS in fitness is defined by it) ws, I) LIE Su. : whore the derivative is (kes along 3 ine of constaat itness +". In equiivrinm, all these versions of the MRS must be equal. 22 Finding the MRS in fitness “Tie evolutionary theory of tise preference is completed hy the possibiliy that the retaras from am insestrnent sway increase de Darwinian Guess of the lavestor’s dwsgheer (ar piher relative) eather tha that of the investor horself. This make il necessary to use the evolutionacy theory of “in weleclion viiich deals with interactions between relives (9. 101. Ihe particular model used here was dovolvped in another context 14], and its application to the eananic problem of tine prefecenoe i disensscd clsowhers [15]. Rather than repeat hat saterial Loe. 1 shall simply stat: he relevant results. 22.1 Resolts from (he evolutionary theory of kin selection. The: theory supposes that one individual (the donor or fnscstor) umiertabes an invetanent that has an immediate cffect on himself, hut a deloyed effect on a second individual (the recipiont). Tee donor and recipient may of may not be the sae individual. The donor undertakes his action at age 21%, and the recipient is affected after + Ge units, when the cecipient's age is), This interuction changes fom £47 to FU + APY the donor's probability uf surviving from age &'t! to 210) + de. “The dumor's erlliy during his same faterval is changed from mit t pi” + Ae. Siwilarly, the Incoraction changes from P*2 to PE 4+ AP the reciyient’s probability of surviving fiom age 8 Lr 2 | ls, The seciplent’s feciicy dusing this interval changed from net wn | Aunts The fit of thi interaction on Dierwinion lies ave summarized ia table 1, which bs acpled fiom table 1 of [14]. Unlike the table used in my sirlier work on time preference 115, tis one includ effects on Fertility a well 5 on mortality. Ln the table. » denotes the enefient of rela- tiouship between donor and recipiont.? the subseripts 1) and # indicate Gre sex of the donor and of TWEETS corllicient of lationship 13, po. 69, 137 138] cas be incerpresod as she Fuction of tas genes tl te india cam expect 10 hob movin, neal | i he donor ad Ecipint we hs sucie val, 12 i he cigint tm lspnog, 141 plik, nv onl 6 Table 1: Low Changes in Fertility and Morality Affect Titness Tiel AddiGve Repioguedve Discount Relationship on change value factor to donor Donat A. fert. Amit! 1 tt 1 Romo. AP rl a] | Recipient Cen. de® | Bo B Dimon, APF WE en r Notas: he cust alle wil inreaee Teeaie) in equency i the sum of row pradunts i positive (negative), The nerstion is deine in he text. For simplicity, | svams chu 3 sex catia bin i ust. at fleets on fotility re bri, thot is ects are small cough fh seensct-neor tran Sm aec AL canbe ignored, and that a single recipient is efecked by each altevistic act. Source: Rogeas [1d, Table 11 the rocipicnt, ind « denis the reproduc ive value (R.A. Fisher, 1938), tis dofinaat by Bie igim iy) ; i @ whete p is the cate of population groweh, ify} the probability of living 0 age §. 7,4) the ex- ‘pected number of ollspring produced at that age. and the subscript 5 inificates he individual's sex “The reprodisctive lus can be inferprotal is he expected present value of an individual's future canéibulions to he gore poo. ‘A gene that encourages the donor ta underiake tis action will oo favored by nak! sclection 3 he sn of the eow-procuets in tabla 1 is positive, or disfavored if hat sum is negative. 222 The MRS in fitness An interaction is selectively neutral —having no effet on fitness. -if the sw of row-products in ible: in reno, ic. iT om Ames APT) I © Here, | have assumed that offosts on mosulily are brief so that dx = 0. When this cquation hold, the intecaction (or investment) described above moves us alony a liness isogtam. Thus, the equation holds che key i the slope of Wis isugaain, tre MRS in fitness, But before proceeding, it will be useful to recast the equation i terms of changes in consumption mse sss tha. fetlity and sorta are bot differentiable. funcfions of consumption. P= Pins) mom ms) 7 whore 4 is consumption at uge r. Turtherniare, 1 assure that the ferdity and morality effects in the table were produced by changes in consumplion. Specifically, the donor's consurzpcion oe age 20" chnged from x1 we 4 Axil), while thal of the recipient changed from a) fo wf: 4 Ant If these changes arc smal, then the fertility und morality effects are AP = AcRin) © Am Awtniz) @ where 14, = BP{, i} hc is the ronnginal effet sf comsuraplion un sucvivel, aad 1, = Fane, 51/05 the marginal offct on fertility. Substiteeing these into squation 5 and rearranging gives the MRS in titness, - hs Sd ARE pum (nlp PAY MAS = = — a ® ane) (or t+ Fifan) “his gonosslines qn. 7 of my earlier paper [15], which excluded the murginal effet of commurap- tion on fertility. 223 The long-term real rate of interest The long ten nierest es is found by setog siting MRSy @ “where is the interest rate over delay 7. This procoduro equates the MRS in uress (che left hand sd of the equation) with that in excliange (te right-hand side), aud is jusificd os folloves, The awpunent in figure 3 shows thar, in ovelusianary eclihrir, the MRS in ites ast oqual that in preferences. Turlhennare, in market equilibrivm the MRS in preferences mist eyual (hat in exchange. In studying cquation 9, we wy exumining the implications of the hypothesis that both caqilibrium ssanptions Told ue. isin my previous popor an fime preference, 1 concentrate on lntergenaritionsl investments in “which he investent benelits the Investor's daughter after cxclly one generation. By assumption, the mother id drnghicr ime ified at the same age. so that the vo reproductive values in MES: ae equal. In stationary equilibriu, te other umd smsghter will ls have equal wealth at this common ge, so that the masginal effects of consusprion on thei atic und survival ae equal as wel. Consequently, the right most fraction in equation § equals unity, sad MRS: = 2 fr, where 7 = 1/2 since fhe two individuals ace moter and dmghicr), and equals Ihe penscation length, 1’, Equation § becomes 26” = #7 or i=(m%T~p a0 “Le selevani ee af populaian grow is ROL the COAT 0B, bUT SOI S07] Of average Fale ver ce cent evolntionary bisrory. Since avalufionry changes are ususily slow, the List couple of centuries of ripia growth sve probably Lad no large offcet. Prior 10 that, mut om average have been near zero. Thus, cyustion 10 suggests that = {In 23/4. The generation time Tis usually a Tile less 8 han 30 years in buman populations. For example, 7 28.9 in the 1906 popularion of Laisan [11]. “Thus, i 54 0, selection shout favor longterm Interest rates that averuge {11 2)/28.9 0.024 por year, in ceasonable agreement with nhiereaiun These resulls are ideatical to those. of my carlicr puper an tims preference 115, Eqn. 12], aud extend those Tusuls rhe more general context In which selection sats via fertility as well as morally. 2.3 Diminishing marginal returns 0 consumption Tne inirouce the standard assumptions of economic smalyis: thos camurnplion helps ia some sense aud that cach successive mil of consumption helps fess than the List, ba the presen context, this will ruean both that axe) and {x} cach increase with sonsumption, and also that magia efticrs doclinc us comsimplan increases. Although thesa assumptions ws uaremrkshle: in cconbmics, hey way seem problematic bere. Eating too much eum he bas for yuu, 2ud animals on restricted dicts bficn seein wa live longec than these with uncestricred secess 10 food 17, See. 103.15. Yel this is no real cause for skepticism: Food i Just ori of nuany consumer caods, and wealthy people do ive Tanger hae poor ones To capac the diminishing mening? effet of consuroption, 1 will assume that ig) = wipe Plea) = Isic’ bone < re + 1, urd allention sc be resteieted 1 to parimeter values such hat 1 says whi he incerval 0.1). Hove mi*iz and Pa an, respectively. the fertlicy and survival probability of + “stumdard” individu] of age x -one who cousumss a single unit of resource. To justify this particular farmulition, appeal o the data in figure 4. ere, the vertical ux mesmsures the variation of age-specitic futility across popelations, and the ori zontal axis measures wean age-specific fifty. The yraph shows that fertility is most variable at nge clues. where fertility 3s igh. At least sowie of this varifion mus reflect variation in consumption, “Thus, ic is sensible to build a model in whith Ihe effect of CONSUMPLION is ZTeAtest on age: chases with ligh fertility Marginal erfifity om survival become me = Emin) an FN Fre) uy x aml the MRS in fess is foes fan {1 Arse (ui gpa {ye 1 i 13 asi = (5 JZ ye A od ier 4 = cxf: + 3) mensuros the impariance of noegiial feds relative to marginal survival. ne epost hs ize HRSA del y 0 & 0 Std. Dev, 20 $ 10 : i wls ; i — 0 2 an 0 A Mean Figure 4: Mean and Stundund Deviation of Age-specific Feat Basel on the following sets af fenty deta: 106 Taiwea [11], Standard Nameal Fereilty [4], 1973 Libsu. and 190 cena Uh [6] 3 Uncertainty about recipients “Thus far, | have assumed that the recipient is known with certainty at the time the imvesiment is made, No alfowance kas yet been nade for the possibility that the henefil may eventually go 10 someone other than the intended recipient. As in my previous paper on time preference, T sll fncarporale uncertainty by assuming that when the boncfit amives, if will he allocated among potential recipients {inclutling the donor herself} so as to maximize its discounted valuz w the deomor. As fefore, | mule out the possibility of dimiribiting the benefit among several recipients. “Le developmen helow differs from thal af my previous paper in two ways. First, it allkws the otorsction t affect fertility as well is sursival. Second, iL will incorporate diminishing wrginal rerms to consumplion 31 Model We begin as before, with txble |. The difference is that, ander vncartainty it is uot the row-suc) itself hat must equal zeso, but the expected value of this sum. 1 assume changes in fertility ind survival arc cased hy changes in consamption, ss discussed above in section 2.2.2. In addition. | use the modet of diminishing purging retums defined above in section 2.3, Lhus, equations 6-7 and 11-12 sllow equation 5 to be 1é cxprossed 15 0 Anand! OP ft + Ae Bn 4 0) a) where # denates the expectation. 1n taking this expectatian, T define v2 4 when there is no recipient at ul. 0 The IRS in fitness is obtained by rearronging this expression Io whiain oa DE oy MS = = FZ) or Flan {1 PERN (0 {x ran {1 PN fd - rela rns) Lam) ws and yo offn 2) measures the relative importuncs of mains! fertility. Ln wht Follow, Twill abe <5 a2 50 tc the final term in 7 cisappeam. Ths eects tention 1 the MRS at points along th. 45° Jn in fur 1. Tn inteigenecational transfers then: is good rouson far inferead in these selues. At stationary equilibrium, the consumption of an in- dividual at age 20 saust equal that of her uaghter ane generation hence. Thus, intengonrtiansl fovestments are governed by the MRS In prossrences along the 15° line, wich must also equal the MRS in exchiage sud the minginal productivity ul inecgenesational investmeut.! These quanlitics would all he predicued from the MRS in fitness ulong the 45° line. Tor Iransfers over shorter inter- vals. there is fess reuson for concen with (ie MRS along the 45° linc, For these cases, the present approach wil ell only pact of the story. 3.1.1 The evolutionary discount function “Lio facilitate presentation of mamerical results, | define an evolutionary discouns funczion A, which salislies ig mel i” For example, when A 3x a constant. fomie benefits are discowntor exponentially a @ constant rate. can accomodte nearly any form af discounting, and is closely related fo the morginal rule ul ime prefirence (VIRTP}: the average value of 3 over any ags-inierval predicts the MRTP aver that {ater [15, Eqn. 15]. enable from age-specili ferslity aud survival cota sing the mds scribed by Rogees [1], 3.1.2 Demographic statistics Lgcaly, A shaukl be cximated using demographic tistics that rofl some son. af Sangre average of human demographic history. This, vl vous, is impossible. 1 have instead red om demogmiphic stil fom modern “nator Fri” popubions, whose vita vate are toggle 10 resemble those of pre-indusriz] populations. 1 would be nawise, however, © take any single: den popuation a the examplas of ou kaw sncesiers, We donot koa Whether prehistoric Immim demography was mare similar to hat of 19th cearary ‘iwan, or that of 19th century Utah, Lo nar just two possinilitics, Nonetheless, it. scuns likely that species-vide mean demographic Fee 113, p17 aon 115, imine 12] A dtamit-ferility populatin is on in which birth-control is citar absent. or else iy applieal ladegerdeatly of the amin of owns xo eben, To El For: prc, women fou os Bh sR 0 ics RS, Bh ot wit ahi age ny sz 1. u prunes have for & very long time fen within the rauge spanned by modern natural-Fertilicy populations. Tu my previous pape, | estimated using demographic statistics from a wile variety of natural. fertiity populations, md found dial this. variation bad fit cffect om Ue answer. Con sequently, T will restrict attention hese to a single sel of derogeaphic statistics. | uso Fertility and patesnity dita of 101k century Utah [6] and the Model West life table with morality Jewel 12 [3, AT]. This mortality Lovet implics that tho expectation of life at bist ¢ is appraisal 45 yeas. 32 Results Before presenting now resslts, T summicize some ole oncs. Figure 5 shows an evolutionary dis count function from my sarlier paper on time preference. Tn the figuce, “age at investment” refecs 10 the age st which s cision is made between an immeditc and v delcyed benefit, Ages beyond The age al investnient ace “futuce ages." Thus, the Tine warked by open circios shows the disccunt function pertaining Wo some: insesunent tat caight be imdertakon by newhors infants, whores the Tine marked by Stars pectin 10 investments by young, duit. To wndorstanel wha hese curves mons, consider a hypothetical 20-year old wom who ha hen offeced soma survival bosfil thal will sot arrive ual she is AD. Since: she is female and is ow of ago 20, he starred cusve in the upper panel af figure S upplies. [indicates that the average discouat sates wiehin the four S-year intervals spanning ages 20-40 ure 0.059, 0.050, 0.012, and 0.007 reopucively. The average of these is 0.032, and this naplies® that the futuro bunciiL should be discounted ay a fuetor of exp. 28 (4132) — 6.528. the 20-yeur old, therefore, should value this deluyed benefit at only abot huif of ifs nominal valle. 1a general, orc upplics u MRTP hat is an average of A over the relevant interval. The figure illustrates the major conclusions of (he previons analysis: Jy the lang run, A converges (© a valus of ahaul 29%, very close to the valus predicted by the ‘heuristic argument exding w cupuation 10. This lent support to my conclusion regarciug the —— « “The curves for different uges of investaent lic ucarly atop ane anodier. Thus, X is well appronimiated by a function of on pegument: Aly) 5 Ay). « “I12c evolutionary discount is much higher among young adults than among their cldrs. This predicts higher marginal aos of me preference among young achulls, a prediction with which we con all identify. However. igure 5 doscribes un analysis on suretvd wics ruther thn consumption axes. The cvplutionary discount function there refers, in elher words. o 8 wade-off between he survival (aot the consuroption) oF donor and ceclpient. “Lhe methods iniricluced here allow wp wualysis on omsurption anes, wish varying levels of portance accorded to marginal foriiity aod macginal survival, "FT avorugo of A previ 9, the MTR. Thin @i60663 i cq 106 112, va equation | Srplics thal the fain benctirs discount by a cor 0 =" Whe 7 = 20s he ine ag. Ih - Females Lo Fuge al ow ntmone ® a 23 Ta 004 Pa Tn oz > PamL 00 oJ \Y TT 1 ¢ 10 20 30 40 0 6 0 50 9 100 NP or Mater 0.06- | A a0 1 so wnt % _ [2] 1 x — Hong gp 0.00 I ad spit yy O10 20 XN 40 50 60 TO 80 90 100 p. fume age ign : Fcionary Discount ¥unction ie, 1 is We average evolutionary dicount rite withia 3 Svo-yesr age interval. “Age al investment” refers to the age al which a Jecision is made herwoon un immeaius sud @ delayed boven. “Fuawe ge” 3. refs w ages heynnd fie age a invesgient, The dotked Tioes show the rate of interest predicied by eaqustinn Hi, where the gensrution luue is Ty = 27.98 for fomales end T, 30.45 for males. ned on ale a ma, oie of 1 cntury Cth Mortons 61, ad an th Mids Wet Le ble normality level 12,8 — 47.5 for Females and 44.5 for malas). 3 0s © Bont ry Gay “ ii » oa Bt, Grr TY fi [IR ” 001- Vo = prea) Ty a & = y Vi pga ts om 0.00 LW 4 TA a QO I 200 30 4p 50 60 70 80 9h 100 +. Mulure age _ Maes 006 A os "4 5 ma, "3 n iis be Be BE, ou2 I. NE REGED oo : ey | EEE EEE EEE v, future age. Figure 6: bsvolutionary Discount Function Afr.) is the avers ge ovolnriomey discount rele within five-year age ixtsrval. All curves sees lo 20 year whi investors. “Future age," y, veles w ages beyond the age at investment. The dotted lines shaw the rate of | “oferest prodicred by aquatinn 1, where tre generation time is Ty + 27.38 for femneles and Ti — 30.45 for ules Rascd on male and female festility of #th century Utsh Mormons [6]. aod ou te Model West Jife table (munity level 12, cf 475 fur fernales aad 44.5 for males). 1 The sesult of this amalysis is shown in figure 6, slang with the age-20 curve from figure 5. TU shove tial « “Lie long-term tondency is word & rie of roughly 2% i all cases, Thus, conclusions axial he interest ate are unaffected by the difference betsseen these models. When comurnption affects survival (Le. when = 1, the curve diffs lite trom that of che. earlier analysis. « When consumption steers fertility. the discount function peaks in the Lite thirties and curly Forties, Cun nct sure hat to make. of this. Perhaps: « young: people are prone to risk their Lvs in rotum far inmediste geatificadon (fos driving, Sky diving. high aime rues). bul middle aged people are more prone to tke risks affecting ferilic. References 11) Elizabth A. Crshdan. Natur ferilty, bith spacing, and the “first domapraphic iransition”. American Anileupologisi. 53650. 633, Sept. 1985. 12) Brisn Charlesworth. Esulufion in Aye-Structired Poprarions, Cambridge Universiey Press. Cambridge, England, 1980, 131 Ausley T. Conte and Poul Demeny. Regional Madel /ife Tibles and Stable Populations. Academic Press, New York, 2nd uiiion, 1983. 4] Ansley T. Cole and T. J. Trussell, Modo! fetility schedules: Variations ie the age structure of childbearing jt humm populations. Population fader, 402): 185-258, April 1974. 15] Tames F. Crows and Moto Kimura, An Tamodvesicn to Population Genesics Theory. Hinper and Kove, New York, 1970. 16 Mahjoub A, E}redy ind Lec 1. Beun, Differential paternity in Libya. Jovrnal of Wiosacial Science, 19i4):395-403, Oct. 1987. 17] Caleb E. Finch, Fomgevity, Senescence. and the Genonte. Univenity of Chicuga Press, Chicago, 19%. (81 Ronald A. Fisher. The Gensticus Theory of Sara Selection. Diver, New York, 20d edition, 1958 19 William D. Hamilton. ‘Ihe genetical ovalufion af social behavior, 1. Joiraal of Theorerical Biology, F116, July 1564. 15 1101 Willian D. Neenilton. The aenetical evolution of social hehavior, 11. Joureat of Theoretical Biology, 7(1):17=52, Tuly 1964 [11] Willicen D. Uamilton. “The moulging of senacence: by nota selection. Joins of Zheores ical Mialogy, 120151245, Sept. 1966. 112] Ingomar Hasson snd Chiles Stuart. Malthusian selection of preferences, dmerican Fo namic Review, 30:529-544., 1990, [131 Jock Hirshleifer. Tovesdnent, Insereas, aud Capiiaf, Prentioo-Hll, Tinglewocd Cliffs, NJ 1970. [14] Alan R. Rogers. Wik ineqopause? Evolutionary Feology. T(4)A06-420), July 1993. 115] Alu R. Rogers, Folutian of time preference by naturel selection, The American Feonomic Review, §4(3):460- 451. June 1994. @nsightspod Brexit Statistics Data Retrieved: 23" June, 2016 Data Source: Twitter Fram: 12 AM CEST TO: 11 PM CEST Total No of Tweets: 302,130 No of Tweets with Positive Sentiment: 157,075 Na of Tweets with Negative Sentiment: 93,305 No of Tweets with Neutral Sentiment: 51,750 @ 17.12% 30.88% 4 Brexit nea Nera ose user Tweet Created At Locatio No of Sentiment n times retweeted Digestion Markets in limbo ahead of Brexit vote: 23 Jun 2016, In your © | negative htlps:f/Loo/UFJGBINVp Hocon discs keynes 00:33 CCST Mind OriginBuilde RT @DutchDL: TOMORROW=BREXIT pls !!> make 23Jun 2016, London positive P history & hopefully the Netherland wil follow 89 00.39 - CFST @EDLLONDON @Finnishd| @EDLIE} cristiano_ro RT @manujosophsan The finest Breail was in 1947 23 Jn 2016, Wurrbai positive sh 00:39 CEST india Leighlackse RT @Future_of_West: The Military "experts" who 23 Jun 2016, negative nwo want britain to rerain In the EL were the same 0039 - csi “experts” who wanted us to invade iraq. MBrexi€. BianchiGius RT @Soppressatira: #Brexit: AuRischio enorme per 23 Jun 2016. storia positive hin familie kavorody. Dislacars in Inc & Cina 0039-CFST flr fabbriche, invece, A” estremamente sicuro. 3€; Italizhc diovale Timesoflsra UK polticans make final appea's ahead of Erexicvote | 23 Ion 201, Jerusale positive o https //L.cofLLEWR INI D039 CLS m, Israel aliiduncan Brerain of Bereave? Vote srart Britons] 23 Jun2016, Welling! negative #EUreferendum #¥Remain $UKreferendum #Brexit 00:39 - CEST on, New Fesland Jan 5 B45 AT @Tren Farester: VOTE | FAVF Hirexit 230m 016, Frgand 1 positive 9 htlps:f/LoofldikPiOkye 00:39 CCST Wopustoll @Otkudia Ail jose Ais? SRLAL bro, od dors ne 23 kan 2016, renin © | negative a sovorim ukie englasid 00:30 CEST nf vel Booker * fanrosss RT @Dwalingan: Irn Dutch and | endorse Meraxit 25 1un 2016, 257 | positiva because we can be united only In freedor, 0038-5 sovereignty and rule of law. #vatel save tps. {13 failedevoluti Trl; Breit be 141, T+135 Tt Tells THT, Telos 23 Jun 2016, © | neutral on 7 ne ik Ai, i J li 0039 cost Tull TET rtp f.cofM Kinga JchilbeT RT @avelinatinance: GBP/USD remains near Smonth 23 Jun 2016, Argentin 1 | negative high ahead of Breit referendum: 0039S a https: ft. co/ uufOUBUH Ta RT @stareogur: Hoa! Gallagher steps into Brat 230un 2016, Cy of posting delbate: | ke the fact that it sounds ike a cereal” 00.39-CFST Dsaka itp: co/ DGD 70x https: cose, TvinginHon RT @AMTrurpaPRCS: 1d ike 2 dedicals (hs weal 2 23 Jun 2016, United 11 [posite UK former lovely cultures that will only B found betwean 00:39 CEST Kingda, the pages of a book. dérexil hilpsit | m Tack Terrorists for deportation June 234, 2016, BREXI | 23 Jun 2016, Manhat | negative https:/it. co/jtHoI0ACKK 00:39 - CEST _ tan, NY Ts elukepe _ #Brexit https J7t.co/qtIKmiBW ah 230un 2006, Earth negative my 0039 CPST (tax purpose Toarwended Race of the Day. Brexit itps://t.co/kn ImenTron 25100 2016, © poste or https ff oo/LYHIBVnhoh 0039 CLSI adechantera RI @MVAlekseley: Le Laux de participation record de 23 Jun 2016, Paris / 4 | neaative. « Ia préDsidentiale autrichienne (107%) devrait A%tre 00:30 CEST VendA battu lors du (AE TAD rendu cur le Bree | oe Gallemexico A€cafrexitiés causarkia impacto en exportacianes 93 Jun 2016, © [ negative italianas por L9 mil mad hlgs:/LcokoBEcaDFSl 00:38 COST lraderprene Cramer: Broxil fears are overblown 23 Jun 2016, Solo © | negative: us hitps:/ft.co/BTRIGQUAIL 00:30 CEST Indonesi elllerrurphl A question | really think was not given due 23 Jun 2016, Ireland © | negative: . consideration over the #Erexit campaign #oteRemain | 01:13 - CEST om hips. ff. cool Fre algaug RT @el_pais: 1a Policha de | andres impide un reparto 23 Jun 2016, 20| NA de cruasancs pars pedi el volo conlra ul Brel’ 0113 cost https:fit.co/UbMOsEnHpL JohnMGiney @IChatterley CNB ABrexi? say remain And Twa 23 Jon 2016, West negative blarmeylovin Mic! wel the uncertaingy| What thinks O1:13-CFST Chester, Julia? PA roburloplicy Meccls sin Lemon a Brexil sube o 80,83 dB%lures 23 un 2016, mexico: NA or https://t.co/28pHgmvpnp 01:13 CEST city Tnestinguire RT @londoniredd: People who vols ABrevit on the 23Jun 2016, English [oy ne bases of Inmigration are likely to be voting on alle 01.13-CEST orders risking their own jobs, pensions anda} RamEstatc RT @NcwsLandlords: UK landlords arc not concerned 23 Jun 2016, London NA aver Brest haps: jt. cofkEIRGTasg fukandlords 1:13 CEST & Fase #Brexil hllps:/fl.co/pFhLeLBH Warklewls RI @Histroepix Applicants for GIcial Mascot ol 23 Jan 2016, Fairield A nemT Brat, Chelmsford, 2016. The eventual winner was 01:13 - CEST , CT Bors Johnson. hips //tco/kNSyl law RodVark Final Brest Appeals Madea. Polls Diverzs on 23 hun 2016, na Referendumd€*s Eve hittps://t.co/cBegvidwmD via 01:13 - CEST @business maxim_bom #BrexitOrNot : Au Les Britannioues ont toujours eu 23 Jun 2016, NA bo Firpression diidire ree ADA An 0113 cust https://t. cofitvuv DiBYb RussiaConn ~~ #BREXIT https://t.co/OmSZiPLKEs 23 Jun 2016, HED ects 0113 cesT srs Voters in the UK will decide on #resit fomarrow. An 23 Jun 2016, San >| wa 4SFSU expert explains what's at stake: 0113 CEST Francisc hits: TUSFINAHKG hitps:/t cof Ertl ach FatsHesk Lying in bed and my heart rate is 75bpm all because af | 23 Jan 2016, Werseys negate Breil. Actually fel sick ol the prospect WiLL 113-51 ide, UK dsoteremain FnonCentra RT @Wirath_O1: Des 101d to Norway before thay T51un BIE, T postive Avert rected FU membership Ares #otslpave: 0113 CPST hittps:/it.co/2¥ol0XHOuq via @YouTube. thellyingme @Scouricbeast @COLRICHARDKIMP @lodicacty Lar 23 Jun 2016, of na dic suggesting the EU stops and i will Then we can work 01:13 - CEST wilh our free Luropean partners. krexil Stephene RT @RuLeskcon: Of cosa there'd bean Eade 23 Jun 2016, A mam8 deal if Brew, Geran BO (CUI head dear riffs D113 CLS! woud damags German jobs. https: 3! PazUtin RT @thejohnhastings: i anyon is wondering you a 23 Jun 2016, WA nat attend iy @edinge thaw you are helping the D1.13- CFT part of Brexit you oppose. lbw En anterior debale cun Farage, Car-eron hablé dela 25 hun 2016, Capadiza NA S€aaCosts del Crime3E(Sol] DI:13-CEST (BONE Si hay algo buena del Broil sera expubar a alla nat car) UK de ESP. Teptunconl RT @lavanguardia: ACGUA opinarka Winston 25100 2016, BED na Church sobre Drei? hitps:/t.co/GANIOR We 01.15 - CEST i: hips /1L.00/5L062PGOY GCPalSth wroxitvole hero we come... Will Istayar will 507 23 1un 2016, SW PA HA 01:13 CEST EarthBabyY RT @Wark Beech: A propos @garbage and wErexit 23 Jun 2016, Alaska WA Wagan post tanight, hans British Fain might affect fumaut? 01.13 - CFST hilps:/{LcowaTFDCKEAL Vaircgs The heme Loday b all boul disruptions Nothing 25 Jun 2006, A could be more disruptive than Breit atm 01:05 - CEST WariaEsquit AT @muyinteresante: ALQuSE es of "Brent's 23 Jun 2016, HA awa ACQUAR consecuencias tendrda? |e locontamos 0146 - CES todo aqui: rest hits. f/1.00/RBI eda hits cont mortalfol BrexitO. Taxit¥Fst 23102016, Rrackly NA 0145 COST _n.Y hal mln RT @oagencye: Area Soros and CAT 28 In 2016, FAIL TWA 01:16 - CEST 4ANTA" 1A PRT) Ey Britain Doesnt Need the EU to Trade un 2006, hunckers Postne Racking MIF Hirai ors) eave: ADACAebate 01.46 -CFST Datiom #cUreferendum hitps:/f1.co/DXCYRAVPS Engeses #1023 vindepandanceDay Brat VOTE LEAVE 3100 2016, positive 0146 -€L51 Hartyanwel If that vote is tomorrow Ir voting out coz 23 Jun 2016, [ [3 Funny 01:15 - CEST > 3 Bare hoads crying about how were gonna die if we bres Eng Obsers RT @jeramytorsbour: The FU s not benign or 33un201€, _Lncains A er cis force. Liss aciialor and enforcer of 0146 CLT hire lending cartels” htps:/ft.co/ IW FNEVSE | Topnumtious _Cancerns aver brexit do not end at the Engish 25100 2016, [oy Channel hips 1.cof Bian 01.46 - cesT https:tcoj/KOXNAF3R38 via FT ipsiperka RT @CatoTeporacho: "Welcome to London, arc you 23 Jun 2015, 12 positive ready to convert or die?” 01:45 - CEST #atalaave Harasit htpsft.cof ThaVOYKANI Jenili RT @iarsrk: | ¢ this trend in News where leaving of 23Jun 2016, 57a positive someone or something is headlined os Resit or 0146 CLST PLIAS Breit So if leave from sumwhere am lac! aegen WarkHoloh Liz Ruiriy bares al to back Bre: Tn LE, Lwerpo posting ead itp. {1.00/OATYDOYMR @MalOnine well done. 1.46 -CFST al, Liz.you are a true Brit.believe in Britain #VOTELEAVE England GreenSamP RT @arjan_: the ones thal stand o benefil from 25 Jun 2016, Plymoul NA ie Breit are unzavoury. Racia, nationalism and fascism 1:46 - CEST benefit rom Breit toronto nia &rex.... big deall Flanel earth wil kep turnin, 23 Jan 2016, loronlo Na n #Cartoon for laughs via GToranto_nien Toronto's O1:AG- CEST The oun! hitps:fftcofulTsoubaps Goad! belkgarri AT @CNAC: UK Frexit campaign's lead narrows ahead 23 Jun 016, nA of referendum: TNS poll hitps://t.co/wTWRb2ROIF 01:46 CEST UDoorrydas RT @Wark_Beuch: A propos @garbage und #Broxil 23 ln 2016, Maine NA posts tonight, heavy British rain might affect turnout? 01:46 - CEST htps./1.ca/wdTF DekiXI stevegb007 UK WARVFTFRANS SIAM PLANS FOR FMFRGING FLL 23 Jun 2016, UK na 1 ARMY AHLAD OF BRAT VOTC 01:46 cust https:/ft.co/TuRDNzprXY via YouTube DarioAtenci @guardian has presented a summing up of 1 pointaf | 23 Jun2016, Manhat negative oA view about #Brexit vote tomorrow's. "vate to 0146 - CEST tan, NY Remain” and Why? https: col GIXYLFD and Panama ‘SamBaker RT @ijpublik: Thal ¥Brexil manifesty in Private Cyc 23 Jun 2016. 2295 | negative #VateRemain #EUref https: /t.ca/QUIfmk6G 01:46 - CEST MituRachl Today is the Day, Whois everyone geing ta vate for?? 23 Jun 2016, © | negative BREXI1 or REMAINT? Who will you vole for?? 0146 - CEST TheCuthank [hanks CIC ‘Its dead heat: Wht you wank 1o know 23 Jun 2016, ince 0 | neaative s about the Brexit vote hitps://t.co/SMVZETxSF, 02:20 - CEST George, Ehret nc lesism RT @ethicistforhire: Can't believe ts called Breit, 234m 2016, Carlisle, 39 | negative and not CUlhanasia... 02:20 CCST Lngland Tandyoduzd RI AMI rurpaPRLS: [0 ike 2 dedicale (is weal 2 23 Jan 2016, Conneel postive B former lovely cultures that will only B found between 0220 CEST icut, the pages of a book. #6rexit httpsde | usa markerstack New past: "Traders: llere's where to find some 2310 2016, positive news protection for your portfolio ahead of Brexit" 02:20 - CEST hitps.fft.co/kDANIN Gal Tarketstack New post: "How are you positioned ahead of the 23 Jn 2016, positive news Browil referendum? hllps://Leu/SLxHIYLX 02:20 CLST moshiag203 RI @alexbland: Herexi findpendence Day 23 Jun 2016, neutral 0 https: ft. co aTmnis2g 02:20 cesT Charis Led RT @Peterl Brandt: AFACTORMENBERS Going home 23 Jun 2016, Panama 7 reget ama Taright prior ta ARPT with Ightest leverage in 18 07.0 CEST mos. at 5% margin to equity and no financa€} marketstock Mes pont: “Cramer: Bros fears arc otaly 25 un 2016, 0 | negative news cverbloun” hitps:f/t.co/dZakAMALSN 02:20 cesT clairebotai AT @Spock_Capt: In the Science of Civilizations, Brexit 23 Jun 2016, neutral Is the Lurupean Uniond€ *s Reckuning, 0220 CLSt hitps:/ft.co/HXTKQIV26w #gack Hach PapasansFil It this storm isn't telling you that Ercxitls doomed 23 Jun 2016, London negative n then... wel, we are daomed. 0200. cFsT Spock Capt In the Science of Gidlzaions, Brexit Is the Furanean 23 4un 2016, Paris neutral Uniona€™s Reckoning hitps://Lco/HxTKQY2ew dgeck 02:20 CIST rach Tocobward_ RT @mikeudar: ¥otacks close lower 3s MWalStrast | 23 Jn 2016, Stamfor negate bY Eeountsdown Lo Arex vate vzw-as dc https:t.co/pTOSAVIGKK https: co/OFevRa2drd Tatlsy RT @me_understuud @PrisonPlanct saw some saying 23 un 2015, Tegatie if youre undecided on iret then vere Remain ca 0700 -CFST you guys can always have anather vote 5€} VascCormru RT @1hcinloreept: If Brilish voles chavse lo leave the 23 Jun 2016, positive nicant EU this wek, it will push the continent back toward 02:20 - CEST nationalise. https://F.cof RGAE: fedaralnews Facts Yellen says no special meetings scheduled over 23 Jun 2016, negative 24 Brexil k¥ellen #BresiL... hulps://L.co/N718bknyod 02:20 CLST Proporiybun Hoar what @Vicldeparl hi, Lo say dbout the Breall 23 kan 2016, 500, poste asa referendum check out the ink 02:20 CEST Colin https £7t.00/XVKOWUSEA | st telsour ne, Vic duchessofi tomorrow i the day when they decida if they forexit | 23 Jn 2016, Bahama neutral sser 0220 costs v_ronuae RT @DerarCurrency: In lwo brio], porspicacious. 23 Jun 2016, Fa | neutral paragraphs, @ProfSteveKeen nails the reasan to 0220 cesT arent, tps. 11.00 3RIFDOT https f/t.c3€ EL Rrexit Rrext Brexit, ich RACY immer nur #firexit. Air 23Jun 2016, Gerean © | positive doch czal in welche under die [UGHIder fleien. 0220 COST y evotel ewe Tarketstack New post: "Markets caught in limbo ahead of Braxit 23 Jn 2016, hegative news vole hilpsiffLcofeSGlnCaihe ven cust DS _Investoo Be sure ta check out tonight's Market | orecast hy 23 un 2016, USA positive 5 Blake Young our resident dforex expert @investools 02:37 - CEST Ere htpsft.cofutiiehi 1 wmiddelkoo RT @adamilent: Good chart fram Morgan Stanley 23JunJ016, markets. positive. J showing surge of populist parties in Lurope. #Brexil 02:37 COST will Boost them further. FEUraf hHTpE/fS€ | geapolt energy Hope _for_s RT @FactDalour: Wiel either be Euratrash orloncly 23 Jn 2016, Knowl negate nity Bri 2mora & the fun bits, nobads has single 0237 CEST THT solitary clue which is lesser evil #B5€} Leeds,E ngland Drools RT @ChariesP Hoffman: Okay, rant aver. Returnta 23 1un 2016, neutral your regularly scheduled freakoul abou Lhe Brexil 02:37 LST referencum, Totestewart RT @louteasdale: Watch @bilejdporier tonight on 23 Jun 2016, Insagra negative i eset Llling about Abrexi Avoleremain channel 0237 -CLS| m= AacspmX Kateste wart yudhaueen Inggris Gelar Referendum Breit lar ni. 23n2016, San neutral Diperkirakan 46,5 juta orang berhak ar-bil 0237 CEST Francisc bagian dalam... eps cof TDODS a Sparkyathlh AT @CECHews: Ic 3 dead heat Whatyou wankto | 23 Jn 2016, Swift 2 | negative era know abou the Breil wale hllps ffl cofvs1GendLe 0237 CLST Current, https:/ft.co/N2ipb2dde Saskate hewan Love Catfor | know everyone i joking about the brexit 23m 2016, Catford, © neutral d Unanderstorm bul has anyon looked ouside 0237 ast ste recent... Stormhatls RT @sturyAlex: Selina Scotts case for RBraxit after 25 Jun 2016, negative 4 Sheila llancack’s case fo #Remain s ke eating the 02.37 CEST best steak and then cating the pac SendraZuce A slush fund paying off countrics to ry and stop a Udal 23 Jun 2015, [poste aral vise Merkel. Wire bie calling you Canute 02:37 -cFsT Blips: cofCeRHL4PAp Alcan: dBrexil INVUQT RT @TheRebelTV. Is 8Furope dying? |< ldentitarian’ 23 Jun 2016, Canada 25 | negative movement the cure? @Lauren Southern 0237 ces hitps:/f1.caOKN KIDsels Hicot hrexic hllps:/fLcofi€} micaoperld RI @jpubli: thal Meet maniesto in Privale Lye 23 Jan 2016, Logland 2323 | negative 1 #oteRemain SEref hitps:/t co/QUIFASS 02:37. CEST Grez_5ith RT @top_The EU: freedom to remove all EU fishing 23 Jun 2046, 77 | positive quotas, revoke the CI & rebuild Brita orcs 0237 cesT thriving fishing industry wsreait hipsiie | Hammersl0 RI @Leawl oficial: @UicabelbHurley fsvoling 23 kun 2016, 3° 380 | positive Wee LEAVE tomorrow are you? WErexit ¥oteleave HEUral 0237. CEST fantastic HUlps 11 afaT2 MYL. Harlow Spent Brass 8 Tun BIE, United poste #LetsGol 0237 CEST States, UREN: Sindependencebay for @Uritain? Wiscons hitps:tco/OIDCIKC wd via @YouTube in Toneyspinn RT @Nin_Matharu: UK EU Referendum 2016 Fey I= 23 Jun 2016, BIRKIN neutral ar Voting Hirst hp. 1. cojslsTwdT 30 037 CPST GHAM, uk Piedronlia RT @RPLW: PLCASL RIT Tn 006, Albers, poste ntl Juncker confirms therall be NO reform if westayin 0237. CEST TX Ue LU Bp cofyqakYbiaGH We absolutely MUST #Brexit #o3€ | Wana RT @liputantdotzar-: Inggriz Gelar Referendum Tun 005, Tangara Twn rest a ni bits f.cofl Ic DISRAVIT 037 -CFST nz. https:/ft.co/GeesrLGD Inconesi a syzcompany Why the United Kingdom leaving the EU would 23 Jun 2016, © | negative inc infuriate the Lech industry hUpsiffLco/sworGst XP 02:37 - CLS dkenstone RI @roomdesignd: 1RAIIGRS 10 11E URITED 23 Kin 2016, Nankang 16 | nears KINGDON/ALL FUTURE GENERATIONS/REIECT GRAB 02:37 - CEST City, YOUR PREF ¥RREAIT SPREAD THIF WORD songs, @FeistyDeanne httpss€ China juncimmel RT @ingrahamanglc: Bono, Beckham & wvery other 25 hun 2016, Orlando 242 | negative man slob celeb in Britain ag #resit. Follow the §» 02:34. CEST FL globlication great for them, horrid lord€ | aos bill Vial Breit Appeals Made as Polls Diverge on 28002006, Dallash © | neutral Reterenduma€’™s Eve hitps://t.co/qiTIBIRIZE 02:34 - CEST t. Worth sec Hew York Gaterzakal 1 back BREXIT, and pleas don t forget to hang Juncker 231un 2016, Port negative [eT 0254 CEST Moresh ¥ TasonDeFurt inthe Science of Crilialions, Brot i The European 25 Jom 2016, _ Chir Tetra a Unions€™s Reckoning https: //1.cos?17061zgn 02:34 - CEST Hill, NJ pazgabsla Brexit: ReterSTncum entre la derecha neolberalyla 23 Jun 2016, Asturias negative derecha nevfuscista, ALY a lquierda? 02°54 - CLS1 https://t.co/pSdrtusaks KolbSchmitt RT @Elyseel/ rine: Choisisses 1a ibe rtAG et non la 23 Jun 2016, 33 | postive oumission UF | 02.34 CPST Brest lave hitps:/ jt. cofnaspSSFRD abcews AT @naoriwoodey:.STurnbullislcolm: “ft would 23.4un 2016, Australi 3 | positive be a very big shock, no duubl wboul il, if Britain voles 02:34 CLST a 10 leave tha EU. abcneus sbrexit #3€ FECEaction RT @naoriwoodiey: Turmbullislcolm: "Tt would 23 Jun 201, Austral posting 5 be very bi shod, na doubt about it, f Brinvotes 02.54 -CFST to leave the EU. &abenews wbrexit #5€ parishats STEPHEN GLOVER: Why I'm voting Breit because it 23 Jun 2016, Athens neutral could RESCUE the FU, not destroy it 02:34 CPST Nicosia https: /ft.co/LKTiPLyrO Ganellv In the Science of Civilizations, Braxit = the European 23 Jun 2016, neutral Unlond€™s Reckoning hips fit ofsteLC3a7et a 02.54 - CEST @wiRED chntypcwr Inggris Gelar Referendum 'Brexit’ Hari Ini: 23)un 2016. AccT: neutral ™ Diperkirakan 45,5 juta orang berhak a-bil D:34-CFST 654338 bagian dalam... hips://LcofLL5E3ypLrd 7,107.4 2888 Fodiranman RT @independent: Final EU referendum poll shows 23 Jn 2016, negative Alu Rerain with significant lead https //t.cofv72i EEe7Pd 0234 - CSI © loka RT @elizberbholds: Is this crazy corm in london 23 Jn 2016, {anon negative some kind of sign of impending door? #8rexit 02:34 - CEST Trump ipocalupse. Vacstin What's more likely. UK Pafiament vaiing to remove 23 Jun 2016, Liane, negative erployrenl rights, Or LU amending regulation, su 02:34 CLST Wales, forcing UK to remove rights? Wbrexic uk Er AT @laorenzaen La decifin de Poavidbeckham 23 Jn 2016, Werica reual sobre l #BrexdL MinionLuropes BGNOUNAO KLNG 02:08 CLSI Dik, https:f/t.co/RTDmsG023e “EnZ007 RT @Lovisehensch: Garman CEL na aris afer we | 23 Im 2016, eastern 53 [ paste Evoraieave. Die Welt newspaper endarses leaus for 02.34 -CFST block, the UK. Vorspriing durch #Brexit https: /a€] sarisniol0 Inger Gelar Referendum Bret’ Hari ni: Jn 2006, World © [neutral Diperkiakan 46,5 uta org barhak abil 02:34 - CEST bagian dalam... hilps://Lco/jUNkgelvm Iegentt RI @zo0witchpraject; Gods angry al potential Sbrexit, | 23 Jun 2016, 4 | negative make feelings known with violent #thunder stormin 02:34 - CEST Landon: Appease pads, vote remain Keller7on Something Strange Fmerges When Looking iehind 23 Jun 2016, © | neural The "Brexit” Bookie Odds Zero Hedge 02:34 CEST https://t.co/pDAIDKOVAE francreynel RT @inthemoodfortw: Ouinon, graffiti sur la route, 23Jun2016, Paris neutral Paris, 1645 AE Paul Ale asy Hirexie 054 cFsT hilps:/{L.co/3VVIz0ADE Ublondegra RT @Farbus: Poll: 80% of Americans Lhink Britain: 23 Jun 2016, 32.7864 positive 4 should leave the EU https://t.co/EPNkiSEcSh 02:35. CEST 56.- tps f/Loof 3rgaVEvsKkD 984TH H FyliTradie Thats that ston your stupidness bout brext Thunder 23 Jun 2016, © reutral & lightning #otepraper dGodeTakingselfies 0035 CFT buttanholel AT @eaveFUOficil: total ave tomorrow farour 23 Jun 2016, 357 | positive independence! 02:35 CCST Lure @Broxil hulp ffl cofupHsaXVesd. Kenhaley2 In event of Srexit UK is holding all cards & LU 23 Jun 2016, neutral powerless THE EU CANNOT START TRADEWARTHE 02:35 - CEST FU CANNOT PUNISI| UK hits: co [ON TORS cactuseriss AT @marics. ba, WL, LiL L- 23106, greece negative der Teislal Sion (ATLL. 0 Tdi itis ish 02:55 COST Athens Tele iy el Til; brennan hrc Agroxil WTSI 2015 https://t.co/3ASzNZsucC Sccordingta it they brexit we vil be forced to [more t2 pick p23 Jn 2016, negative pun the shack! ¥USAmerica @nyhre 02.55 cesT Audor?8) RT @Mrforestroan: To our uk friends across the 23 Jn 2016, Ilactings positive pond serosit and take your country back 02:35 cesT WiketheSpik RT @scodyl81: Voting te remain is effectively treason 23 Jun 2016. USA positive . fresit Notelasue hieps/jt.co/KGKrMxmiZG 02:35 cesT visorbon AT @busines:: This sock trader who made 63007 in 23 Jun 2016, _Brecken eur weda Chin ft warried about Brexit 02% CST ride, CO ttps:t. cof kATgnWEE2 hitos:/jt cof AUD Zwikta SEt_RotkGE #oteLeave #rexit tips i/t.co/nyCRNES Sw Z50un 2006, 50960 postive 035-CFT aA N 00893 Stok £ Ticardoigus RT @AndrevEloch: PR Stunt of the bay Tatoo Shop 25 Jun 2016, London, posite ira uffers ree Breil Lalloos (o highligh the pemnence 02:35 LSI UK of voting eave hips ft. copeidac! Depthofvil RT @CaucasianAllur: The darkness fs aking over the 23 Jun 2016, Far Far [poste ne WEE The migrants ara taking aver Furops. Slrexit 07.55 - CPST funy #oteleave dStandUpForEurope hie! CUCHTEIGH .....how many faccberg kes docs KBr. have 2510 2016, souther © | neutral T 02:35 CEST n calforni Zesty_Tinant Australia shares 1o gat opening ITE from Brat polls 23 Jun 2016, aw neutral A tps. //1.00/Kcl CH nance 02.35 -CEST York, NY hips /1L cof JWICMIRXRS x Blang7l RT @V_of _Curope: Your country noeds YOU: Vote 23 kn 2015, United 24 positive Leave today to rake Britain even grater 02:35 CEST States hits. f71.co/ NXE pict] AIMINGHT RT @lnst & Studies. This guy wil be voting Remain. A 23 kin 2016, sarf 12 | negative charatan voting for charlatans. Unacceptable. #Bresdt 02:35 CEST london hitpst. cof ImSIDGHAUR Newsdeskid RT @NewsceskBIZ: Vote remain and wel forge 23 Jun 2016, 1 | negative ony you for 1966! German newspaper wade into breil 02:55 -€LS1 debate Soccerway hrpsijt.cojlUuoiGrplh Sdverkuraw RT @stplr: Erexit suspense total et dermik res Tun 2006, Kansas 18 [negative mike rises en garde A quelques heures du 02.35 - CPST AOFRDreadum https:fjt.co/TZMOgmI ¢AFP hitps.{ft.cafy361 WWIG198T eft Wednesday, June 22nd, 2016 Braxit: Remain, 2342016, GUASRI © | negative House Si In, lal Bingo, Malchd€ 0235 CAST CO hitps:/ft.cof3Is5hhO=DS ENE ory Josetey RT @nissingfaktor: Brext. Grexit. Departugal 23102016, Portand a0s1 | positive Halcave. Fruckoff. Czechout. Oustria. Finish. 02:35 CEST, OR Slauakout. | arervia. Byegium. Shappyara RT @Vixan_chick: et taday be Pricain's Independence 23 Jun 2016, positive n Ua, Vole drut Beller Greal Sritan rather than he 02:55 CLST 25th State of Europe https:/t.¢! SonDisH Sleepless in tha City Lats Traders Bet Bilions on Bret 231un 2016, Venus © [negative Result. Dloomberz hitas ft.co/Vetnaobris 02.55 - CEST ArchivePert RT @refugee archive, Very pleased fo have > 2342016, london, 2 | positive orm stimulating day @UEL Library Encl wi great 02:55 CEST England rancrabls Hhrexic AerentPastsSharedFutures. huge} Angelis) RI @bare_digitl In Uhe Science of Civilications, ext 23 Jan 2016, Lama, 7 | neutral kl Is the Eurapean Uniona€”s Reckoning 0235 CEST FL Hitps:/11.00/SLDALGWOY tech tired itps:(Jt.5¢ Nacemsiddi RT @V of Furope: faraged€ 7s final rallying cal 23 4un 2016, 19 | neutral quis SESE" us versus the Establishment soand vote 02:35 - CEST for Britain hitps:f}t.cofl FRgPropE Tynannivan RT @theghisshient: | ust want a know how the 731n2016, Bay negative 56 rei will impact gelling Duelor Who back on 023 GIST Area, CA @netiix. NacemSiddl RT @Y_or_Eurape: Your country needs YOU: Vote | 23 Jn 201€, posite quisd Leave Luday Lu make Brin even greater 02:05 - CLS https:f/t. co/NXFiXxrtl Tavierp RT @ajay_mahil: This i God warring you shouts 23 Jun OLE, hegtve rest 0235 crt helen fb lafta peas an Twitter reckan the storm is God 231m 2016, landon negative supporting Brasil, o alternately God supporting 0255 cst resin. a3008 RT @AMTrompAPRES 1d like 1 dedicata this wast? 23 Jn 2016, 727 | positive former lovely cultures that wil only b found between 02:55 - CLS I the pages of a book. #Brexit https3€ | ho RT @danielaylion: Ojo a Ia5 portadas dz 13 prensa 23 Jn 2016, Ahora] 76 | postive britinica de mai¥ana. Fito es posiconarse y no lo de. 07.35 - CPST Madrid EspaAza. #Broxit #BroxitOrNot hitps:/3€ | Bordurkeror RT @_of_Curupe: Your country nov YOU: Vole 23 Jun 2016, 24 positive @ Leave today to make Britain even greater 02:35 - CEST https. {ft.cafNXFjbbdrtl Alishuomar @CharieyyRachael 'd tel her to vate for Trurop. But 23 Jun 2016, 0 | negative she's a useless brit. So she can vale for Brexil. 02:35 CCST Thasball RI @brenchrorl rump: $SRLK1 VOIL 2 Jan 2016, 70 | pote WAKE UX GREAT AGAIN 02:35. cesT IME 10) LEAVE EU #MakeEuropeGrasthgain TINS 15 OUR FREFDOM #MakomricaGreatagain hts€] peterson al AT @Amblohnfolton: fitain ic a strongestand 23 Jun J01€, 78 | positive ” mast ievportant European aly & @Brexil would 025-5) promt the revitalization of western security. Tiey_meakin RT @markets: Found Reaches Highest Level of 3016 23 ln 206, London reutral an Fe of UK. Brest Voting, 0736 CPST https:f{1t.co/goDSmBZoWS https://t.co/IHUxUzSphi andrewnap RT @FrenchForTrump: #8ROXIT OTC 23 Jun 2016, Occupic 372 | positive wi MAKE UX GREAT AGAIN 0236. CEST d 114L 1 LLAVL LU Horida #MakeEuropeGreathgain TIS 15 OUR [REEDOM #MakeAmericaGreathgain hESC} ConsurerFY ¢Remainers US “partners” | The fFeceraRessrve is 23 Jn 2016, US, 0 | negative I Pushing [he SLeunory lo deel he Verge of Hal 02:36 CLST Africa, Implasiona€e https://t.co/xFhROHvpal #Brexit EU Eekoll WkDxicoy ol aCceBrexitate a columns de 25100 2016, © [neutral @anCLasti hitps:ff.co/OlbrmeAWehE 0256 CEST roulovesluc. AT @laredWyanc: BRITISH MUSIMS POI 166% 5ay 23 Jn 2016, Indians 235 | negative ¥ they wouldn't warm of a terrorist attack 02:36 CEST #Brexil ALUrT BT rumpSpuech #NoSillNvBreak hitps:aE KiartivichsC RT @PetroleumEcon: Breit: The UK will probably vate | 23 Jun 2016, negative a stay, bul oil Parkes fear the potential fallout 0206 CLs (FREE) https: co/tMGPzaTUos hitde Fossfrenstt Jesus lads, this ominous pre referendur thunder 25 Jun 2016, London | negative starm is, well... ominous Hiei thunder 02.36 - CST lady Sapph RT @peacelavedixie. Ifyou are irish, | dan'tknow 23 Jun 2016, 2 | neutral o how you can watch this and oven comsider voting 02:36 CCST rerain. foresit @oteleave hitps:fjt 3c! Bigdatahires Very interesting! Inferences drawn from 31an201€, Chicago, positive “Biptiatanalylics done on Arexitis contrary to D226 -CLSI USA mainstream peda sentiment tps ff1.c0/Ccpa Wg 127 Hedgeye ~~ Cartaon of the Day: Frough Already! 233m 2016, Stamfor negative: 02:36 CEST d, Get our daily cartoon emailed for free: Connect https. //.ca/SUayxdPCOT Hirexit eat hitps:t.co/BloPiaP 12H memasauer RT @SCabrerab: FrenBClio final de campaioa para 23 Jan 2016, Venere Ta [negative a convencer al 10% de indecisos. Cameron padre sufrir | 02:36 - CEST Ia Jas consecuencias de un rexil hilps/3€] Fhunmik RI @ mou: 3€.89.355.,0. 3d — Jn 2015, GAs 136 | rege 8,68,72.8,5.78, and 18,3" 8,/8,8 02:36 CEST %h.- "h 28.04. 54.20 13,05." AUEA0A 21% 3.4 Brexit 4. — 4.6000), BuAE, 3753303, 78% TE, wr 080,00 0, a 0,13 3, Ke A. I "AN £A75,88.70 13,98, 8,583 23, AED, E70, “00,0, m0 0 iB, 88a sa, 3€) TndeCardio RT @elonimisL: Trade harriers postarext would be 23 Jun 2016, negative “aallsh', savs German business an 02.36 CEST hitps:/it.co/tddFBIby via @hlaiOnling Vima_pooh RT @WUDDLAW: The lalcst Veritas Internationall 23 Jun 2016, Puerlo {neutral https ff. cof TgS dmeriBF Horexis fauref 02:36 -CFST Rico. Toteleave RT @Australiaumwiab: On eve of Brexit vote, rval 23 Jun 2016, UK, nat positive camps race La win over undecidids 0256 CST LU hitp/{t.co/0:FetCipsdl tomorrow get out and vateleavedt | LodyConser RT @chuckdevare: loping that our British cousins. 23 Jun 2016, North 5 | postive vat across the pond declare their independence 240 years 02:36 - CEST Carolina after we declared ours. #firexit partiTsano RT @bbcmundo: ALQUAR es el Brext?: 7 preguntas 23 Jun 2016, positive clave para entender of eferendo en Reino Unido 02:36. CLST hitps:/t.co/BKB7XCE800 hitps:/ft.cojax2naVII3E Custard RT @alnell: Head of German Industry: postBrexit 25 Jan 2016, 1677 | negative trade barriers would be "yery, ery foollsh's urges 02.56 - CEST “trad: regime lo rainlain levels of Les€ PW_75 Nach der cldung, dass alle Breit Volksentscheide 25 Jun 2016, Deutsch © negative komalett folgenos sind, werden alle Meldungen und 03:13 - CEST land Warnungen au cinom grossen LOL WTF Toysimangu RT @igudapp: Should | say or should | go: British are | 23 Jun 2016, _Indonest negative mang divided on @ witter about leaving the LUI [ESE CI hitps:/t.co/RawOGEsb HEURES hips: cose | hes RT @jin_nation: 5'C3.65,373 - Tun BLE, [neutral BANE", 59.5D.740, 0 She rent 3. 01.13 CFST Si FARE 13 03.03.65, 58.53.03, 35. A788 7 Ai 68,, "8,08, 00" NERC + BL, Ch," Sh, EC 5,25,£5,63.€275,%8.72"3 —a,u8"8,i5,03 7833 48,6 ihn hts. 4f.co/NI OI O5DSy Vovayamam AT @TheFconamist: Would feign students apply to 23Jun 2016, Hang 43 | neutral alo business schools in Lhe UK afler a Broil? 0:13 COST Kong hitps:/ft.co/tnTKX34cia https: .co/SbODRER2S DISCOVERY_ AT @slesbland: #Brenxit FindependenceDay 23Jun 2016, Kuta 15 | neutral ull tps £11002 1 BwSZe, 323 -cst Lal Kerriacabi RT @AllerWestAmy: Latest Brent Poll Shows Masskie | 23 lun 2016, Lake 19 positive Swing To Leave EU: Referendum In 12 Days 03:13 CEST Charles, hitps.f1.cafySurea7 Ohl via @Barracudahlsma ITs Wickee3s RT @INTIutsu: Ifthe UK dossn't get out naw, there 23 Jun2016, Vegas, 36 | negative won'tbe another chance, as their country willbe 0:13 GIST USA overrun & ruined NBREXIT HUK hetps:/jtS€ Catcherbloc RT @Rautersbiz Asia stocks, sterling rise as Brexit 23 Jun 2016, Jamaica neutral anxiety abates htps://1.co/5¢TQSNRER] 0313 CEs TareverReag RT @AllerWestAmy: Latest Brest Poll Shaws Massie | 23 Jun 2016, Texas positive an Swing To Leave EU: Referendum In 12 Days 03:13 CEST faka. hitp.ff1.cafySureq7 bl via @Barracudahlama Gads Country ) Themi23 | Alsoremindar that Putin i [probably] sing the SVR To 23 JUn2016, geting poste Influence the arexic debate In a proLeave way. DIL3-CES| coffee wander uh Us Threepe RT @bluchand007: This will ba our finest day. 1am 23 Jn 2016, Nabrask positive © confident. threxit Mateleave ¢luchand 03.13-CFST a, USh netiesen [AMTV] BREXIT ta Collapse Furozone (WARNINGE] 23 Jun 2016, © [negative A€° NWO lps: fof 0st D26W 0:13 cLst ATIC RI @MoAnsar: Incredibly, ve heard of some pour 23 Jun 2016, 13 | negative Wuslirns considering Breit, utterly unawares it's being | 03:13 - CEST lead by the antibusiim far rightl3€ | shdulmalip RT @somdatomwiman. 1.0,+4, 30,03 75, Ad BPA = 23 Kin016, 14149) 12 | negative 5%. £3,955. 13,08, Brit 03:13 CEST 05,100. AGHA, BN EA £9,410 0,50 S118 Bt bd uh DA "370,08, 0 ER, NLR, 73757 ELA, 8E3ED4.€3, 7,40. 50 00, £020,504 20.500 4. 873.62 ".5,50.78 +a 8, 22000.05,% 80.30.13 04, 3a a 1%0 00.30.03. 3. 90 + 8.93 5€ patricerls RT @WLP_offiidl: FADE ce sor NinitADs du 20h 23 Jun 2015, 5 | neutral dz @TFL. vLorTravail #Bresit wMILPTFL 03:13 - CEST hllps:/fLcofuliLia Tn TBS507 AT @geraldcelente: Paul Craig Raberts Just Exposed 23 Jun 2016, dirty negative Ihe lerrifying Reason Why The Liles Had 1oSlop ~~ D313 CLS doon Brexit At Al Costs SingWorkiNews ita: JosephDdal RT @AllerWestAmmy: Latest Grexit Poll Shows Massiée 23 Jon 2016, Nadiso positive Swing To Leave EU: Referendum In 12 Days 03:13 CEST mn, htps:fft.cofySvrea7 On via @Rarracudahama Misbam Smarltners In the Science of Cilicalions, Brest bs the Luropear 23 Jun 2016, LISA neutral hep Uniona€™s Reckoning https cofRya2WizZly wired 03:13 - CEST hth t.ca/uwIwaDvm enc Breit could slam a group of countries nobody3€™s 23 Jun 2016, London negative alkin about hllpsft cofdDUrShLy 0330- CAST & Singapo re studios Foreignaffai The roots of the disions over Brent: Tn 006 New neutral " https. ff eafN KSI inl) D330-CFST York, NY DaNTIEI 5,588,377 WRrerita 850 8,37 2312016, Bangkok neutral 8,140.3 460i," 0330 ast 8,348,70,83.20.8,18,88, 875,73 78,00'Wd, 08 Fd Thatland 8, KER 50 0 G0 0 ed aI. HealCassay RI @1lghting aries: Today BADCHews2 has plenty 23 lun 2016, | alcon negative El about #Brenit polls but ZERO about these polls 02:30 CEST Bay hitpft.cafSAYaicU SI Australi Faliarws Belgien PW cally for LU mecling alter Bron vole 25 Jun 2016, neutral hitps:/t.co/JakPLLUXr via SPOLITICOFurope 0330. CEST FS Stocks Brexit E7D70D AO DUDTD BY DWOHD DE" 23 Jun 2016, neutral Hu DELI: AD20IHD,D, S050 DKUVARER 0330 CES #uD NEDDRfin AEUR HUSD PY hits. fft.ca/K djlarcC WanlikeFab Niafi-ana vot | eave. Vatel eave fret 2342016, Antigua positive fog 0330 CCST RepASh Tuporla ade Sisclde mex WFinanzas Brexit preocupa a a econorAa de EU: Casa 23 Jun 2016, Ciudad negative eo Blanca https. //1.co/pEScrdthile 0330-CEST de hitps:/it.cojal iT tunRd whic FazyForm Bren: <baHeute<fbs SchicksalsTag TAKr Furopa: fm 23 Jun 2016, Augsbur © [negative SILRRLICH: Hout sir men 45 Millonen ingé 0330 COST 5 hitpsi//t.coNVGIOKREN German Vv smackey678 RT @andrew ico: low supporters of Remain hape 23 Jun 2016, 2 | negative 3 far, of Broil feel by 2025 hlpsi//LeoflsRaptSYX. 03:30 CLST 4dB000 RT @lohnTirran: Those shocked by #Brexicstrenglhy 23 Jun 2016, USA [negative every European country in 193010s had a popular, 03:30 - CEST native fascist party. The Liberal urdeac] smitty_one_ Forget Project Fear. Be positive. Choose dynarism. 23Jun2016, NOVA positive euch Choose Brexith | via @telearaphnews 0330 - CLST https:f/1.co/epLOKBSMLO cnrprilppin The nonBrits guide to Brext https//tLco/VISACSZHEY 23 Jun 2016, neutral - https. ff1.00/ MOK BKRD 0330. cFsT tableaupubli For #politicsdatamonth, sophie sparkes shares tips 23 Jun 2016, United neutral < on building lve politica] tracker 03:30 COST States hitpe:/ft.co/SGUzI Bb HErest HEURst imanjeatkau #Technolagy MTech In the Science of Crilzations, 23 Jn 2016, neutral r Brexit Is the... https //1.cofwtiwsOls5 00 03:30 - LSI https:t. co/d5F3HEsDS hetos:/jt col RING TrbulationN Breigt: What Is It About? 530m BIE, Tegatie aw Paul Craig Roberts 0330 CFT It you reac the presstitute media, Braxiti€'the referendum tomorrow... https f/t.co/QBAZkEyaov WagRG RT @theordinaryman: Retueer fyousant aut of 23 JunJ016, Cheshir negative “tu 0:30 ose HBBCDebale ALUM] WoleLsawe ADL MVolchemain #InOrOut HLabour #VatzOUT htps:/t.cac FTnawama No man’s an island https i7t.co/aPRju0gaY 5 1un BLE, neutral 2 tps ff. cofuODIpELIEY 0330 CPST hoofed Dilbate i theatre. Respectful discussion is usualy 23 Jun2016, United positive worth. dkck ACUreferendum SCUrefl #Brexit 03:30 CCST Kingdy hitps:/ft.co/NWEA Ww UX m Tosconomic © £20°D7NfEY. REoyR, DUREDLDY RIETD' Hin iE, GioHh neutral su UR, DAREDADID, DRO! bret NORWOOD 0330 -CLS( 02, 2:0%0WREN By https coOlne3INgRS oippk, tps ff cafiRIEIONTY DyRtens fifiice*, noi fied fie UnaFrevms Browil: Whal Is IL About? “A Information Clearing 23 Jun 2016, german neutral nn Hause ICH htps:/{t.cofUEErIYICOV 03:47 - CEST sugustotisca AT @missingfator: Brexit. Graxit Depariugal 25 Jn 2016, Londen, posite | leave. | ruckoff, Czechout, Oustra. finish. 03.47 CEST England Slovakout, Latzrvia, Byegium. lucic_bucha To #LeaveorStay? Interesting breakdown of the 23Jun 2016. Mickour positive n rexicreferendum by @business Intelligence 03:47 CPST ne, Economist Gan lanson Victora hittps:/it.co/cPSGihCN Teblasteral _ ilps/7Lco/5GF he 5 Jun 2016, negate ack sia stacks, sterling rise a5 Brexit anvisty abates 03:47 CPST RonaldARe @laxdusiness #brexil Save yourseli and leave the EU, 23 Jun 2016, Washing. positive. mero urlosc your rights and your country and acullure, 03:47 COST lon, usa HonzoPanc Ifyou cannot sta current, plese don try to. 25102016, Long negative e https:f/t.co/mCEIQtiyt 03:47 COST Beach, cn Ug_UkCrawl Cameron vadtaced afar German oficial says Brussels | 23 Jn 2016, Craviy, negative or WILL trades with rita aller Breil: DAVID Carreron 03:47 -€LS1 Logland and... https: co/beOuAOAF Taumazhe RT @FranchrorTrump: PSREXTVOTE Tn 2006, Unked 13 | positive WAKE UK GREAT AGAIN 03.47 CPST stares TIMETO LEAVE EU iMakeFuropeGreatgain THIS IS OUR FRLLOOM #MakeAmericaGreathgain hesc| dauoad RT @slay mail This bs God warning you sbout a 23 Jun 2016, 5 | negative bresit 03:47. CEST trevordege | liked a @YouTube video https: //t.cofwd)QWnzHHw 23 Jun 2016. Collingw negative BREXIT to Collapse Furazane (WARNING) 03:47 CPST oad, Ontario, Canaca hari RT laren |< ts trend In News where leaving of 23 Jun 201, 263 | postive someone or something Is headlined as exit ar 03.47 ces Brent So f leave from sumwhera am I3c! merendon A€ceNo habrAl ningA®n tipo de rencgociaciAnats, 23 Jun 2016, neutral advert Juncker a quienes 3poyan Brexit 03:47 CPST hllps:f{Loo/bR3xBYSq vhs @AristeguiOnling ull_blomber RI @Zwepol: Nolerar all de sor propagerar mol 23 Jn 2016, Sweden” neutral sue #Brai variar vara desama som propagerar fF 03:7 CEST kraulff: frigpal. wiesteos DAY vel man hur landet iggerie! su AngloRighl RI @zerohedge: Bros: Global rigger Lvent, Fake Oul | 23 Jn 2016, SL. Louis egalve Or Something Else? hitos://t.co/eWWVICTV] 03:17 - CEST Bigrmind3 The Canservativa Case Against Brexit 23Jun 2016, Danbury © | negative hits. 1.00/ lcakpas via @F oreipnAftairs 03.47 CEST CT TRUMP NO RT @michaeljohns: The #UK is a great nation and still 23 Jun 2016, 37 | positive WILE a special relationship, Britain should be governed by 03:47 CEST British #Leave, friends. #arsc VertaCister Breit Fl dems brik nes Pips JE cofadakoNores 23 Jun 2016, Guadaln © [poste nas. its. f1.ca/adaKENSFR Braxit: Fl dilema britfinico... 03.47 -CFST fara, https: it.cofkviNZanv 2) Jalisco RonaldARo @CuruRaver #Brexil Save yourself and leave the LV, 23 Jun 2016, Washing © | positive: mera ar lose your rights and your country and aculture. 03:47 CEST ton, usa 550000 RI @JASEMARKRUI IER: Vote like you've never voted 23 Jun 2016, Notting 32 | positive bfors. & vote for LEAVE EU is 2 vote for PEOPLE 03:17 CEST hamshir POWER! Reruer! éheexit BrextOrtion hip3e; o, UK Mrs Coder RT @FareignAffairs: The raots of the divisions aver 23 Jun 2016, # | neutral Breil: hltps:/t co/MKsBIMjnU 03:47 COST JhicRarrure RI @ConooplGrp: Currency Lraders in Singapore will 23 Jun 2016, 1 | neutral : ba at their desc from 3am to await WBrasit resus 01:04 - CEST https foo fate XLV hl psiffteodt] Revlucion #Monagas PMiaturin La ntiga del bred: ACquie 25 Jn 2016, Waturin rez WON pasurAi si el Reino Unido abandons la UL? 04:04 CLS Lstado https:f/t.co/AFXyVhOBfs. Monaga . SrQISR RT @Firaberhliurley: Vota tarorrawahatever your 23 Jun 2016, 2649 | negative persuasion. I'm fer #Brexit & promise to neither gloat 04:04 - CEST nor whinge. Rut OTF: hps:sc! Sawalot AT @rmissinglaktor Br exit. Grexk. Deparugal 3 Tn 01, your gin 036 | posite Ialeave. brackolf, Covchoul, Ouslria, Hnish. 04:04 CLST joint. Siouakou, Latersia, Byegium. sce Aelaid AU Audreysl ned2know: Investors pel Brexil jillers: Local shares 23 Jun 2016, Sydney, negative poised ta open lower as investors get defensive shead | 01:01 CEST New 0.0 Nps: coirFRRVHDNP South walas Theordinary RT @heordnaryrant. We are votaleave 750m 206, GREAT postive man 04.04 CPST Rritain #CUReT loveLuropeleavelU 8Brexit Arcrain #NorOUT abou ateOLIT lps Loaf 30cMEKOI sherisel313 RI @Gricedake2974: The most stupid woman ever lo 23 lun 2016, | ree negative hold power Theresa May says many Sritons 1:04 CEST World SE"DENENTT GREATLYAE™ for Sharia Law hitps:/it.cojda€} listings RT @Reutersgic: Ai stocks, storing re 53 Brox 23 Kon 2016, Japan eutral aniery abates hipe://t.co/ST7QSRREN 04:04 CEST Slengimar His own private Braxit. Attps./c co/bALyaBOBER 25 Jun 2016, Austin, © [reutal 0808 CLSC IX Darmansyah Menkeu: Kekhawatiran Brexit |urun 23 Jun 2016, DKI © Na 0 https: cof rSukatE3n 1:04 - CEST Jakarta - Kata Lemang iroveranc RT @ianbrerr mer: Online & telephone polling in 23Jun 2016. manche 11 | negative Hester funup to the Brexit referendur, es close... 04:04 CEST ster lps fool L2kyK5UgS deborascha RI @missingfaklor: Brexit, Great. Departugal. 23 un2016, Porto 126 | positive. hn talsave. Fruckoft, Caachout. Oustria. Finish, ODA CEST Alegre Slouakou, Lirervia, yegium. ns shabs67 AT @dubsrol: rer. The UKs Donald Trump 2300m2016, somewh 1 | neal moment https /L.cofB5yYWHORUL 0404 CEST ere Jefirush RT @missingfuklor: Broxil. Grexit. Departugal. 23 Jun 2016, Arlinglo 4126 | positive Italeave. Fruckoff. Caachou. Oustra, Finish. 01:04 CEST 0, TX Slovakoul, Latervia, Byegium. Aniatoune https /fL.oo/mC2 rey bk 23 un 2016, | RANCE, [Na 1:01 -CEST_ THAIS R_de_Gerbe RT @Stop_The_EU: Don't rake Britain accountable 23Jun 2016, Weybrid 9 | negative ‘ for the failings af an FU and the &,-ura. 404 CFST ge Wirble resichtps {ft coincssraiyHw don, UK FowenBana "The message is fear, fear, fear" Peter Shore Braxit 23 Jun 2016, Washing negative dora ke i's 1875 hilps if co qdoobOCd) 404 CLS! Lan, DC hitpsft.co/ AnNOZVXpol GigiHunk RT @lantaKaReporter: British voters are taking partin 23 Jun 2016, India postive historic eferendur~ foray to decide f hey want to 04.04 - CFST stay inor leave Europe https ffa€} Gemencius? LOL Rbrexit fbrernam AErer ainVaBrext Fiferkel 23 Ian2016, Allover | negative a lunches hips /fLoofoRtirp) 116 0408 CUS! the net Rogerlordan RI @Nigel |aroge: IU time 10 gel our borders back, 23 Jun 2016, DIW 1214 | negative. 2 our damoeracy back and our country back. #Brexit 01:01 -CEST North https. //t.afeAs Dshi0 Teas KarialainenF Brox hankaloitialsi verboostosten palautamista | 25 Jun 2016, Fohioh- negative i Hitps.f{1.ca/NSOllqUeA 0401-CFST Karan Karjalainenf Rrexit tocennAirkiflinen, seursukset 23Jun2016, Pahjais- negative i ennskoirallomat hips cof Sd UOuCGIL 0421 CLT Kstiuls brik via stuck, sterling rhe us Breil arvicly bales 23 Jan 2016, Taiwan Teg https://t.co/umOpEIs0os via Reuters 01221 - CEST Pao_jimenn RT @_CarlosPak: Horarios clave ABrext ABremain 23 Jun 2016, WXDxic 7 negative a 0421-CEST 0,01 un23 Horario Wes amdpm Vatacianes 11pm Conteo preliminar Jun24 Horatio Mex tama! Tech Law Drexit: Potential Consequences [or European Union 23 Jun 2016, 1DSupra © neutral Trademarks hetps:i/t co/yIDH1baOCB by @foleyhosg | 04:21 CEST com sa @IP awshlertsh pinrceipctr Brent: Potential Consequences For Furapean Union 23 Jun 2016, Concord © neutral Trademarks JD Supra (press release) 0 vil): 0421 CLST LH, us hllpsdcolpsafraiss FyalvarciZ RT @infobacAr arcs: Bort Johor "Cote jucves 23 Jun 2016, 10 [ neutral 005 puede convertirse en el da de a independencia” 04221 - CEST hps/1Lofknb IYW=31W Aireit hps/1L3€} Tolcontinks RI @internazionale: La Drexit & un alibi per poles 23 Jun 2016, 13 [negative eurcpei poco coraggics, scrive Eric Jozset 01:21 - cesT https. £/.0/CLTBrby So Starmyknight RT @leaueFUOTicial: #irext leads in atest pall, 23 Jn2016, frizana, 267 | positive a7 carried oul by the ost accurate pollster at the 2015 04:21 CEST USA General Flectian https://t.co/ Dwple | BurtanUnifo AT @leaveEUOTical: Hannan reminds foidebate that | 23 Jn 2016, 770 | postive m7 here is no such thing as Ll money, only lapayers 0421 -€LS1 money Breit FightaaRain RT @BasimaFaysal: NBrext hitps://t cofabyranDVY | 231m 2016, BETZ 7 04.1 - CPST marbasch RT @missingfaktor: Breit. Grexit. Departugal. 23Jun2016, Buenos positive Ialeave. bruckoff, €cechout, Oustria. Hnish. 0421 -CLSI Aires Slovakout, Latervia. Byegium. Feabaiye #AceNawsRaport Japan official says concerned about 25 Jun 2016, United © [meatal we rest pact an DX and financial markets: 0421-CFST Kingda https:f/t.co/YBAYSyBARS @hccFinanceNews m Brosking1a4 #AceNewsReporl Japan official says concerned about 23 Jun 2016, © | neutral Breit impact an FX and financial markets: Da:21 cesT hllps-f{LoofLOqVY WGI @Acchinunce News WornenWor &acisr Bacis | Project Racism rebounds in rex 23 lan 2016, New © | negative Idews1 vate Britain to Rarain but EU supers... 01:21 CEST Jersey, tps. 1.00/25 1BYGARS Hine Bue ¥Tcor usa cuslshUK RT @drceathreont. fis on Australian, can you please 23 1n2016, Partaro > | positive point me in the right dircetion for some #Brexit 04:21 CEST uth perspective Ewiarranali andfor Snailhima | Tracers_Edg Japan official says concerned about Brexit impact on 23 Jun 2016, positive - FX and financial markets. Deputy Chief Cabinet Se... 04.1 - CFST hilps:/fLco/DLTICD) dares TejalFalanis RT @llcounorrics: Curupe considers implications of 23 Jun 2016, United neutral Brexit hitps;//t.cofncatTX Th 04:21- CEST Kingda m possiefim @Senpaterson RE your Breit pitch are you aware of 23 Jun 2016, Sydney negative this appalling UK Govts' 01:21. CEST discrimination hteps:fft.cof7EmTeral il costing 07 budget 51612 outreach20 BREXIT: luracl Nevds UK to Rerain in CU Lo Fight 23Jun 2016. Citra, negative a Threats, Says Ph David Cameron Israel News... 0421-CEST Florida hllps £1 cof NHC via @binalerts andbiler I yrexit fails start a tradition where LU slams the: 23 Jun 2016, negative door in the faca of the Ph symbolizing EU's 01:30 - CEST Independence from provincial gavernrent. Starentr RT @WSI: Fastern Furapeansin UK. rush ta applyfor 23 Jun 2016, San neutral sieet citizenship shead of Breit referendum 04:39 COST Francise hits. f1.cofFOSypiPrY och Rebecca A__ RT @Forunaliagasine: Why Erase wil ba 3 disaster 23 Jn 2016, hegative perce for Ireland hlgy://Leofucl\ vc 0439 L510 Dradders7L https //t.cafzhe)ILIWY Smalin vote Leave. Please 23 Jun 2016, London positive. read article 01:20 - CEST abrahtm & Escucha a€wBorn in The EUS€= la nueva canciin 23 Jun 2016, Mithoac neutral de Spector hepsi colftalfrorhis | Ssapitas 0439-CFST kinda cargo MEDC 3 Piastal | Escucha S€ctBorn in The EUSEs fa nueva cancion de 23 Jun 2016, neutral Spectar https. //1.cof4ytwxPChrk 04.38 - CEST Ilo 514 Fscucha Akcsfiorn in The FUSEe la nue cancif0nde. 23 Jun J016, erica neutral Spector hitps://t.co/VYCHS aX 04:38 CEST Lailfer #brexil hitps:/fLoo/TunglLap3Y 23 Jun 2016, negative 04:38 - CEST Toraconsentl El quintenta londinense Spector astrent 3€csBam in 23 Jun 2016, negative du Ihe LUZ€» una nueva canciRén en la que expresan su 04:38 - LST sentir acerca del Brexity todos 0s.. Fbogangete _Escucha SEcaBorn in The EUSE a nueva cancion de 25 Jun 2016, Quinta neutral ws Spectar. Fl quintento londinence Spector estrenf? 04.38 -CFST a Rao, #€wBorn in The EU... https://t.co/GOIo53Xdf MED xic OU Ripe Los an Ay Predictionbook suggests | 23m 2016, PA, neutral abuul 1:2 pds of dbrexil happening. 0438 CLS Flbay Milky Waylan inked Rallzons Hmm es or no", [el me seep on baby baby lel re 23 Jan 2016, 22 T [posite sleep on LI give you an answer inthe morning. UK. 01:38 - CEST Acacia hape you pet better, sexi suvenue Iohnserocol RT @SohnGSulluantit At stake in Brexitahether UK 23 1m 2016, london 20 | negative 4 stays in an undemocratic polity o regain ts 04:38 - CEST selfgavening democracy? Not trivial: RAE] asscarjuarer Fscucha écefior in The FUSE fa nueva canciinde 23 Jun 2016, Cash © | neural Spedlor hitps:// Leo TUCias 04:38 CLST a Chink7 RI @aork: | Uh end in News where leaning of 23 Jan 2016, New PoE somaone or somthing is headlined as Rexit or 01:38 CEST Dalh Drexit.So If | leave from surwhere am 13€} Rasalia glez Fscucha A€ceBorn in The FUSES 1a nueva cancif’n de. 23 Jun 2016, Caahuil neutral Spector hitps://t.co/Vb7gFHmOSh. 04:38 CEST a selualile2d Brexil: AJ2 du rADADrendum, dADbal cflammA© 23 Jun 2016, France neutral devant 6.000 spectateurs X Londres. #022 04:38 - CEST https ou nABHCAOYHI Chiroyo The latest w—¥37S Chiral hitpsi//Lcofhotit abso 23 Jun 2016, 10KYC © | positive Thanks to @sebapeter @chikashiojima o1:38 - CEST @cubanadentures érolingstones shrextc weapon) RT @Farboes: Pall: Ab af Americans think Fritain 23 Jun 2016, 337 | postive should leave the CU https://1.oo/CPRk4S8cSh 04:38 cost https: ft. caf3maaV EVs WachamanP RT @hilenio: 3-1 Problemas an ol parafica JGQUAC 25 Jon 2016, Pusbis, hegative uw en el HBr hipyif cof SEaiAGHGAL 438 CLS MAD https:/t.co/ mKpDABAD. a ETCPosts #bitcoinnews foitcoin wbitcoinews five] US. Stocks 23 Jun 2016, tara neutral ide the Waves of rect Anxiety 0456 - CPST Morida https:/it.coft XXotu1XcE dbitcains Sbitnews ehircointalk Taka RT (1 teanna: Wa ara praying or you Stan 31m 2016, Fr posite Arercans stand with you! D436 CST Worth #Brextt Tog #Voteleave https //too/ IOEUBUS ngham wh Hoofdnieuw https://t.co/CsupbjE3eC To brexit or not to brexit: wat 23 Jun 2016, negative 51 ie mont seen itp colbSaRNISW 04.36 - CPST Trafficiiddy What is Brexit and the Ramifications of Leaving fhe 23 Jun 2016, Traffic negative Luropean Union [UK News] hllps://Loo/CVAZOMECAT 04:56 CLST All https: co/B3rOPIXBLL Around The ward, Kumarabhis RI @dsnews: Holland, huncker raise stokes on ext 23 Jan 2016, neutral 58 hitps:f/t.co/¥b2guYnliA hitps://t.co/PYhCLUMYug 4:36 - CEST ONLVSANIE RT @DDNewsLive: #Brent: UK goestopollsinan 23 kn 2016, Gaman negative FIA historic tefarendur on whether the country should 04.36 - CFST rer~ain @ member of the Lurgpean Uniond€: Brandonila RT @Blondeligressnc: The latest The Nurse 23 Jun 2016, positive: nelry Chronicles! https://t.co/tLrMbiIL7z Thanks to 04:36 - CEST @DUDDHA DRAGON @0sagieSelma @Gibbsdithers #oresitae] Cacishavis RT @Reuters: ON prices ise 25 markets on T53un B05, Brith rautral tenterhaaks ahead of ret vote 0436 CPST Calumbi https:f{t.cofA2AU?3CAXO0 hitps:/1.co/ZFOmIuGIRN a Canada SamRamalh Prediction: #Brexit is defeated and everything stays 23 Jun 2016, negative sits {rote ar esl tha same 0436 CPST grahamina AT @IASFMARKRUTTFR: Be proud today sndvote 23 Jun 2016, Durham positive 5 LLAVL CU Lu Lake back controll Power lo the People! 04:36 CCST, #Brexit Moteleave htps:/{t.co/00ebEddutD England trumpeount AT @FLforTrump1e: HBr: 4BBC HEU 23102016, United negative wv 0836 -CES| States Rule Eritannia & Without the darn contingnt of Furope infested with iusiim sympathizer beral Pollyad€} CarlaChame 87% of Undecided Lo vole ABroxil.... Brexil WINS | 23Jun 2016, Granada © | negative: ros [a Referendum alistical dead heal ? Nicarag https:{ft.cofDoMFILSOjH hits:jt.cofj2Vgrswiok us marsquads1 RT @Rablawe: Ta my UK frends: how doyaufesl 23 Jun2016, Bahru 15 | negative abuul the "Brexil"? And why? Very curious logel the 04:36 CLST p,NV REAL story. Torulasry Live Thread: The BREXIT Vote: AEritain votes on 250m 2016, Souther neutral Inciependence from the Eurapean Union 0456-CEST hn https:/it.cojafdcul27wl Californi a Us CuspCreativ What i Brexit and th Ramifcations of Leaving the 23 Jun2016, Souther negative < Curopean Union [UK News] bllps:#/Leo/CAMIYTIGoG 04:36 CIST Californi 1othAmend RI @oovhouchburn: @10thamendment today we fly 23 Jun 2016, 57th positive ment ree! #Brexit hitps:/t colTAOKTvGY 156 CEST State Turakirass RT @sjplus: London's mayor Sade Khan crushed 23 Jun 2015, TIT | regative cen: Airesit debate A€” while Fasting, 0436 CPST i drop, please. hllps-f/LoofeNsil mle Q. pamsap_y RI @independent Victoria Beckham is not supporting 23 Jun 2016, 19 | positive the Leave campaign hetps://t.co/S1zjoWSm50 04:36 - CEST https. 11.00/10 DO1C ConceptGrp Ol pices rise as markets on tenterhooks ahead of 23 Jn 2016, [neutral Breil vole hilpsiffLoo/uswitakonel 04-26 CLS JOIIMEAZ01 What Is Breit and the Ramifications of Leaving the 23 kan 2016, Motor © | neaatree 5 European Union [UK News] https://t co/anSRKNFm20. 04:36 - CEST Club of https. //.ca/kIDMSGOpA! Aenea JUS fighltorror 1s Russia Really s Threat to Brenit? 23 Jn 2016, Jerusale © | negative hitps:/ft.cofFKECTN pac 05:13 -CEST_m Gesthmorgs Frat history s wiitten today 23a 201€, Mexico neutral n D513-CLSI City Joannawom RT @saredWyanct BUITISI MUSLIMS POLL: S636 say 23 Jun 2016, Arerica negative anal they wouldn't wam af a terrarist attack 05:13 CEST Bret AEUre! ATrumpSpecch éosilNGBreak hitps:a€ Talphshields RT @roarielruieh: Support from Chicago, for British 25 Jun 2015, Las postive 33 frmedam from the FU. May fritain reclaim sovereignty 05.13 CFST Vegas, over its ation. WVotcL eave MEroit nv TrumpCoull _ @Cizabethburlcy You ere the cribodiment of British 23 hun 2006, United poste ents Beauty. Preserve your nation, preserve your people. 05:13 - CEST States aprox brasizZ014p Eurapean Union faces Afican migrant criss’ 23 Jun 2006, Vancouw negative ool Underfire Merlcel issues stark warning 05:13. CEST er BC hits. f.0a/c 1 Wke7 34 soaneseys @UK|abour Breit all the way 23 Jun 2016, neutral 05:13 cast TMWILTS @UUIeWombato6s of he poll. & indications orc hal 23 Jun 2016, negative Remain iil vin today... Wasted opportunity fret 05:13 - CEST assays @BECBreaking GUEFA EUEFAEURO If Brexit wins will | 23 Jun 2016, Betung negative @1Alreland G1 Aiales Dngland @Northemireland 0513 -CEST I1ut be disqualified? https:/t cof EXIYENubw Bitcoimagie_#hitcoin Price Drops $100 As Broxit Hopes Falter 5 Jn 2005, Watier neutral Blockalerts 4Blockchain hips: /jt.co/CAQFE mii 05:13-CFST Maesnit hips /Lco/Banvobitpe Witter Sammy_io0_ Broxil b also purl of pralecling Irchand anid Wales 23 Jun 2016, pow n Britain! 05:43 - CEST Wr_Vivaol ACQUAT = ol RBrexit? Van 7 claves para entender sl 23 Jun 2016, _Wiexica negative a referendo de fina Unico | Par bibemindo 05.13 - cesT https: co/TrOILABIPA. hitps:/ft co/zueGHO20XE Arblivedray WSinagatiews Inter Selangkoh Lagi Dapatkon Bek Sapo 23 kin 2016, Kola neutral on Genoa hitps://t cof UKE 05:13 CEST Bina, Sumater a Utare brexteer20 #Brext AEURCT Sounds familar, seems fie the 25 Jun 2015, © positive Fy protocol of fear campaigning is rite these days NOT 05:13 - CEST fooled BLeave hitps. /11.00/5e21 yN6Tu3 Carysim HinciTkalent: Asia stocks, sterling rie a Bret anxiety 23 Jun 2016, Seattle, © neutral abates: Asian shares cdgod wp and sterling stood 05:13 CEST WA hips /1060/BODGRKTRAD 23€1 Tilismyds RT @ikeMia_ to all my redo Tolawers, vote 23 Jn 2016, all posite ddy rar Lomorrow AURLAIL 013-ELST pultae lata. Tantasyman SAD SER SHURA SOR 5 1un 201E, Hava posting dan A ttle ic as we head into this binary busin 05.13- CPST known 2s BREXIT. htpsfft.co/aadr i Txwé $5PY GordonFEan @KIKTheReds] Get some geography mate before you 23 Jun 2016, neutral nett corarent. Scotiand, tales and fnarthemireland are. 05:13 - CFST valing tou its Boresil nol deexil Wkolasratu RI insur [ve Brilish 100d al 0 moment in Ure. 23 Jun 2016, Vancous 103 | positive fist https:/ft.cofcDoan Tigh ABraxic 05:13 -CEST er, BC, tps /1tco/wpkUonAA Canada favtan2 RT @ingrahamAngie: Bono, eckham & every other 23 kn 2016, Some 339 | negative slobal celeb in Britain ag #Eresit. Fallow the 5 05:13 CEST herein glaaization great for them, horrid fore Virginia Kostlason RT @hikehacck: Be a patriot Vote Lave. Mhraxic 23 Jun 2016, Astoria, 3 | positive lps: cof KnOn bo 0530 cis oR Tanlreetun 5,3, 4, JE 325 — Beer WELSH Fe Regt 23 Jun 2016, OEE BE 05:30 - CEST SoG, HILLY AO BL — 0 hitps:/it.cojedyoaspFOZ by @HufiPostiapan itp. ft.ca/701bOMCT Iruthenaric. RT @serohedge: Wha Is The "European Mover-ant’ 23 Jun 2016, 39 | neutral s And Vehy The Atawer May Change How You Vole On 05:30 CLST "Brexit” https:jjit.cojFKKOXFH lum Wiatervlynd RT @thedalybeast: Brexit wakes absolutly no sense at 23 Jun 2016, negative al. teres shy: ps: coftaPIIGYNMZO 05.30 - Ces https: ft. co/FZe)onXCiN Tubinbiz Wud, Music and MilesLong Uns a5 Glastonbury 25 un 2006, © [neutral Clashes With fraxit Referendum 05.30. CPST hltps:/fL6o/1715HQBy=Y vAa @hubinbie Nyheler24_ RI @V_of_Lurupe: Faraged€ *s final rallying cal 28 Jun 2016, 57 | neutral 7 26°35 us versus the Establishment goandvote 05:30 - CEST for Britain’ https 411 co/ Leb Prypt ItsDasisDa Wa, Music and MilesLang Lines as Glastonbury 23hn2016, Las © | neutral son Clashes With Breit Referendum: Their countryrmay 05:30 CEST Drear be abaut to... htaps://t.cofqmVaXanXUM usc Noanebin RT @X@I Wk: Dear Britain 73002016, Westem 10 positive When you vole loday, remember the sacrifices rade 05:30 COST Australi <0 you can be free. a rex AoteLeave ALU HUlps /ALco/HLIE arllegar lollow Mud, Music and MikesLong Lines os 23 hn 2016, Cloud © | neutral Glastonbury Clashes With Brest Referendum: Their 05:30 CEST 37 A: country may be a. https: cofradSopspY telbour martinsicve RT @Rchmansic: According to the poll conducted 23 Jun 2016, Lincoln, 14 positive 27 slight majoricy (525%) believes, #UK should otal eave 05:30 CEST Lincalns (Breit) in ALUrcferendurr, Wipsf/i€] hire BlueFloridia Some ind of publiciey Stunt? Except for Princess Bi, 23 Jun 2016, negative n the UR hasn't gotten this much global allention since 05-30 CLS the early Empire days, ABrexic JayDook RT @realkingobiso: Breit Poll Shows 807% OF 25 Jun 2016, postive Armenians Think Britain Should | eve FU 05.30 CFST https. o/ghiHHKs<9Q htps:f/L.co/ Gh 2KHR2H iN BharalRajne B-aRS aYEIN—aVES OIL BVA] dted¥e WA 23 Jun 2016, Indie neutral ai A. SARE ar Ha Sa BT 05:30. CEST Aci SGT GSR” ABYSS 7 hitps://t.co/aWSyelOv2 via NavbharatTimes hits {t.ca/ JS PHeaV. Artofetian There's toa mich at stake for elites to let the people 23 Jun 2016, Negrez negative of Weritin exit he BLU. Len i the people win #8rexl 05:30 -€LST votes, elites vion't let them ReutersBiz Oil rises as markets on tenterhooks ahead of Bret 231un 2016, Where © positive vate hHps:fft.cofwizutey! 05.30 CEST you are. poluakerfor Wud, Music and Miles| ang lines as Glastonbury 231n2016, Neen © neutral d Clashes With Brexit Referendum 0530 COST ~peEiE" hips ft.cao/HCISRACEIL torikn RT @benphillps76: Peak Brexit: UK protestor tries ta 23 Jun 2016, Australi 15077 | negative burn the LU flag, bul can't, because of LU regulation 0530 CSI a on flammable -aterials hitps:/4€! Falneth RT @Daviclo52051015: AT Please take a penito the 231un 2016, 548 | neutral Balling station with you fomarrow & don3€™t usea 05.47 - CPST pencil #Brexi hitps://k co/O¥nrUyxud3 FRI3_WORL RT @RcalAloxoncs: WATCH: Standing Ovalion for 23 Jun 2015, _ free. wor postive [] Former London Mayor Over Plea to Leave FEU 05:47- CEST Idtuta hp //LoofONSITHASMI AVoleL eave SBRLXIT notaco #leask!] m WichalEinet RT @INTIutsu: IF tha UK dosnt get out now, there 23 Jun 2016, 137 | negative te wan't be anather chance, x their country wil be. 05.47 CEST overrun & ruined ABREXIT #UK https f/t3€! IndomTradi Oil rises as markets on lenlcrhooks ahead of Brent 23 hun 2016, United neutral ne vate TOKYO (Reuters) Oi prices rose in Asian trading 05:47 - CEST Kingda, 0... hlpsilfLcolb2KGIC2aFw m BieDatabiass ForexLive Asi FX ns wraps bret polk driving GBP 23 Jun 2016, neutral still https:fft.co/b/iUsIIXOPm Forex news for Asia 05:47 - CEST trading Thursday 23 June 2616 Ansa€] Cryptosourc #bitcoin Bikeoin Price Grops Below 5600 As 25 Jan 2015, Woridwi negative HO SE RrexitSE™ Hopes Falter hitps:/ft cofwXiaxhbfYP 05:47 -CFST de. FreeCryptoC _flbitcoin Bitcoin Price Drops Below $600 1 23 Jn 2016, Wordw | negative a AE BrexildE™ Hopes Faller hllps/fLcuf@VCHBROID 0-47 CLST de. bintanghadi Breit itu untuk kedaulaton GB. hanya keluar zona 23 Jun 2016, Soeraba © | negative putr ekonomi perjanjian bilateral bisa ditata lagi. Kenapa 05:17 - CEST ja - po Kanijed de Nederla nds Indische. DomMitchel Be smart. Don't let racism and fear win #Betterin 231un2016, LA/ negative ) #Brexil ARemain hilpsi/fLeu/Vel I6LNben 05:47 -CLSI London J Roarton Lene. balika7510 RT @BLervoire: RAT sultat sans appel ce seir sur 23 Jun 2016. negative @lann : 05:47 - CFT 7% pour le Wrest Un ArADFAG rendum vite | Breil ANLP2OL7 dvecharine blips: /a€ HXS_torex_ Breail's Real Impact Would Be Gradual and Global 23 un2016, Geneva, positive EN #5tocks #Finance Forex #GEP ASGD ASGOIPY AUnited | 05:17 - CEST Swiasrl Kingdom Dow https://t.cofhSIadwonQf and sunandavae RT @myindeakers Breit Will the United Kingdoms 23 Jun 2016, Houston postive hist leave the European Union? ABrosit 05:47 CEST itp. ft.cafis Yas! OurNewFur Les Britanniques votent avjourdi€™hui surle Breit, 23 Jn2016, Berne, positive ope on les Lurap&ens sur li€avenir der nolre. 0547 CST Swileerl continent sur https: /t.co/SEN Bnb3ss | and Velkerpauls Fiollet debat! Det Indre arkeds resile vA rd har 23 Jun 2016, negative on INTET Flot mechrrel 05.47 - cesT Alle frygter Brexit 3€” bortsat fra Putin rips ff cof FI BNCr 71 JASFVARKR FU referendum Thursday 231d June. Vote |EAVE FUR 23 Jun 2016, United positive uITR relurn FOWLR 1o the PLOPLL! #BresitOrul #8reil 05:47 CLT Kingdu hutps:/t.cofECTNZAAAD m Brome Warquardt] RT @Bjoemsta 3€cThe ime has comeates for 50m 2006, London meutral 3 A€mindependance Dayi€os? UK Titelseitan margen. 05.47 - CFST um ACU! WBreit via @suttonick hitps:/ft.co/ Ts DISE Viadsundar AT @missinglactor: Bret Grexit Daparuga TnI, Sngapo postin am aleve. brackolf, Catchout, Oustia. Hrish, 547 Cust re Slouakou,Latervia, yegium Chennai theador19s Toray. FU ceasing ta exis, UK ceasing ta mist frexiz 23 4un 2016, negative 7 05:47 CEST Janunos RT @1uémd: 80% of Americans belicee Britain 8 the 23 un 2016. Wash. positive warkd would have a better future with BRET 05:47 CEST DC hittps:fit.cofudNungSXts hitps:/t.cofiba 7ea€ Spain 3rain Fates ik the braxit situation | guess 730m 701, Wartan. © [negative 0547 IST IL Chicago expat PIIGNIO63 RT @XoPLWe¥: RELRSt Polling day armives & counting 23 Jon 201€, Nr 0 [posite Hinson postal voles rom just one howse in lower 0508 CLS! Manche Hamlets ABresit Motsleave hitps:/jeiC} ster, England CHCConGon FI Brew pone en riesgo ba nat de Reino Unido sus 23 Jun 2016, © neutral fC] finanzas locales https://t.co/0vtUOarede 05:04 CEST lamirdlo olive: RT: ajonglish :ABrexit and the toxicity of the 23 Jun 2016, © | negative UK politics tps: co/ARBFASHQR 08:04 - CEST htlps-f/LoofXLdLiNkm) Wrortiofic RI @mkopNY: LIS Stconomy continues lo deteriorate, 23 Jun 2016, Oregon 7 | negative #BONDS ra BUY, #Bresit or #6remain fs ielevant, 05:04 - CEST STOCKS will go DOWH uly hetps:/ft.co’€ splendid10d resi. los 3 temas que definen el referendo sobre la 23 Jun 2016, © | neural a permanencia o salida de Reino Unido on la UE 05:04 CEST https:{it.co/p1aDmHemHN | BBC asirgotravel Harilela Hotels: Braxit will be tough for hotel industry: 23 Jun 2016, Budapes positive While Breit il it the hotel induse.. 05.04 CPST 1- hilps:/7L.cofy UsBHXEICT Wenbe_travel Hungary redrivergd RT @NRO: Breil is prouf thal people are fed up with 23 Jun 2016, negative government planning: https://t.co/sWpnNhSWi 06:04 - CEST Barbierels Brexit: los 3 temas que cefinen l referando sobre la 23 Jun 2016, neural i permanencia osalida de elo Unido en la UE: Los 08 04 - CEST bith... https://k. cof TKANVspySER. lumirdta notiven: RT: elmundomovil :CLAVES | 20 puntos para 23 Jun 2016. neutral entender el afcefrexitiée de Reino Unida 08.04 CPST htlps:f{L.co/n73hHZNAdF hitps://t col HOK3SKKTbz Nolgapronta Todus andan muy oxlrahtos por ol #Brexil 23 Jun 2016, Mexico Tegalive mx 06:04 - CEST airgotravel How vil UK Souris be affected by Breit? Brtaim's | 23 hun 2016, Budapes positive tourism Indus, while resilient, wil be... 05.04 CEST 1- hitpe:ift cojask7be7) henbc,_travel Hungary Swaggertar Brest los 3 temas que definen of referenda sobre la 23 Jom 2016, neutral am permanenca osalidade Reina Unido en (3 UF: 10s 5:04 - CFST brild,... hilps:/fL.cofGICYSOC20R Sheor-sads Harilvla Holels: Brexil will be (ough for hotel industry: 23 Jun 2016, Warldw neutral Vihile Breit will it the hotel industry hard two... 06:04 -CEST ide https //t.cof IMGBIalOSH ATT RT @dibya shareluz: Merb Kya llogah Kiya? 23 un 2016, Na #Brexit #Rexit Exit hitps://t.co/Oirowb51lub 06:04 - CEST odemei 87 RT @Reutors: Oil prices rise as markets on 25 Jun 2015, 0 [neutral 7 tenterhaoks ahead of Breit vote 06:04 - CPST lps f/LoofAAUTICOXO hilps/Loo/ZHOrIuG3Rn djingjing RI @sombalonwimon Li,»8.2533,70,% #3 J £0 — 23)un2016, BKK 21 | negative 8.%5a.£6,3,887a 13.08, Brit 06:01 - CEST 8,50,40 5,10 Jb%ed €3 03,4" 8,53 B08, 1a a ua 03,°33 5. 5,70.53 83, 8,5,3,3 05, ATAAMAFUA — HE EA pai 63, 75,9 % 0d £3,433 3 33 50,3, 273,63.73.54.50,™0 70 78,05, — ER EERE EIR ETL SRE TR SRY 8,335€ CCConGon Fl Brevi tam bin define af Fura del Futbol IngiAGe 23 Jn 2016, neutral aor hp fLoofaNAjrisass 0504 CLS Anthonyswi RI @relandbreds Great response fror= people of 23 Jun 2016, positive hoe Shaffsld today. If wa can maximise our LEAVE tun 05:01 - CEST aut, wr will merges with > reat ett epatrader Alert en losmercados: os dos. escenarios del frexit: 23 Jn 2016, Shangri- negative Silos bri inicos votan hoy por ali de a UE, lasbo... 05:08 COST La hitpe:/ft.co/GAENPCP HY Nyaranar RT @AMTrumpAPRES: 1d ie 2 dedicate ths tweet 2 23 Jon 2016, Derwar, 21 | positive former lovely cultures that wil only b found between D522 CLI CO the pages ot a book #Erext httpsae onefingersh _ WBrent, stage [eR https: colviGhseGI8 Hin d0E a negative ant 057 CPST _ sandbox Thel6ihCha RT @W axCRaser: This is Boris Jahnson before he 231n 2016, Walerh 77 | positive per realised thal Bret would be his chance to become 05:22 CIST aplon [2% itp. 1.00/XnSGDAGRDK itps:fit cofat Joephinehd RT @afpfr: ¥irexit lnc Britanniques vatent cur leur 93 Jun 2016, France 1 | neutral aribe awerir cl sur celui de UC hls f/LcofpZkCOROL ~~ 05:22 CST Lurupe AFP hetps:/ft.co/P2hN 2u53m eis L aba.. Wanuelsign ACEI in del suefto europea? Brexit'o Dremain', los 23 Jun 2016, Panchim | negative enzat britkinicos ceciden suf futuro: 05:22 CEST alco, EI Wienteas oda el. hip: ft.cafl NCO myahWee Salvadar loupaBS RT @ProfTimRale: The ea that Faglish nationalism 23 Jun2016, FRANCE 10 | negative has posicred suppor for Broil s unduly sirplistic 09:22 COST [44000] and requires reexamination https:/{3€ ziruma_roja AJLABORATORIO CLINICO BACTERIOLOGICO esti; 23Jun2016, MATURI © | positive 5 disponible] hUtpsiffL.cofaluriUrste Bbrexil bvenezuely 0522+ CEST N ESTADO WONAG P Thousandne Palilicor 117 |= eH ZiW-[u0 1,1 Broil L155 23 un 2015, GRECCE neutral we Telalol-T T= 104 EL, Bll J, ABAD, I, Ife: 08:22 - CEST Taiz PIMA Tl TALE ICE Tf, T= i. https:t.co/nHxgbPwuL Wiguela_5V ACEI fin del suehlo europea? Brexit o Bremain, los 23 Jun 2016, Ciudad negative Brtfinicos deciden su futuro: 0521-CEST Aros, La Mientras todo el... ttps.ft.cofclibbiNeuva Libertad Pontifex mi RT @frecWorld2: Russian Propaganda full specd 25 Jn 2015, Westfel 7 [neutral nim ahead to Pret bitps:ft.co/SaFYXFSq) 051-CFST a, Deutsch land RPKien RT @ShaRhis 107: Why has @twiter promoted 25100 2016, 51 [negative @UKLabour andremain about » ties on my |L today 0321-CES| and not promoted leave once? Dodgy methinks 3€1 Tora RT @Davidlo32051945: RT Please take a pen tothe 23 Jun 2016, Callforni neutral palling station with you fomamrow & don3€™t usea 051 -CFST a, USA pencil ABreri hips: co/OYnr Und Tnestonke RT @Fabes: Poll 80% of Americans think Britain 23 Jn 2016, posite v should leave the LU hUlps//Leo/LPNka8Scsh 0821 CLSI hitps:ft. co/3maavaiSkD Carsonsievi RT @missingfator: Brant. Graxit Depariugal En 006, Naw posting " tales. muckoff, Crechaut, Oustri, finish, 051-CFST York, NY Slovakout. Latervia. Byegium. Fernand SV ACI fin del sudo curopeo? Breil’ o Bromain’ los 23 kn 2016, San negative brithinicas deciden suf futuro: 06:21 - CEST Salvador Mientras lodu el... hips //LoofqYOykiwXUp ou Salvador abprewste Explained: Why, how is #UK voting to stayin or leave 23Jun 2016, India positive per 03.21 -csT HLUrST RBrexOrtol iret https:/it.co/NIXAVTT 1a https://t.co/RIESQEHCK mala Paris joins global tributes to murdered UK lawmaker 23un 201, chennai negative Jo Cox tps: cofnVIST Nob 0521 - cesT https:/it co/q90unGrs Hx FnaelaYa3 RT @hcordinaryrand: This a my Flag i fLyous.7 23 hun 2005, pote 51507 0821 -CFsT Breil AlLoveiitain Mbelicucinbritain AloweBrilain #lamBritishnotEuropean no2EV aE | Finklinincia RT @DasShakticanta: If Breit happens, India fs ready’ | 23 Jun 2016, New neutral 0521- CEST Dell via Times Now App https //t.co/mNBriN3e2kY ValulaNews | ruders plan for allnight Brexit vigil 23 Jun 2016, neutral https: co/IAPOBSabaw AValutaews 06:30 - CEST https /7t.cofScaxubmata ATUNINIKKE Asa Ine bracing for Brexit vote: Nikke| Asian Reviesy 23 Jun 2016, positive {] https:/it.co/VBXIkLAhON #Brexit 06:39 - CEST chruhiler RT @catoletters: Defeat the Establishment: Brexit 23Jun2016. Los negative https: ca/FsampHpaQs 06:39 - CFST Angeles Tanguilem La Brexit en tA%te Gans deux sondage: 231002016, france positive https/fLoo/hiALDpIkY 05:39 - CLS1 mok he U has to rol 6 or more on 1620 to sae against. 23 un 2016, ZRSrich, negative Brent. What happens it rolls 3 critical failure? 06:30 CEST Switaerl https. ff1.a/mMn 143NC and SEtRlite)d Brent los Britanniques du sud de a France, 23102016, France negative inquik lent pour cur aver, ART 05:39 COST https ft.cofTeslahOGNAY https: ft. cofimAaliDAyH BR_Schwab _ Schwabens Wirtschaft und der Braxit: Was wire 23 Jon 2016, Schwab negate en wenn? https:/t.cof IXNallSlo DE3Y-CESI en fizza roha RT @itradeph: Asian Stacks flat/lower as count down 23 Jun 2016, Republic negative mrad to Braudt vote just hours aay. 06:39 CEST of the Philippi nes stirlleonline BREXII. £ decisivAf pentru vitorul Uniunil furopene, 23 Jun 2016, positive. LL Tabiifra proBrexit, avantaj fragil, potrivit ultimelors.. 05:39 - CEST hitps.fft.cofut7 URN Post_lecla RI @francofontanadd: Brexit, Il problerra 23 un 2016, Vicchio, negative dallinghikterra, & non solo. 06:39 - CEST Toscana Uapertura de @imanifesto hips f1Lo/QuBDSAMEGH ariunfihing la stay, or nol Lo stay, that is the question”. Today 28 Kun 2016, Urk, The negative forall UK people... Interesting what the voting Wil 0:39 CEST Nether! rr ands #Bresit or #Bremain Backing off RT ©CUNL_nek: How wil UK tourism be affected by 23 ln 2016, Latvia 1 neutral ars Rrest?: reais tourism industry, while resilient, 08.39 - CPST hips: cof CaF 3500dkA Openiinde RI @ASAPHwsLIVL: The nonils guide lo Brox. 23 ln 2016, Norther 219 | positive dRecs @CNN https: cofBOLEICIBac 06:30 CEST n Arizona Sebastionin RT @larbes Meco: Pesa se tranquilza ante posible 23 lun 2016, Mexdoa 3 | negative vi derrota del HBrexit en referendo. 05:39 cesT hits //t.ca/PI7YMINTA Scucobol AT @undarcovermag: Judgement day Bre OUT 23 Jn 2016, iPhone: negative OUT OUT OUT GUT OUT OUT OUT OUTOUT OUT OUT 05:38 CLST 51.4564 OUT OUT QUT GUT QUT QUT QUT OUT OUT OUT OUT 92. ouT ose! 2.6056) 1 ET ee SE EY IS Tee TS [poste 8.03, 3153, FRIESE @0Co, 43TVENET, 3,000 06:30 CEST RYAN, 3f Forti ang ¥ dR SKE JET Sop ALIS HKG, -aa SaiaaC, aac 3473, an 250 TEND ea SEK REE RES EE BA NEWATAT, ef ACETATE, hits. co/pwn3BrPkXT hitps:/ft.ci€] Hewat RY @nhk_ncws: 3618,03 53,3 a “wSegF 56 280m B06, FALE TS [poste 5.13515, STREIESS,E5 e1Ce, 43MVE31 B/S 0539. CEST ceEWid Forties EGR SK JE Sop ALIS AKG, =, SaTATaC moe 3073, a BTL Oca I HE REE ER aE BAN TWATAT, ef ACCHT VAT (TL, PHN, hitps:/fL cofpwn3BrPKXT hitps:/ft c3€! stowarl ss RI @AMTrurpaPRLS: 1d like 2 dedicate this bweel 2 23 kun 2016, Cogland, 432 | positive former lovely cultures that will only found between 05:39 CEST United the pages of a book. desi hUlpsie | Kindy Trumpindah The EU doesn't care about you. Why care for them? 25 Jun 2016, Tampa, © [negative ause tel eave Brew Hremain 0839 CFST 11 shaunmeg3 AT @Dwalingen: Very telling, very bus: the Remain 23Jun 2016, Sautha 2a | negative 7 campaign cannot say anything positive about #CU and 0539 CCST mplon, its “future” ABREXTT FEL hens: fje ac uk Tilonaria RT @rylimes: Brexitvote heady has a vinner: the 23 Jon 2016, Espana posite gambling industry 0526 CES hips: cojUBW3IWOGaYs Patty Ely RT @uroncwses: BRENT: 1 Reino Unido 1ega al 530m 2016, ChilAIn, | nevtral referh incum ean un ar-pate AR rico en low 08.36 CFST San sondeos https: ft cofadkoh2tCar Fintona chile curuls7s Act fin del suedso europea? Brent’ o 'Oremain’, los 23 Jun 2016, | negative britkinicos deciden suf futuro 06:36 - CEST https. //t.cafnhXeh0abl Joanberna If youwant, today... forest: 23 Jun 2016, © negative 05:36 CCST shiontakohia RT @nhk_ncws: 3648.00, 56+8)8 fic Seg BE 22 han 2016, 112 | positive nu 8.15175, Se (E3115,E5, oC, 437467131, 3/3030 05:36 - CEST Fhe aes Ed JUGAL Sogy RAG ANS, eR J ree HP LAE 43 HS — ROI a 8/473 GTIA a). CCRT SPATE, 5, HBTS, tps £1.00/pan3UTPRKI Hitps /#4.c3€1 banglcacdav RT @alplus: London's mayor Sadia Khan crushed a 23 lon 2016, Hew 3 | negative . recant #Brexit debate 3€" while fasting 05:36 - CEST York, NY. ie drop, please. hitps:/t.co/cNjh mime Conectalnte BREXIT Boris Ichnson, a a caza del AStimo voto 23102016, El © | neutral ma hips #1L0o/HNL lich hps:/ Loo iH DEWISRE D526 CESI Mundo naBIAIhPY 5,CI175, Bfebemboce, se WIEPATLANZATIAOATAS, 23 Jun 2006, 0 | negative. ah =e 3 Senna Tem 05:36 - CEST itp. ft cafeniRNpyF77 ER re Yoo? 10168” Oe 23m —¥ 13277 aos [Reulers 33 4301 "BIA — 3 AYA! naeedzonll RI @iarork: | © is Lend in News where leaving of 23 Jun 2016, SRKWO 3102 | positive ne someone or something is headlined as Rexit or 06:56 CEST ALD Drexit5o If leave from surwhere am 13€} [IT INGRIINDD erie A SPY AD SER, HAD 23 Jn 016, 0 negative ah epee FAKE CANES Ie BT 05:36. CEST https fft.co/MISTcoNXoR ERK re Yoc 20168” 06a: ZI —¥ 13a ata es Reuters 33.37 5 ST — cap hay depa RI @radiolbe: vandaag richten we de schijnwerpers 23 Jun 2016, 2 | positive pe helermaal op GroetBrittannike met Astudiolondan: 05:36 - CEST hits. /1.00/Nlaivhe Hhrexit hts. f/13€ KarimPadani Hat aff the press! Office Baily is aut! Read | atest 2342016, Ahmeda © negative ¥ Ness now! hpi co/hCXUNGR LW bres 05:36 CCST bad tairvind Balan _hel RT @washingtonpost: 13 Brexit facts that wil make 23 Jun 2016, Athens, negative bs Americans feel less erbarassed about theirown D596 CLS GA election hitps/t co/RyMUmZIClx SharmaChel Breland is passibl pac on Andis TE Jn 2015, Warba Teale an? https: co/kDAES?Bb2y 06:36 - CEST, Wohara shia HOUSE_OVERSIGHT_01119¢ Bavaria Only mad dogs snd Englishmen [_& Scatsmen, 310201, Singapo negative Welshmen & Northern Irbhiren, & worren) JUL, D336 CSI re hetps//t.co/HESyasLaog https:/jt.co/IERInre Toumagr #vimafinance Standard Poor's: WIHT IZI, 1 Tn 2006, Ahers © [negative i Fn] 1, Fr, o,f 08.36 - CPST Tella Tel, Paci: Brest htps:#/t cof dfwidhv0iC Wadjaknow RT @5weclCacophony: (1/2) If see JBrexit, #Boris wil 25 Jun 2016, 1 | negative mae on HCameron. A GE will be forcad WCarbyn wil 8:36 - CEST challere u halal doris, S0{503€ DinsiWalke RI @scolsdinpora: As [ve been saying for weeks... 25 kin20l6, Ken 8 | negative . “Wiould Europeans be fre2 to stay in tha UK after 06:56 - CEST Drea?” hits: /1.cof OW HANGXAY HIDE] bobbywarly Round 15. 231m 2016, 0 | negative ada 05:56 cesT England "remains" in Euro2016 11 hahaha EUROS But hy to wait for BREXTT result tomorrow. #BREXIT hips. /ft.cof Poh 3¥aRP v.sabia RT @arkteguicnn: Julio Milin y Francsco Gil 23 1un 2016, 52 | neutral analizan can Carmen @risteguicnn el referADndum 08:36 CLST por el llamado "Brexit” tps: cofiAQTS€| byrie2013 RT @Elabathburley: Vote tomorrowwhatever your 23 Jun 2016, Suny, 2796 | negative persuasion. I for dlirexit & praise to neither gloat 07.13- CEST nzland nor whinge. But VOTE! https:3€! R_KitanoR RT @nhk_news: S€38VeguZcVee 23 Jun 2016, positive “AN AES, eck A 07:13 CPST LE Ea ep Cp RC Fp Tora Te Za eS SIGE ALLAH 0 YD. BS G34 A<EET, AE {TAR BEAT SHEE, its. ff1.a/SF XVmTWRL fnhk news. | mattnofls RT @laStarpa: Scemiati contra a Breit: ibn 93 Jn 2016, negative allo disastrozo per a 07:13 cst ricercaiésh htwpeft.cof\wazHiCheR: Capelawega RT @V_of Europe: Dutch poll leader Geert Wilders | 231un 2016, Breda neva wants a Net after a Drextt, 0713 -Cesi hitps:/it co/R4CQIDIAKA Valentino RT @ronaldlecssig: Gesstze macht von dermich 23 kn 2016, berlin neutral a geswiinhiten BFUKar-r sion. Wir wollen hemolatia 07:13 -CFST german Jota, sash ABrenitBelArworlcrin Firth 3C v PG_enlurs Final Brexil Appeals Mat Poll Diverge on 28002016, South neutral s Referendum Eve https:fjt.co/DakivoTlac. 07:13 CEST Carciina Usk lghwewege (al Bret Appesls Made Polls Diverze on 23 Jun 2016, Columbl neutral Referendum Lue hp: f/L of YaLUNKSICL 0713 CST a, South Carclina Viier8Fs Final Grex Appesiz Made as Poll Diverge on 25100 2016, Auckian neutral Referendum Cue hutpsif/Lco/20c00m272d 07:13 COST d, New Zealand Sandramart Ese matrimonio necesita Terapia y no un Serco. A 231un 2016, PERRE negative o hrs de suberlo @InfobaeAmericu: #8rexit; Hembla un 07-13 - €LS1 sigante y el mundo espera aukinito WikauGiobal Final Breit Appeals Mada 2s Pols Diverse on Tn 006, Aucklan eutral Referendum Fe https: f/t.co/QIYQD02rs D713 CFT 4, New Zealand VivierGroup Final Broxil Appesls Made 25 Poll Diverge un Jn 2006, Private nulral Referendum Fve https. cofc(CIAVEYPT 07:13 CEST Wealth Manage mene GanyPlarm Final Grex Appeals Mads ss Poll: Dherge on T5Jn 2016, Auuckian mewtral en Referendum Eve hetpsfr.cof) MWINYA 0d 07.13 CFT diy, Hew Zealand Sitar Final Grex Appeals Mada 25 Poll Diverge on Tn 2006, Aucklan eutral Referendum Eve https: ft.cofh armrl1V67 0713 CEST 4, New Zealand Chadistore RT @robecenk: GTberytaran They're gonna chicken 23 Jom 2016, eget se aut... eit htps:/ft.cojacaTICeD] 07:13 CFT bigirvenkya AT @TINE: Mud, music and 120our traffic jams.as 23 Jun 2016, Entebbe neutral i Glastonbury chishes with Brexit vale 0713 CLS, hitps://t.co/NbSSe3bxSr Uganda FairwalfDes RT @Fionnaightiessey: Only ons of many reasons val 23 Jun 2016, postive ne be vating | FAVE. 07.13 crsT #Brexit hittps:/ft.co/Szhlm BAgxb TommyBarr RT @bbeardrran: Ok Briain. Us midnight in Texes, 2% Jun 2016, poste s butts Gam your time. Ga vote. Heres Wotaleave 07:13 - CEST voteLeave lakeControl ps:/LcufiE rollienl22 RI @logesschau: BrexitUossier: Goodbye nach 43 23 Jun 2016, West 5 | negative: Jahven? https:fft.cofANbmG3e71L WBresit 07:13 CEST Sussex, uk TheSagarki Game of Thrones Has 1012 Stake inthe Breit Vote. 23 Jun 2016, ne © | negatiee mar Seriously. https /t coMMuSUshEs 07:13 CEST dwsch https: /ft.co/ToP3IaGbr wr Felnoraue RT @eljukehox: Todo el munde s3be que ool Brexit | 23 Jn 2016, _ eibar ewral cho Susy maine slosespiltalon voli iv-ion 07-13 - LST Espafica, GutTheEU RT ©Y_of Europe: Evan France vould (EAVE the 23 Jn 2016, Yorkehir 5 [positive SE°SAdRE™ FU IF had a refersndum, top rench 07.30 CPST» and philosopher says https: co/AHPaxRalS The rtp Humber England Betis RT @insrye_UK: Bec, leggings 1 15 things vied rather 23 Jan 201€, rege be IN right now |including Europe) 0730 - ESI https:f{t.co/02FpISgZin #Brexit sStrongerin hitps:ac! URiaincHot © Di, BuNEDLORE ND 3D D% Brat Fhn BIE, Kyiv © [neutral News RED. Re PRE OHDPD DIR 0730- CPST (Kiw), 04D RE-iC OHA B18 f10-DuDsfie Ukraine REDHEUENATN, 0" 02KEDI—6%0, © B,0i: 07 ©0 —-, B3AE070 NI fo NeA-R_ 382 EEE 3D DADENENED. fe. Ips co UMA 5p u, ooeie wii— 050) ma_arm_42_ RT @ndaktuell: #GroAfbritannien entscheidet: 23Jun 2016. Weltme negative n AsRersaindu oder folesvefa? Referendum Aiba 07:30 FST tropold Sede Verbluibin der Cu Auull orl hitps:/ft.co/tuKKESIOO MBSE | wien, ETMarkets FAO data shows WErexit or no Eras, PN may net 23 Jun 2016, meutal slip below 8,000 hrzps:/t.co/uxSUTDakIl By 07:30 - CFST @kshanand hips :/Loo/dIwPISSI4 reneverkroo RI @geerliilderspev: Brilain, loday you can make 23 Jun 2016, positive PY history! 07:30 cesT Independence Day. #Brexit hittps:/jt.co/eCecLTDWO lazer. RT @thchill: Trump on Srexit: "I dond€™t think 23 Jun 2016. 5280 positive anybody shoud listen ta me” 07:30 CEST hllps-/11.00feLLSP2CHE hllps: Leaf Due nikZW Ki mbelido RI @Loyolateon: Andilisis del Prof. @racarfloen la 23 Jun 2016, Espafiza 4 | neutral Sermana Econdmica: el Brexit 07:20 CEST itp. ff.cafO17¥ 2130p Sanesusfende Puro to | aok Past PMI Data with “Mrexit* Worries at 23 Jun 2016, © | positive om the Forefront htps:/jt.cof ia Lrplol 07:30 cost hanshafner Yes! can'l wail lo nol have Lo lislen Lo your Listed 23 Jun 2016, Berlin, © | positive: rants in the European Parliament. Please leavel: 07:30. CEST German relly: co/DeAO HIM v m_barisione RI @I ranievollmer: #irext: | else ten britischer 23 Jun 2016, milano 1 | negative: Zeitungen ars heutigen Referencumstag, V.a 07:30 CEST & Boulevardblntzar werben Fir Flutie. hpi fenova, italy Usangarisp Rerain or Leave? Today is the day buk Sbrexit 23Jun 2016, CYPRUS © | negative: england feu HEUreferendur https jt cof pFrck0Bp 07:30 CEST _ Nicosia Or Esai @Forelyarti SETegid alguien puede explicanme | 23 lan 2016, marsella negative @ UAE: pasa? Aqui solo hablan de futbol y brexit, 07-30 - CLSI Debs ce los pirineos no hay nada. Gracias! Sophiesweb RT @WizeVieAnimalo: @sandralacgel @AimsStalas 23 10m 201, rege 33 @Saphiesweb33 @ManamNarazie @Capeheritiamie 07.30 - CFST #isisAREN uslirs #Brexit #VotcLeave #Remain hide Dagmartivd "Rasismen sor jag mAfUe skrasmde mig" 23)un 2016, GAflch negative er @hahelena:s kehika via @sutnyneter 07:30. CEST org hitps:/ft.cofYeqSaDHAny eErevic mbI038A _ hitpsi//t.co/WiQTSotLL7 ACitzenRadio (2016/06/23) 23 Jun 2016, DE T [negative Choose Your Crm Adventure, WYPD treating inar 07.30 - CFT infractions like erimes of the century, §€} Pennyaisel #Piosenkanadeih> 25 n2006, Warses of na 57 https: ff. cof 2ubcdgTex 0730. CEST wa, #Brexil. Polska Weasterreira Breit AK nova tantativa BrtAenica de flexbiizar 23 Jun 2016, posite ml comunidad europea hitpsiffLeofobD vv 07:30 - CLS1 Detonrlitic BREXIT: 111E UK DECIDES 23 kun 2016, Odds for negative s 07:30. CEST every Get 4/1 Remain ar 10/1 1 save whan you join Detar candida te: 8 https: /r.cofMKIRIOPFAm #EURet https:/t.cofRRALKD WOGUESma RT @heaudetstephans: #Broat or rot bresit? nor 23 Jun 2015, negate © out 2 Teles san les cuestions du jour! Fela 07.30 CPST eADponse ne sera pas sans consACiquence surd€ | DavidRobl @Brexil AValcRermain AVuleRarain 2S\rongurin TE hn 2005, Berk Tegative nson https: ft.cofV uBiDKSa 07:47 CEST oe aharofiucd RT @ZampiariChiara: A pocha ors da vot Aluncker 23 Jun 2016, positive 1 awverte: "luorl &° [uart” 07.47 ces #Euro buracradia /INACCIA i popolo! ate! ee exit hrapsat west ham AT @noblearti6: n a nutshell rest Wotel eave 23 JUn2016, Frsex positive mad hilps:f/Loo/ZASN 6iGSDI 07:47 CCST W_Reimeh Sung [Ar den [ug brexil 25 Jun 2016, Berlin T [positive hitps:/ft.co/PVIDIKETWD 07:47 - CEST tormanolla AT @jimmydelittiel: Merkel comes out in support of 23 Jun 2016, 1 | positive nd Brexit YOIE LEAVE hilps:ffLco/ySvWaWunoa 07:47 - CESI UtterCuatse RI @davidschnelder: Drexi atest. After John Barnes. 23 kun 2016, Manche 35 | negate h yesterday, 100 Nai scientists hava just rung Sky News 07:47 CEST star 1a tay Gave gat i wrong, jeanclaure RT @KimJongUnique: Fn cas de #Rrexit, Halland sera 23 Jun 2016, 13 | neutral “inflexible” selon Maczon, Comme avec LifDanarda, 07:47 CIST Wiarines, les antits... aps: fjt.co/ GAC, rauban ad ft the UK votes against the EU then the PAI most likely 23 Jun 2016, © | negative la will resign, Voting starts right now in LIK. #Brexit 07°47 - CSI @AJENews https: //t.co/MBKinVjBEU Arissturtle RT @zjplus: London's mayor Sadiq Khan crushed a 230n 2006. Albugue Tezative recane Hiresit debate A€” while Fasting 07.47 CST rae, na ic drop, please. hllps-f/LoofeNsjN mer Q ruddiantosu Pabiikan Glomotii Ceras Hadapi Brexil 23 Jun 2016, LKI negative ara) https:/t cojzsiFgksH Havel 07:47 CEST _takarta bulos RT @WTaylorCanfisld: The latest Global Nas Fecdl 23 Jun 2015, Souther neutral itp. {f1.ca/aG Hen MEPN bres: ured 07.47 CPST Califor BrigiteGior Be careful Le brexit fara cA Siiver 13 GB jusau au 25 Jun 2016, hezative gio pA nord, el une pluie de haricols rouges s'aballra 07-47 - CLS1 jus AeA "urement manipulation SiatersonCh RT @benkalcher It won't oe easy, hel i may ven 25 Jun 2016, UNITED neutral is look esa ristake ot fir, but lots be bras. lePs all 07.47 -CFST STATES June 23 independence day. #3€ Tresnzeane LIVE Leave or Remain: UK votes in EU referendum 23 Jon 2016, New negative ws Bllpsf/1co/NAGMWLHTDM hips (Lo I0PIB21, 07°47 -CLSI Delhi the_AndyG uneven Brith, pel Ir nervous/excied loser the 23 Jun 2016, Chicago negative result of the Brexit vate. HUGE vote 07:47 - CEST Bitcainiad _ Bitcoin Trades Lie Gold as Investors eck Brant 23 Jun 2016, London neutral Ieciges: Chart hitos:ft.<o/oP g7LIPTs Bbiteoin 07.47 cesT seryito news sar-iashahb RT @iar-sr: | ¢ hs rend in News where leaving of 23 Jun 2015, positive ams someone or something is headlined as Rexit ar 07:07 - CEST Brel So if eave irorr sur-where am 13€} Weshally The whole brexit things wan born by hates and racist 23 Jun 2036, In and negative British people! 08:01-CEST around the world nasosgrige RT GINTHENGWAT: ¥BREATT and Donald Trump are 23 Jun 2015, TWeid] neutral actually the same thing 08.04 -CFST Pini] fish via GANOWRT zie. tps. fft. frp RKNE CamilleDor RT @Slatefr: AsRemainfish on Rul eausfs, IFurGpe sa 23 Jun 2016, neutral devoir se buuger hls co/SbpSOvaaHS. 080s cost Foon RI @UmaCharioews: U5 RBrexi Ure. 23 1n 2016, Jersey 5 [pote nston #Choosewisely 08:01 CEST City, NI Laughs courtesy of glohnOlver @Lastweekl night https: ft. cof ejerlECty Wauricehe Iwoners ullen verdecld Gir, orgeachtde ulsiag 23 Jn 2016, Raslofar Tegative or 08.04 -CFST endsvee To brexit or not o breait: wal je oct welen fia n @NOS hitps:/ ft cofynECIKed30 JesucriTe6s RT @incigndeVerdiad: Kips 23 Jun 2016, positive 7440 Rerin 39% 08.04 CLs) Leave 51% &vatel eave Brent Tillyhoyrme] PLLASL PLLASL PLLASL VOTL 1OUAY DONT SAY TOUR 25 ln 2016, LCT postive 75 OTE TO LEAVE AND DONT VOTE MAKE THE EFFORT 08:01 - CEST BOVII: 10 SAVE THE UK [a ERRFXIT hte t.cofal NET? british fasci ll those in FU tap jobs are Jaws or hard ine eftjright 23 Jn 2016, Frgland, © | positive w Jewish servants. 0808 COST United Brest Wateleave https ft cojDLuxenV2pi Kingda SmSwers ne EUG HIRE” EAE GRRE SSS kee 23 1un 2016, © | neutral ws Sogr SIESSAINE SINT STVEE,2ENE aay. 05:01 - CEST COT VATA, FRAY 5 SAE, AFAEICHTA AC in §oERR iE, EL CFPIATL En go dL EEE ER AIA Uke, E5e hier ESTs in HERAT "5,0 hp {11 c0f6ifl Baca nsmersNews Recordingli https: cor iC525g0nd 23 Jn 2016, the [3 ht 0604 CLS1 sound booth FdNewspap RT @News_In_Essex EU referendum 2016 lve: Essex 23 Jun 2006, United 1] negative ers Voters head to paling stations fo... After manthsof DR.04-CFST Kingda campaignin... Htps:/t.cofr2GIcvMAE] m PRI “Brit supporters ar appealing lo the UK's curry 23 Jun 2016, © positive lovers to win Thursday's referendur. 08:04 - CEST hUpsL00/<tOVAHATA hp fLooful La 1sbHuwe Waketezs RI @aonbobordah hitps://t co/kPGSARD CaRdas 23 Jun 2016, 3 | negative mercados financieros Acitimas seianas no slo 08:01 - CEST Breit. mercados sobravalarados, infiados pode. mattiewietz Wie doen even een Ares] Tot 09.00 uur geen Adele, 23 JnJD16, Neder 0 | neural e One Dircction, Ed Sheeran, Ellie Goulding, Coldplay, 08:04 CEST nd Jessie L... ttps://t.co/YKQUSZSKGA Biviaw Brexitcer fims himself ilgally crossing Channel with 23 Jun 2016, West negative migrants 08.04-CFST Nidiand hips: colSORKLOH siWorce stershic FiLconard UK Trends... ¥Brent or Brean 7 he financial folk 23 Jun 2016, NZ eg we say no | What do you say & why ? 08:01 - CEST Sundaybusin _#Brexit Today voters have a chance Eo reject the most | 23 Jun 2016, Dublin negative ass heinaus campaign ever ran in Britain, writes, 08.04-CFST city, @susanokecfc hitps://t.co/QZESGc0D Ireland a Colurmin @martinvisser Grootschalise Brite chartsge 23 Jun 2016, fegative van bevolking Europa. Laat 1e vertrekken’ 08:04 - CEST hips //Loo/Lowjilbnaq Kérexit pana brentARAnestyspRIvAL. Olin ime vikoll 23 Jn 2016, Hiebink negative Lontaossa ja aihe alkoi iinnostas, koska se tunki 08:01 - CEST Kaikkalta. Talvon, extefent irtaudu. Rinnsy 46 AT @1u4ma: 80% af Americans believe rtain the 23 Jun 2016, |incalns. positive world would have a better future with SREXT 08:04 CCST hire England hp fLoofudtinzKUs hits L col iba 7eiE r_andreyG RT @lentaruciiicial: SYDRNEDRORAE Brent 25 Jun 2015, negative 3 RERUN, STDYDLIE LE DRT 08:2 - CST DUD BADRD’ DeDREDUD https://t.co/E672hk3acX hitps://1.co/BsFLM7NSC Gharlotiell RT @LisaHenegauwen: ¢EU laws stip Britain of ts 23 Jn 2016, positive 207 Waza Carta rights, don't let Elrulers ake ibertles 08 22 - Cts with history. dvoreleave Sbrexit NESE. VanOberg rec 234m I016, Soest, negative Him, Arch und Zwirn! oh fAunde cs schr schade 08:22 CCST Deutsch wenn sie austreten, aber wenn sind sie selbst schuld! land Gwatkinso RT @briishbulybee: Demolished: The four biglies 23 Jun 2016, 15 [negative n told by the Rerain campaign https: ft. cofibNirolSary _ 08:22 - CEST SoraRtwets RT @USATODAY: FBRENKING Voting begins on Brent | 23 Jn 2016, Washing negative referendum: Will the UK stay in the LUT 0822 CLST ton, DC hutps:/ ft. co/hoRkttasRi Super_Cya @Paulbernal UK has anyone evan spoke about what 25 Jun 2006, negative n Ere would rman for aur surveillance ws? 0827 cFsT ParisFrance Nigel Farage refuses to apalogise for ‘Breaking Point’ 23 Jun 2016, Paris. neutral News posterin final pitch Lo voters 0822 cost hitpe:/ft.cofTLNKSIHGD HGisogleNlerts SebShearer Really interesting coverage on Sky 310 @ectvnaws 23 Jn 2016, poste too, @skyNews @BBCNews @euronews #LURel 08:22 - CLSI #EUretarendum sbrexit #Voteleave Francaid fr Brexit es Brita nmiques se prononcent sur ar Tan BIE, Fark © reutal maiintien dans TUF hitps: 2 cofrcd a3) 0827 CFT https:f{t.co/HSoayPISP LSMusic202 RT @ChargerGros2: Arex lps://Leo/hecOIME2le 23 Jun 2016, United 5 | neutral a 05:22 CEST States Tuarajaness DCOLOROINGE 25 Jun 2016, 0b negative a DEREORFRAYDKDKRYRYLD REPKE Dy RD? -CFST eDERYR” fioB 04040" BIFLIOAB RED NDI" BDL 8.676 DyficouR Dy BYAFA, 000° 62 Brexit Dose hitlps-f/LoofULVSAHENS fen fe Spacekwest RI @Davidloh2951945: RI | was at the polling booth 23 Jun 2016, Concife positive for Tar to vote to LEAVE th EU ster years of waiting 08:22 CEST rgeloge/ (ue a pen) #Brexit Hivated htpae] bezemk ast never_cverS Will you stay or will you leave? That's the question, 23 Jun 2016. positive n Goad marning, Britain! fEraxic 08:22 - cesT Maz saroth RT @iarvmillard: Major leak from Brusselsreveals 23 Jun 2016, neural NHS will be JE KILLED OFF" if Britain remains in 0822 - CLSI the EU"BVoteLaave PEUrst #rtoday hitpss JESS_AR_BS A snapshot of the VERY balanced BREXTT research K53 23 Jun 2016, pote students hae undertaken inthe build up this 0827 -CFsT historic day. https:/{t oo/DyKASeXazy Wasler2001 RT @TrisleMiclitore: Moneta propria, unild di 230un 2016, Marche neutral EY misura, guida divers: onestamente nan ho ai 08:22 CEST - Italy percpilo la Gran Brelagew dentro FUL. Krexil GNOpinlon Gulf eas lead editorial britain should vote ta stay 23 Jun 2016, neutral in the #EU hitps:/jt.cofEVnoBMAGF #EUreferendum 08:22 - CEST erent int. feeling british today! 531m 3616, Nordrhe negative 0822 COST in ebraxit Westtal SantosSaine RI @1R_Conversalion 8brexit, une affaire Dreyfus. 23 un 2016, Bordeau neutral w A anglaise, par Benjamin BAccle #EUrat 08:30 CEST 3, https. //1.00/CRwI1 w0] https: ft.co/I 60S] INalq Trance: asudb AT @rendincontent. FU referendum. Fal ComRes 23 ln 2016, Alabam negative poll shows large lead for Remain bert 08:33 COST a https:/f1.cofxxdSwkBidv https://t. co/QFXIp223GR Sgtlovejoy RT @Reuters_co_jp: ice, 23Jun2016, afeEf0E 104 | negative FR Sg FP Be PEA J ET RTI 73 ARCA o 5, ERVICES ech 2NLT* 30-510 3 B35 3/304 3 20 - i UIE TES J SHERS, SRE YST ST WHEE Wtpsi/teofwASYSRMZIW Brexit https:it co/sKEAUpNLqe dsonpelitics Vote duly cast for #leave let's take this chance! 23Jun 2016. Oxford positive ref Brevi fhe eave Motel eave 0839 CPST SeputartradiOBLIGAS| FASS Kembali Hijau Saat Pasar Tungzn 230m 2016, Salo neutral ngs Referendum Brexil hitps://Loof8iWq LdHRI 08-39 CLST raga RI @yannthompson: bred lestbienti Thi, 23 Jun20l6, Pawnee negative ouverture das bureaux de vete dans 10 minutes 08:30. CEST - Ferm eture 13h plus ard | hiips:/jt.cofwSAcse | Serato _ n brace Wor-cnDefy RT @suevencer: Jeff Witchell's best photograph: 23 Jun 2016. neutral uk 4€"These people have baen betrayed by Ukipa€™ 08:20 - CEST Hitps. ff1.00/SN Twssmevs hughriminto Can vou pass the hrsxit fest? 231m 2016, Sydney, negative n 1 must have been pays attention because | gol Sout 08:33 COST Australi of § correct. https://t.co/FrZredcd a who2stu RT @lisaHenegauwen: The ¥EU is. sinking ship what 23 Jun 2016, positive we have to abandon 08-39 - LSI Reclai your sovereignty before its 00 late! snot dbresit https se DemoGrazzi RT @Trev_Forrester: Save these Islands from 23 Jun 2016. 127 | neutral domination by a orsign povier rest 08:39 - CPST htlps:f/LoofFlermveyile eshazeloa RI @DalyW alUK: The four ig Tes Wid by Te Remain 23 Jan 2016, 3 [regi reer campaign https; tof SULGWHEXU 08:30. -cesT https /t.cofyl j05)isbe Woatetsda rent 23102016, Manche © | negatiee I 08:39 - CEST ster, Frgiand ES_investiga RT @busybuk: Waming when you ga to Vote an 231un2016, Inyeur 167 | negative lor Thursday lake cither 2 permanent marker or a Pen 08:39 CLST head with you to Vote in this Referendum PLEASE RETSE | emilyr_willi genuinely scared #Brexit might win 23Jun201€, London negative ams 0839 - CEs Seun7H low isit going? MOREXIT? 23402016, Nigeria negative 08:39 cesT ukipsalford RT @LcaveLUOficial: Tomorrow's @pestononsunday 23 Jun 2016. pendich positive features @PennyMordauntMP, @Nigel_Farage & 08:39 - CEST wry @steveillonx making the ease for Brexil. hllps:3€} sulford ae THirk_Blue__ wish to In In & worldwide street, not a european 231un 2016, London negate sky culdesac EBrext 08.39 - CEST Fearndenni RT @DavicloS 951945: FU depend an the UK market, 23Jun 2016, Monma positive trade deficit was A£23 billion in the EU's favour 08:39 CEST uth JanMarch 2015 WE WILL GET A TRADE DEAL h3¢ | ees RT @LOFenlalour: Donald Wirump sa rend en T1201, France posite itconse en plein vole sur fe Ment 0839 cust https/ft.co/rEmR2x? Joamuimssz @xisraisis sh? di uv 500 8 voto no Brent hn 201E, Fon, | negative auto 0839 CFST _Partugsl brcnaught RT @affensivecuppy: FU wants ta censor the Infamet 23 Jun 2016, Ontario, 2 | positive. ont again? 08:36 COST Canada Frexit MateLaave SLURclerendum #BBCUChle https: /t.co/kT2A00Lmed Gelalande2 RT @tranceinfo: EN DIRECT Abrexit or not fbraxtt, 231un 2016, pat neutral ARbat entre los AADPUTATs suropACens Nicolas 08.56 - CEST sarthe, Bay (FN) 1 Yannick Jaco (LLL) A 7hat sur Hoe nies Joscdeynes Wrexit Abrcmain Abrendt pol Slcave Aromain 25 un 2016, Isabela | neutral hitps:/{t.co/2HntColVADP 0856. CEST PR Sar Jitke RT @V_of_Europe: Faragedt “5 fina rallying cal 23 Jun 2015, neutral AE7I13€7 us versus. the Fatablishment goand vate 08.36 - CFST for Britain hitps:ffL.co/LiRgbPrapE Copariwar Brent: LUrclerendur voling 3ets underway ind UK 23 Jun 2006, neta https:/ft.co/h3Cprbld 08:36 - CEST Svagdls AT @rgenciS7: You know, you want itl 23 Jun 2016, positive Happy Bleave Ebrent ers! 08:56 - CEs Tomorrow this time you'l celebrate! itp. ff1.ca/S TKS 710 HenkPuffel Niosten we bi een Horexdt straks ook halen hearin 23 JunJ016, Harder negative: mans het Kans! goon? 08:36 CEST _wikk Jock Fades] @inforrex212 Resumen dodicado a Nodhidlan ye] 28 hn 2015, U1 Tegalive Acitimo dia antes del BREXIT/BREN AIN: Este es un 08:36 - CEST tartare breve resumen... hUps {foo NXNHUVKTL Teresablckh RI @theordinaryman2: A lstminute plea. #voteleave 23 Jun 2016, South negative m and help change the course of history 08:3 - CEST England near the Voted ALsavel WEroxit bremain HINOrOUT sea httpss€ Gravwnufe RT @WantEnglandBack: Julia Hartley Braver 23100 2016, positive 08:56 - CLS You don't need to trust politicians to vat for Brest Just truss yourself @releprophnens [ey Novinil ERA TR, DP DEKAKPRRA DED, Brent 23 Jn 016, negative 000°020%), 50) flob” 08:36 cst BLOND NTH0'0NFHLD” 0%, sp DXB DD DDUOHD DONDE FLOKD fie hitps:/t.co/ ae NXEBNG TRING Kira REL OTRO SANTUARID: Resumen dedicada 3 un 201E, ditto Tegative Nochivtlan ef Katimo fa antes del 0R36-CFST federal BREXIT/SREN AI: Este 03 un breve .. httpst.co/ReejyrmTG0 Zordie_toss Don tizave, love EU. oteRemain FEUTer fret 23 Jn 2016, neutral #orislohnison ANicolasturgeun dig Farage 08-26 CLS “Guardian #DaiyW ail arian RT @UKIPNFRN: UK would be bonkers to leave EU, 23 Jun 2016, neutral alla cay Michael Maars 08.36 -CFST strongerIN Hotell HFUref HINarOUT #iNTogether Breil itp. cfu. | Na_No_Coc. Because infographics really do hald the ke 10 23102016, Landon negative o everything.. ast rinuls Breil summary for you 08:36 CCST @VioteRemain hitps://t cofilaRICi5L FredSimonE Sa what next? After Brexit: Roadap for a leapin the 23 Jun2016, Brussels negative u dark EurActiv hips /ftcofeatiMILsy 836 -Cs| Belgium Tatiordysh Everyone's entitled to thr ow opinion on brat bul 25 Jun 3016, postive Ey wih does the leave support look fie a bad season of DA.36 - CFST celel big brother? ACurel Wah Rl @marcosalvali: Nessun uomo A un ola, 3 Jun 2016, Tatra cormpleto in se stesso; ogni uomo A” un pezza cel 08:36 - CEST continente, una parte del tuto. (0. Dann 1621)3€1 Jackandstell The Brexit poll are too close to call, which means the 23 Jun 2046, Australi negative N UK will vote S€osremain€e hits: fcofprialulTd 0836 -CFST a via Gaz SEATpA RT @IndiaNoles: lradebice india: Zn 2015, ewan 32 neutral httpe:/ft.co/FZTUSPOFuk Sensex, Nifty apen Fae 08:36 - CEST ahead of Breit vole; ala Wolors gains 23 Jun 2016 rosswilares @vladsten @kimenezgarcia if UK votes Brextget 23 Jun 2016, Landon © positive a Your spare room reacly cause I'm coming to lve with 09:13 - CEST vou revistacosta RT @Qsrescar: HI ACAFFTFRAPapaCusntameGTrates 23 Jun 2016, 1 | positive bi Da gusto ver los medios corr donuncian los 02:13 cost corruptos, antes Gibraltar shara Breit. hitps://t3€. VarboughBu RT @nytimesworl: On Twitter, even cats (and dogs] 23 Jun 2016, 37 [ postve ‘ are getting into the ‘Breit debate, 0813s hitps:/{t.co/BELi3nrk2! bps //t co/C7dNdNIear TanG07X00 RT @politicsHour: Should the UK remain a member of | 23 Jun 2015, _ South revtal 7 the FU or eave the FU? #rexit AFUReferendum 09.13 CFST West, England Sunfeubing RT @TheSun: Make history belicee in yourself our 23 Jn 2016, Santa positive countrya€™s greatness vote LEAVE 09:13 CEST Barbara hips /1Loo/ LgHNAG ve eure Galiiorni hitps:/t.co/Qni6AOzmY a Dr_Lucie RT @lennyRohn: In case youre stl undecided Zn 2005, UK negative @stephen Curry on Blood and Drexic 09.13 CST https: cojir plal WAFPA€ | Sguardiansciblog #EUreterencum HOUSE_OVERSIGHT_01120¢ Shscusnan RT @V_of_Europe: Cameron redfaced afer German 231un 2016, _Sauth neutral o ufficiul says Brussels WILL trade with Britain after 0915 CLST Lust Brexit pivoted htps:/t.cof1yOrUomb England. Batzhavabin IV BRIDE ME Fil, LL + WIE FITC 23 Jn 2016, Tole] posting bis erent 11 ALL Id LRT 0013 crs geist LHL, FDL Ti21. Di Tosie FP: 2 Ey | aveFurape hips: cof 15ybQuKPsm Tgadude RT @POLTICOFuope: 7 signs that Mere i really 23 Jun 2016, here negative happening hitps://Loofig B4AWGO 09:13 CLSt hitps:/ft.co/OpVOLTOV Sndyilackne RT @Christanityag: 12 perfect songs or your 25302016, Londen negative ] Bret or Alem in worship sett 09.13 CEST https fLoo/NaYevwS2ZHS kL Ureferendum https://t.co/GoBusE Segraiasioni RT @pin_upicierno: Bruallas minaccia gf ingles. 251un 2016, Sasear negative ss 0313 CEST Sarden "Se uscite dall Europa starcte molto regio!” a are, Ihe _sludkki Lverylhing You Nevd |o Knuw Aboul Brexil: Hello 23 un 2016, Gurgaon positive: ng Traders, Ue have ban getting lots ofac 09:13 - CEST https //1.00/cKRUMZimBY. Jesabfm RT @ActualidadRT: Comienza la votaciX’n en el Reina 23 Jun 2016, Spain neutral Unico para decidir s seguir] o no siendo riembro de 03:13 - CEST 19 UF hetps://t.co/6HORXT7Upe https nd RT @afceras: quindi par ¥Waddel la Arent X- come 1 23 Jn 301E, T[regative #referendur di ollobre... che si perda o si vines A 09°13 CLST ugusle, restiame, #orrnibusla? ferendus. Si pl Brexit fuera en Fspaea en la papeleta de 234un2016, httpffa © | neutral Aragh'n se verka “s, perc polhaba” y “hemos de. 03:13 - CEST bout.me salir”. Paralos foranas: es noy eX. fferand Ura RI @p_corradini: Loge a Gran Brolagna polrebbe 23 Jun 2016, 1 | negative sancire a fine della UE. Lora che hanno sempre fatta 09:13 - CEST core c..o gli pareva. Arexit paultisperl RI @Dani lannaniIER: bly three minute Siredt pitch, 23 Jun 2016, 182 | neutral 1 via GCN. hitps:/ft coflvbXTvaod 05:13 cesT kermel_sian _ hitps://L.cojqkvOURDVN 23 Jun 2015, Wiedan WA ur 09:13 -CFST Kata, ndones edwards _m RT @W Giff: Right, polls are open, leta€™s GO! 23Jun 2016. Hampsh positive arin rexit Mitel eave Spots ri 09:13 -CFST ire hllps:f/Leo/TapGlarplH vate far Rrexit https:/ft.co/bi7yI4RHXA 00:13 FST ge, UK. Twengway RT B_of Europe: Brexit WONT spark trade war say | 23 Jn 2016, negative Gerrans hugs: #/t cof 10yG3udy 0930 CLs ibnzloril RI @rorybroor-field: Let's make the SUK free again] 23 Jun 2016, Allahuac positive #oteleave PErait PEURet 03:30 CEST _k Bar CrustyDines RT @westerndofence: Today, we §0t choose again 23 Jun 2015, Naw postive aur whether we want. ta be free. HRrexic 0930-CFST Nialden hllps:/fLcoful50LbEE. Surrey FundStrateg Lxchasive: Brexil fears? UK equily managers cul UK 23 Jun 2016, London, negative ¥ stacks to lowest in three years 09:30-CEST UK https /f.oafl W2VPxvYal Jeroen RI @ooohouchbun: lady sthe last chance the UK 23 fun 2016, posithe. will get to fly fre from the fascist European Union. 03:30 - CEST. rexit, Relieve Vote pave hips: /3€. OhSaNicalle RT @lessFspinX: don't be foaled, Rrexitis NOT the. 23 Jun 2016, negative. snsueer, WVOTLALMAIN @VOTCIN 0830 cost hitps:fit.co/GK1EAZEDob Grassy Knol AT @onatokebloke: Dona {Have you PEFEx TEIn 2016, Atoad posting ' hip. f1.cafsl0BTCE2S. 0930-CFST tube in sector Er denizeni2 AT @efarpad: lg Breit Ta FAL, fir aL 23 um 2016, negative Til Te 0330 - Cis TTA Te Grete, Le 19020 Tif, Tt 1,1 ToL. iel. #syriza_rmalikes mark248235 RT @Gjon777: Jacob ReesMogs on Osborne's Brexil 23Jun 2016. UK Hull neutral a7 Budget 13062016: https://t.ca/YUYTRVWCHY via 09:30 - CEST @oulube sadiejorrett RI @Benjominfamesls Funny how many Welsh 23 Jun 2016, Cardiff, positive people | ses posting #TogatherStrongar when it comes 03:30 - CEST Wales ta foothall yet they dont see that far the bie] terraceblun EVatel eave Hiirexit https:/ft.coMoRRwetd0) 23 Jun 2016, positive 1886 03:30 cost SpulnikiNew #Brexil ABroxiti Brexil ABroxils BroxiL #BroxilkBroxil 23 Jun 2016, NA 55K raxiciBrexit FErexitirexit FErexithrexit 09:30 - CEST rexel §Brex Bred #Brenil Dubblelren Irending News about https:/ft.cof7ml mkvGSKU 23 Jun 2016, positive. ds Brest Vote 09:30. CEST ubbieTrends. NPORadion To brexit or not fa fbrexit? APORadio! live vanuit 23 kun J016, Hilversy neutral Londen mel @chrkijne en @jorisluyendik: 09:30 CCST m, The hitps:/t.co/DL QUST hep: 1. cofiAMteOmsm TY Nether! ands jobruria el rex 88217, altres qRfestions na menors 23 Wan 2016, Sabadell negative ttps:t.co/SToLQPrsbj 09:30 CEST Sugentes Para no perderse nada del rferkOndum brikinico, 6 23 Jun 2016, regi enuiva de @elmundaes hitps://1.co/Xrazg3all 04:30 - CFST @maria_hdez @anabarrio Thibautlal #Brexil or not #Brexil thal is the question. 23 Jun 2016, Versaille neutral hiey 09:30 CEST 5 Stafanmach RT @BosddngD: Remain or leave? In UBahniaggon 23 Jun 2016, 38.4466 posite ue S828 it dh Stiemungsbild cum Arex eindeuliy: 0930 -€LSI 31, hitps:/ft.co/ZDICXRD 9.10279 5 Finarlinks 3 Raiffeisen: DrexitReferendur, Solar City, Tesla 23 Jun 2016, neutral Wiotors und Stzatsanlcihon im Blickpunkt: Dasd€] 03:30 CEST https: ft.coSTRrNTAMY ess 37 AINVESTORS DavifTrevor Cast of ving wil FALL ance we BREXT 730m 2016, T[reutral » hllps/fLofikiimaHhRL 0330 cust beomininvisi RI @Owenlonessd; bret happens, we will face the 23 Jun 2016, In my 153 | negative ble fights of our ives and we have to prepare. My video: 08:17 - CEST bed, tps. 1.00/251390Lw itpsie | Twestin andyknor2 RT @V_ol Europe: Cameron redfaced after Gorman 28 un 2006, uk 267 | neutral official ays Brussels WILL trade with Britain after 03:17 - CEST Brest Bioted hips cofdyOrUombe, iphone mr RT @Daviclo$ 851945: AT | was. at the palling booth 23 Jun 2016, The Fad 380 | positive for Tar to vote to LEAVE the EU after years of waiting 09:47 CEST of the {use a pen) #Brexit vated pac] vari wendyekna RT @Multi_Ling Mat: Hold your tongues: why 23 Jun 2016, 5 | negative w language learners fear vote for Abril 0947 cis https:/t. cof 3CMRABHE Seureterendum abllinzualism 53€] GraduatesC In gran Bretagna, nella glormata di oggl, voter il 23 4un 2016, © | neural hroni famoso Brexit, ower i Referendum per restarc 0 08:47 - CEST meno... tps: ft cofnOGKn1Vrk awaiiu AT @louisahansch: The Morning Star's socialist 231un2016, Landon, 7 | positive editorial for Vote Leave and Hbrexil 0947 CST UK hetps:/ft. cof 2uig) Warkatia FTSE 100 breaks 6,300 nd pound hits 2016 high ss 23Jun 2016, Londen posting we Brest vote gets underway htas:/ftcofQTV24Tram 09.47 - CEST @Telegraph Chiara_sahi Wi i nota di pA 56 resto ma sta in dsparte, a 3¢ re 23 hun 2005, negative nevada? MBresit 05:47 CPST Torysaaa. @Arekilliacer Niamey 11k dy wistystiis 23 Jun 2016, hegative waruni s ABrexiL Lo byAby din prysenic, Bid 0347-51 moAiie inne kraje teh zacandi. wychodaiAT jel UK Warkiswin RT ©madeupstats: Tris accounts been auistfor a 23 Jun 2016, tanche E [negative while, but due tothe fact that the react campaign 09.47 CEST tar, UK have stolen a lot of our material, wee GordonGekk RT @WSl: BroxiL vole: what lo walch as the UK goes 23 hun 2015, wall 1 | neutral 0 101 ta the polls htp/t.co/NHPETXw. 05:47 CEST _ Strat Wealth Ver Pound, euro higher aheacl of Brexit vote Morextrader | 23 Jun 201, _Singapa poste tex &larexnew Atrading awealthivertex vaar-ast re Hitps.fftcofIUataPssh SuelngSiom What daes this ACTUAL MEP say about Breve. ANUS 23 kan 2016, High negative ons watch especially if youre stil undorided. 03:47 CEST Wycom https: ft.cofpBVToCraW be, UK WaryKapadi RT @theordinaryrand: The #EU bans the word 23 Jn 2016, Leiceste negative a iret? a7 ast on England EUReferendum #leavetl AVoteLeave #Strongerhn #InDrOut ALabourlnForSritain https:f/ti€ | chances%3 RT @labourleave: The polls arc open Get ow: and uss 23 Jun 2046, ONTHER 184 | positive Your vate ta help us crest an independent Britain. 09:47 - CFST FGISTFR Breil ALU hips //Lco/hBLEUASE] WeScopols RI @Davidios2451945; YOUR COUNIRY NLLUS YOU 23 Jun 2016, 217 | positive: min TQ VOTE LEAVE TODAY #Bresit 09:47 - CEST hits t.ca/Q0rATVI highgateale RT @Davidio$7951945: AT if you hae voted to FAVE 23 4un 2016, Landon a3 | positive x Uhe LU Luday AvoLed #Bresil ft recdom 0347 CLs hitps//t.co/sSIKBNKAE BWoulhR Rain and thunder in Brexit land. 25102016, United negative Don't et ry people fol 09.47 CEST Kingda #strongerin. demain m aul RI @arelheilrusller: Whatever your views on #0rexl 23 Jun 2016, London positive the biggest sin you can commit today is not ta vets. 08:17 - CEST Democracy Is fragile and a gift. PierTosa Dear UK, withaut the “Feer coser union’ you cing 23 Jun2016, Midena, negative away, with no regrets. #Brexit ABrexitOrNiot 0347 CEST Maly Krangneslar RT @Quoen_UK: David Buckhar is backing remain. 23 Jun 2016, Stockhol negative s This is mainly because he can't spell Srexit. #EUrel 10:08 CEST m, Swern Leanomy Wr Brexit vote 'woukl mean a UK recession’ 20n 2016, United negative id hitps:/t.co/\WaZaV0320i httpsiit cofsalgvauc?d 10:01 CEST States WIOB_BLATT "Brext'Gefahr verunsicher: fast jedes zweite. 23 Jun 2015, Wolksbu negative deutsche Unterneir-en hits: cofrbeucGriI 10.04 -CFST rg Wonalisrel RT @florianeder: Sorry und ute Reise: Mit Respekt 23 Jan 2016, 7 | negative i und Bedauem”, so wilde dic LU aul den #rol. 10:08 CST reagieren. https.://1.coWWCIKiEM2D Catarinagall RT @Alasdairdl: #EURef ABrexic 23 Jn 2016, Nether! negative 9 1008-CEST ands UK "expats" moaning about immigrants. OH THE IRONY! Got a check to roan about "changing our ways. hips Ukiphoh AT @WAFEFUK REREXIT DAYS BRESU_RWAFEF UK 23 Jn 2016, | revtral tps. /1.ca/TTafsForul) 10.04 - CPST IGuerrerol RI @plalanda 11: Dinvensifién dela inversid®n bruta de 23 Jun 2016, Mackid 3 | neutral anco UK en CspaAza y stock de cmplco correspondiente 10:04 COST (Spaint Breit {Flaborado por SIF https: /3¢ velvarsik Brexit have grabbed all the headlines and stooped 23.Jun 2016, England, © positive despicably low, & vote for Leave is aligning with 1006-CESI United extremists, with people without a plan. Kingda n Vivianstarrry RT @theordinarymana: Its your decision 2 23 Jun 2016, a positive 1006 cust Lie for IN Retueet for $0UT FURR! rel eave SRrent AeteRerain ARO #Labour #ValcOUT hae. HewsSprinkd RT @indupendent: When he CU referendum resull 23 Jun 2016, Winterl 18 | neutral es will be announced hitps:fjt.cofSKWNOHANGA 1004 CEST ell StevenDows _#Brexitor nat, your business must be prepared for | 23 Jun 2016, Frankiur © neutral ansD any possible utcom hisps: 41. cof bvANQAX 1004 -CFST 1, #Qrscietm bint] Geran Y OomCaldero fcc 3€ Brexita™: las ASlimas encuestas y las claves 234un 2016, Costa © negative n del referRindurr hps:f/t.oo/tWesDhdLep 1008-CEST Rica teddybearis RT @Steven ala. Jeremy Corbyn makes the case for 23 Jun 2016, a the 2 | neutral ms Brexit EU referendum 2016 hitpsiit cofUgaTHefvOa 10:04 CEST pubs, via @¥ouTube naw ase off. Onista_Ne Der Freitag nach der #BrexitReferendum cleft 231un 2016, Frankiur © | negative ws Kein normaler Handelstag werden nicht nur [AK 1004- CEST Lar BAfrsianer in London htps:/t.co/aXzF8TPrYs tain, German ¥ iethabol7 Wore than 40% of fortune 500 companies were 25 Jn 2005. Pyongys postive starteci by irmigrants and chidren of immigrants. 10:04 -CFST ng, Aracing stat hey . Brox forth Korea Giokyn Bundesregierung vor dam Brext: Klappe 2 und durch: 23 Jun 2016, negative {taw.de] Berlin hat Angst davor, dass die brten die 10.04 - CEST EUse! httpsit.co/ARGhuBCIM WizevieAn RT @wiide_nicholes: @jercmycorbyn you vated to 25 Jun 2016, Comal 1 neutral malo dissolve the UK. Luckily you wil never get fo Number 10:04 -CFST | 10. wBresit Alabour AHS dmomentum flinlpost #BrexlOMol: No turning back’, #LU leaders wam 23 Jun 2016, © | negative #Britain from 3 vote to quit. Follow live: 1001 - CEST tps £1t.c0/JOKCHrtde htps:fft coh Ces Peterllaies @the mehran @terlINTAO Wht dd the flomans. 23 Jun 2016, 0 negative au ever do for us? Don't we all know where this Breit 10:04 - CEST came from? Rampant antiflusim xenaphobia? Tiayd_fisn RT @RT_com: WATCH LIVE: #Brext referendum 73 1n 2016, Calgary neutral underway in UK hlps:f/LcofaDUKPWwall 1006 COST Wounl https/ft.co/YhrhbeeeDC Royal U Kai¥ugals RT @BobEstropaio; AACA Mo va airse Gibraltar de 23 Jun 2016, negative 1a Uni&2n Europea sin preguntar a resto de 1021 CEST espubtoliorees 1? #Bresic Tory_anthp RT @Daiy_Express: Britain CANT tackle mass 23 Jun 2016, negative immigration unless we QUIT LU loday, Broil MP says 10:21 CCST Eure htipsy/t.co/yQNa0ETW https:/jt.cac! Tike_space RT @josedeynes: Poundsc Day of Destiny Arve: as 23 Jun 201€, Pusrio [negative a» History Shows hati °s Possible W211 ico, hitps:/ft.co/2¥TrwUKyol via @business ABret usa doremain #le3e] conehacom RT @ciarvilrussn: oy exo dsl Brexie. Una no, dos. 23 Jun 2016, Madrid 2 | negative so ContracrAnicas al efecto. https://t.colrmVDamzlre | 10:21 CEST hips: ft. ca/fyGhiyedent hips: (/1s¢ | SADorman AT @londonDynaslaw: | 3m 3 Tary Furascaptic 300m 2016, Edimbur negative Remain voter. rex is simply ral anintellgenl 1021 CUST gh, choice atthe moment. hitps:/jt o/OCsDSbbaE | Scatland Rogers RT @RobertoFioreN: MBrestc per | Europa della pace 23 Jun 2016, negative W della ibert. Uscire dalla ¥Ue dei ricatt, delfusurn 10.21 - CEST © adv, periino del omicd€} Douglas Ni RT @TravelorAU: What the Breil could mean for 23 Jun 2016, _ Stockhol neutral sson travallers to the UK and Europe 1021-CEST m, hits f71.0ofuEXVVPeGa Sweden, Earth Charizdog RT @KevimAnth SMASHED FQUR BIG UES TOLD BY 23 Jun 2005, CHGUS Tetra REMAIN CAWPAIGN hetps://t.co/PanuNiyRal 10:21- CEST Hoot Breil vote eave Kole Leave dStrongerln Luropea Biancherila RT @nausicalibre: hteps/tco/35Vuaknj Les 231un 2016, Annona negative wa tars technocrates LRPS de 'UE, font un llen entre 1021+ CEST “Brent et es nazil=> Provoquer fa paurd€ Rhine: Apes. annembes AT @1esversOfPawer: Walkawill Remain speeches.on 23 in 2016, Foland neutral BBCNCws24. Since hey arc TOTALLY irparlial, L guess 10:21 CST Gave, Gisela and Boris are havings€ | France Jeve RT @prcouteaus: RBrextt Un "effet indirect plik? 23 Jan 2016, negative tal De tt faR§ois, oe West pos Fanglais que parlentles 1021 - CES EuropkCens, mais ar Aricain hitps:3€ Parthian RT @OhBrolenritain: BREXTT BOMBSHELL Poll puts 23 Jun 2016, neutral ave SFVFN POINTS ahea af Remain hours before 10.1 - CFST referendum htipsi/fLoafiLuOrcRG alChiari RI @dragoni La éBresl) Un grows alfarcper gh 23 Jun 2016, negative alibator che potrebbera voler far cradere chasia 10:21 - CEST iA! probabile il Beran Allos://L.d¢ Elisanyebe hat bs this brexit thing 230n 2016, Nigeria neutral 1021 cesT OFXGZ Big day lodey as the UK decides to Brent or 23 Jan 2015, Sydney, negative remain. Don't Forget OFX is apen 24/7 during the. 1021 - CFST #CUReferondum, including wedkends! dsupport Wocklabour RI @1heSan: We speak lo the malionde™ grailers on 23 Jan 2016, babulou neutral the #Brexit frontline before referendum of lifetime 10:21 CEST 5 Sussex Hitps: 1100/1 P¥ahbI RUZ hitps:t.coi€] Dankeferhi @Brexit ADrexitOrNot watching this FU misery i 23 4un 2016, neutral » You're smart u get out! if you want #Dictatorship 1021 cesT Merkel und a Muslim GB stay. Wananick RT @RTenfrancai: fBrext entrainera "apocalypse 23 Jun 2016, Paris neutral Aconormique” selon Grorses ¥Suras, Jacques Sapir 1021 €LST 10 rh Zipond hepsi co JAIN Fst bitasac Kreiznagel RT GV anuslaKC: Wy Braxit Diary: The WBrext ball 25 Jn 2016, [negative rexel @d_buniness hllps//Leo/UDIbeICeT | 1039 CLS Iehorsan RI @larsrki | ¢this trend In News where leasing of 23 Jun 2016, Coma, 335 | positive somaana or somthing is headlined as Rexit ar 10:30. CEST Bangla rest So if eave from surwhere am 136 eh brield3a7 @lestchodl ive un des premiers effets bARAGfiqua 23 1un 2016, © | neutral du Broil sera fe dEpart do KCar-eron 1039 cost Padlinaous RY @chrizugorl_porl Mbriaininout 4goudbyelk 22002016, Geriran 7 | negative tart #Braxit MBrexitOrMot Hivotec ¥iiarkel 10:30 CEST y hulps /1Lcoft wand Roschappell RI #Grexit WANTS US 10 IGNORE EXPERT ADVICE 23 Jun 2016, 0 | neattoe @georgemagnus] @dannyipaimer @timjohnston 89 10:30 - CEST @ScientiniAFl BeskeringS hips. ff cofeucswil GF VilTynidn _ epolitalogi wiaden ehkiin mielenkincaisin priv 23 Jn 7016, © | negative en on Uianiaien, #Bresil ARcmain iSlrongerin 1039 cost #standbyme Toopviax flohnson neartar enije op Brant Hi hecfinog 25 Jon 2016, somewh © [negative Inst wan het Imperium virus! hips ft cofglHVifeby) 10:39 CFST rein via bps ff cof SAMRLITS the milky way Widdietonki RI independent Leave supporters are very 231n 2016, London 14 positive ddie suspicious about the pencils at poling stations 10:30. CEST its. f71.00/ ARAN hips 4 cofre41 C3197] barbycatton RT @lz buckley: Shattere! fram thunder & lightning 23 Jun 2016, a | negative il and worry abou the rronster Bros croaled. | fest ike 1038. COST Vim in a really cheap Frankansta€ worldnewsd © DD EFOHO'DHATAD, | © 040. Redu: 23Jun2016, Russia, © | positive ar UTEIHRLDUE OTiED fL0DAD.D ©, 103-CLST Moscow £30,0°0ulE £00020, fT B30" Di REDRIPDADADHEADHDAN DD, DOH fileB, DuNeDuD%D fox on % Brest hitps./ft.cafad Fuh Wastespeda RT @acksonTOny: Our dear neighbours & frends are 23 Jun 2016, North negative fist saying ‘please remain’. 1039 CST Yorkshir Solt's da just that. We're Astrongerin e tlre hitoss/fLcofL3€! aut the cra RI @cholt 1: SVotel eave SlakebiackCantrol 230n2016, USA, positive pec #TakeControl #Bresit hitps:/jt.co/MOzmYNBLZ 10:33 CEST UK, irae rants really cit think this whole “Tdss al vhavate 23 n2016, UK negative Breit” through, did 12 hilp://Lco/agZF wal) 1038 cost Hay_ Quaker RI @Luds7hed: Gul out & SVolckurmain, Dun'U ignore 23 lun 2016, Hay on negative expert after expart & gamble on Britain's future all for 10:39 CEST Wye, the bi rest consiemain SEE | Wales JohonDIgSMI Si les anglais vote pour I bret vous pensez qua AS 23 kan 2016, Park, negative le va accuser lislam ou pas © 1038 CEST led. France SrefanaVp2 RT @rgencs7: You know, vou want il 25100 2016, posite aa Happy Leave #Bresil vrs! 1039 Cust Tomortou this time youl celebrate! https //t.00/S1KSnl 1210 SHChEIRRIO Gesolgan can EBrexit oar de 7org onduidelif. 231m 2016, Nederla negative or hittps:fit.co/0bFGLLDOPS 10:39 CEST nd Au _opleidi Gevolgen van #BroxiL voor de cor onduideik 22 Jun 2016, negative ng httpe:/ft.co/VRUSInMPa 10:39 - CEST pramodkrra aH *a¥ aH, ai au aHKAN aVaaY, atea¥T anealWa"atE 23 Jun 2016, Haridwa negative wal ante ant dn'Sni GamO¥ aR; hRVON EAT LU 00 0¥E 1039- CLS r BH Sidak'an, akoeal ak Suk ak Bu ax SYean sti wBrexil Arelerendurs hilpsi// Leo Sdiolpswy. J_Manasa @moralmyopia and a lot of rights and things arc 23 Jun 2016. josh_m_ negative: enshrined in EU law and |don't rust the Tories to 10:20 - CEST lea out uphold thern if wee brexit. look co m-Lon Comzolinasal Oedicala s (1 Triet ariel UE. oreo FBrcman 23 0un 3006, Wilana Tezative va hitps:/ft.cofkebgRathz 10:35 - CPST migiario Abren las urnas an Reino Unido paral referenda 23 Jun 2016, negative sobre la UL HULps-//L cof MNWpjsLmm 1056 cust #intarnacionalas WiallGuinn Interesting @Skyllews giving braking news’ satus fo 23 Jun 2016, Dublin posite latest Dons UK population stats showing 500k 10.36 - CFST increase. Surely plays into #Brexit 2 InvestingTR Browil ABD A’ASin Sorun Olmayabilir de Qlabilir de. 23 Jun 2016. neutral hitps:/ft.co/fSTCKHARg! 10:36 - CEST Hoxtantill Pouring with rain but asa bailing, clear the 23 Jun 2016, negative #britishweather is as upset about potential Brexitas | 10:36 - CEST am kioteRemain Teidup21 viral Dil down fier small US. drawdown; seen 500m 2016, Tegative chapy before rex uote... eps £1.cofl kAAFVIVUY 10.36 - FST CharWaers Brest Referendum live Updates: Vote Result, Stock 23 An 2016, United positive £3 Markel Reactions And Whal Happuns Next If The UK 10:56 CLST States. Leaves The EUSE https //t.co/mikTbnlzdi TheAustinR RT @Chinky_Ree: David Camelon getting despelate 23 Jun 2016, Shit posite hades now 1096 CEST Creek “I vi lave the FU, thers wil arly be 24 steers lft in the Alphabet” apres labonarr Jour de vole : Ia presse brilannique majoritairement 23 Jn 2016, Toulous neutral pros Brexith An https: cole 1056 CEST _e TREBINEST RT @2twestaboutic How the European dream died: 23 Jun 2016, hialags, neutral Cheersos @Nigel Tare nails case for Brew while 10.56 CEST Spain Merkel fures https.://t.co/SXo0tAIBuC Slanmaddis @jackjoh01213520 @bcomininwisible Brexit refuse to 23 Jun 2016, Tyne negative an20 say they will reduce in=migratian let alane by how 10:36 - CEST and much.IL is a rightwing coup! Weary, England Tactical Th RT @amz0010: Leaked Latter Reveals That David 10n 2016, UK negative nes Carreron Hatched Anti Breil Plot 10°96 - CLS https:f/1.co/GPEEMAZEB via @peaplesvoite_tv Collecti_VA RT @BFI/TV: Breit: Turquie vaut absalumant la 251un 2006, Fesples: I [negative n mainte du Royaume cons. FU 3036 -CFST Mouline hittps:fit.co/puBFUYTATR hitps:/ft.co/1e0TStudpw aux [Francs] Sulfolklz | @avsdestorbrexit Will ba wong Less for UC Ball af 23 Jn 2016, positive wur Luropean cousins Luduyl kwearefumily Let's do 10-56 €LSt this!¥brexit https://t co/9ZXLPSeolz Spas 217 RT @SafetyOrProfit: you're inthe FUR, in Fmaritime 23 Jun 2016, negative and allowed ta fate, read this: 10.36 - CEST https:f/t.co/gB8E250v By Remain Warka8730 RT @ANDREASSTAVRI, @FroudPalriotiol WERENT 23 Jun 2016, England, 7 meutral ast BOMBSHFLI: Poll pus | ave SPVFN POINTS ahesd of 10.36 - CFST United Rerain hours before referendum hitps://L.cod€ Kingdo hazardnews firal Off down after small US. drawclown; seen 23 1un 2016, © | negative EL choppy before Brexit vote... hilps //Leafivbill omy 10-26 - CESI WarkinCWs @Strongerin @Sadiakhan Utter bollocks the #EU(s 23 Jun 2016, Cheshir 0 | neaative parasitic and our relationship needs to end #BREXIT 10:56 CEST eo CharWalters Bitter 36 Brexita€™ Campaign Could Turn on Record 23 Jun 2016, United. negative & Nuraber of Voters hitpe://t.comHiSA Gs 1036 - CPST Stats Agatha AB RT @polskathetimes: EIAkbista ll neoficjalnie popiera 23 Jun 2016, Praysad, positive i" Bre? Tok Unicndei biogral kilo] 2056 -€LST wiht https:{ft.co/mmichYEVIG https: ft.co/WISYSISTW mana imide Polska! Fabri_Biscot Sleepless in the City Lets Traders Bet Billions on Breit 23 Jun 2016, Suey - negative ti Result https://r.co/dHdRidlafG via Sbusiness 10.38 - CFST UK Andrefitier ERadiovalle A” control Brest, pease don't leave us. | 23 n201€, Arcisate © [postive The Clash Landon Calling (Official Video) 2056 CLST https:{/t.co/giSNZERs2 Lombar dia Claudiaeffe RI @Owenlones8d: If Brexit happens, we will face the 23 Jun 2016, London 1608 | nezative fe fights of our ives and we have to prepare. My video: 10:36 - CEST tps. 1.00 51c39e0 betps:se ValdnisC AT @Spencerhlio: |FTSTAKF BACK CONTROI DF 73 Jn 2016, Noord 30 | postive OUR UNITED KINGDOM CYLRY BRITISH SUBILCT MUST 10:36. CUST Huland DO THERE DUTY @vote_leave MEREKIT VICTORY X hae subtell RI @obritom: Derocratic duty dane. dvoteleave 23 Jun 2016, tngland 1 | positive Steady strear of voters hops overwhelmingly #Brexit 10:36 - CEST Homenews3 #viral Oil down after small U.S. drawdown; seen 23Jun 2016, Santa negative ss choppy befare Arexit vote... hitps:jf1.co/7QunSGo?y 10:36 - CFST_ Clara Mauroflugi RT @Dwalingen: Gorbache warned he European 23 Jun 2016, bancari negative people about the striking similarities between the JLU. 10:56 €LST © and Soviet Union ABret hitps:/ft.cosc | Smacktainy 1s dedsion time! Don't et Britain 20 to wastell 3102016, Londen, negative breil BLUref PRemain hips: 1, co Raq} CaF) 2056 CLT UKivia Munich) ‘anca_toader RT @NickKristol: As Bt vote on Brexit, my column: 23 Jun 2016, London, 5 [poste R18, Jo Cox. May Britain Remerbar Your Wisdom. 10.36 - CFST UK hitps:/ft.o/aksTagLON? hitps:éfL.cod€ | FabFfabicnd AT @charlorragne L558: Breil 23 Jn 2016, Sud 20 | positive 3 INCROYABLE! Les citoyen: du Commonwealth 10:36 CEST ouest A Dsidant au Royaure Uni volenl au eierendum! | France, En plus des 2de gana TmISTIE) Frama vi ARrexit 73 Jan 2016, Nurbai negative 1056 cust Quantumtx RI @ira_tenae Fr Halian ar | endorse SBrexit 23 Jun 2016, positive plorer because we can be united only in freedor, 10:36 - CEST sovereignty and rule of i, #\otel eave Kips:/3€] hopbin The #Arext Allen, made whale after Alredt team 23 Jn 2016, neutral returns o orbiting mother ship. 10:56. CEST https cafdionfeant aia RT @yiotalds: By al man, vota 10 ramain in the ELL 23 Jn 2016, USS negative brent 10°56 €LST Briain [Ie inblogel ~~ #Voteleave HBrExit https//t.co/IUNVIKM6T 2342016, KAfin, positive 20°56 €LST Deutsch land FR205 RT @haballo7789125: #Brext 25102016, FRANCE neutral https. //t.ca/hnNECKYuR 10.36 - CEST nicholasaylo RT @alssan erik. Qausett hur det RAV dag kan desta 23 Jn 2016, Stackhal negative u vara en {Aga al stila sig. Har sii svar viabla 10:56 CEST m @richolasaylott HArexit hitps:{/3€ Contrepoint RT @jipebe20: Brexit : que cisent vraiment les 231un2016, Paris, positive N partisans cu Leave hp /fLofndsd73bmd0 via 1096 -CLST rance @Contrepoints Fabrysivia RT @LeavesUOiTicial ake sure you getout fovote 23 Jun 2016, fanche postive faday for our independence and » brighter futurel 10.56 - CFST ster, UK #EUreF #Brexit MotcLoave hitps:/jt code corbyniokes Yomama so durb we have La say she's voling for 23 Jun 2016, Isknglon negative Braxit because of political cisengagement rather than 10:36 - CEST racism or stupidity. London polskatheti A @Nigel Frage dif od rana w doskonaf ym 231n2016, Palka positive mes hurmorze... EU WBreait Relacia na Adywo: 1057 ces hitps:/f1.caTUONSHTE] hitps:/jt.cojRgORFDAFYS Hussnhima RT @docshayyi: & U501 350.0 U,@40i U7 23 Jan 2016, Paris - BE heed OSUMSG0DSY BENE PUW ISIE PE 2097 CASE brance: B50,090u088" TUS B50, 0'050, 0... 0,28 © 070,48) U0, D501 G50, AUIS), 01.0 240, 50-0050" 050, 50'D: DUS! Breit or #Remain U"B:0 BL. 5 SLpiaky RT @APaman Ich wette, 45s der Forexit heute 23 Jn 2016, negative aunnsion der Gegnor wasgehl, 50.35%, Gay hat W575 Brfsselschan entschieden! HErexitOrtiot bosrse_talk The latest @hoerse_talk: hitps//tco/PARPSNATSI 23 Jun 2016, Frankfur postive Thanks ta Gregor 16 bresit buy 057 -CFST 1] German Vl TivaNowog AT @ independent: [save supporters re very 3m OTE, 37 [postie adsla suspiciuus aboul the pencils al polling stations: 1057 ast httpss/t.co/yzROXrOIGE betps: ft cojm1FcG3107) Fragie_ meg" Tl DATTel DT TET, ITT IG PTE 5100 2016, © [regatve Lele I=. Be. Jedi Toei el 1057 CEST PATEL iy... #brexit #hremain hits: {/t.cofwBkmbWiPoy Https £1.co/A1GKLTA aroncake RT @SacEconhag: Steve llediey of @RM Turion 2310m2016, Stafford 33 | postive makes the trade union case for dLext 10:57 CEST shire Wolelcave dBre AUR! lps /fLcofOLeRDI le hips G€ amnews2d Gviral Oil down after small U.S. drawdown; seen 23 Jun 2016, negative choppy betore Breit vote. . https://t.co/YkoWpXPOXF 10:37 - CEST Warcabaco RT @slEconomistazs: A Buenas dAas! Hoy pendiantes | 23 Jun 2015, adh, negative sary de Reine Unico que ya ha comensado avotar Agfrext 10.57 -CFST Spain o Sremain’hitps:/f.cofyjgUIGyBal hilpsie | AnncUrda To Brexil or nol Lo Brexil: thal is the question facing 23 Jun 2016, neutral ris tocay. (Law3801 hare in London and will have 10:36 - CEST complete coverage of the vote, Monument Salou | Magaluf tambA® votaran #lrexit 23 un 2016, VNG.CA positive. wacia 1056 -cesT_T prestontow RT @prdioster: Outh. va GDAaranoich 25 hn 2016, Lower negative er 036 -CFST Rue #Brexil ARemain #TUrel ACUrelerendum Mounlai hitps:/ft.coRCEVTLLG ns, NSW Wosdlands _ @barjohnhore Bthecarolermaions OF sojobs dont 2310n2016, Cymru, negative aokshp. matter Lo you..£0t it. SmAlIRight kick #Brexit 1026 CLS United Kingda m odriguesh quien le importa Una ef Brexin ai nada, esthin 23 din 2016, Nadia negative orca tardande. 10:56 cesT saw RT @cToro: Wha do you think the UK public will vale 23 Jun 2016, Cngland, neutral in next wizek's referendum? fbrexit 10:36 CEST United Kingdo Jenvselby 1s quite Smiar to hak my reaction vill bs ¥1da 23 km 2016, London © [neutral nat wake up ta dystopian postiet fitain 10.36 - CPST tomorrow. hitps://t.co/mCub5zoL00 TradingYupp RT @Fxflow: Do like Austin and LIVE trade the Broxit 23 Jun 2016. 3 | positive ¥ with us 10:35. CEST Jone 23 starting 2330 GMT hltps 11 coflyOuvkcr bp hits ff cofmSpLogher aronresebo @Sauronsstock 110r inte man ska FANVAIG 5 (RST 23 Jun 2016, neztive mkt dagan innan Grexit/Bremain, Avan om man anar 10:36 - CEST urtallet. Gissar Falk Kar passiva nu famjamup2a firs Oil down fter small 1S. drawdown: seen 23 1m 2016, negative: choppy before Brest vole. hilps://Lco/72)UwqUBGc 10:56 COST Tlupstrearm Us decision day in Briain, Check oul he ©F1 Ive blog 22 Jun 2016, London Pose on the Srexit vote 11:14 - CEST hUps #116011 GYAC400 hltps tL co/2IRiw2 V1 wakingther: | think this 153 reason to SLeave dort yau? ret 23 Jun 2016, West posite arkey hitps:(ft co THI RATE 11:14 CEST Yorkshir dudmpsn "ARACIT nan whois fuslled entirely by hate has 9312016, Notting negative began hor slow & unsteady journcy lo the polling. 11:14 COST ham, station” brent https; f.co/dtagsstisa England. oraticays BREXIT, what's gonna be taday? What do you thinkit 23.1un 2016, Chile neutral 2 must be7? 1118 -cesi IMS. dom RT @0blviousheaper: &Chrisuk1 343 230m 2016, UK positive table @jemimabond0D7 Brexitis having confidence inthe 11:14 - CEST country, rather than outsourcing its management fo overie] _laurcripn_ RT @UKPREKN: You won'l gel back your country’ il 23 Jun 2016, negative You vate for a #Brexit you'l giveit away 11:14 - CEST “stronger otal AEurat https:/ft cojose! alberloft0 RT @raramolccola: Geta in parale semplic © povers, 25 hun 2016, Pagani, negative 0 ma a nai che nan n asbiamo un soldo, MACHE CAZZ0 11:14 - CEST Campan CL NL FRLGA DLLLA GRAN BRLTAGNATI713¢ | is Parlicieic Gold Hugs $1070 Ahead Of BrexiL Vole, Wore Yellen 23 Jun 2016, Santa pusitive #lanexvellen HFOMC... https: co/NASGIGATI LL:11-CEST Clara, =) franTrambe @Corriers a bel natisiane che traballi i Trano di 23 Jun 2016, positive ta Spade in caso di Brexit! © AndFranchind 11:14 cesT @sandreaprincipi Toacdonaldr After Mirexit Roadmap tors leap in the dark Rn 2016, ruse Tezative " hits. 7100/15/17 INGI Hd @ ReutersUK 1.14 CPST nickoreay @campbelllaret Lucellent speech on Scddebals there | 23 lun 2016, West negative is 06 manifesto, no case from Broxil. 1:18 COST Morse, Haw can you vat for a cause with na plan ar idea England Helleico "Making Sense of 3€"Brexitac™ in 4 Charts” by 2312016, Boston neutral AMANDA LAUD via NY1 [he New York limes rarer https: ft. cofisuasHtoxu 2aEspana Breit: GuRa para seguir y no perderse nada en la 23Jun2016, Espahza negative nache del referf @ndurr https://r.co/ GrOKPISYHS 1114 CFST noticias #Economia https: cofymBsiDithn Tedviggun Foret ae F310 201€, Sweden © [reual 18 -cusi noticias21es Abren fas urnas este [eves en Reino Unidopara ef 23 Jun 2016, © | neaatree histirico refer Cndum sobre cl Breit’ 11:14 - cesT https. /1.00/002007ikm Unstablesha RT @BeverleyTruth: #BRFXITFOR RFAI FRFF FAIR 23 Jun 2016, 7 | postive TRADLWITH AFRICA, SOUTH AMTRICAAND THE 11:14 LST WORLD hitps:/t.coPPHpat mL Tandacnd RT @Davielo52051945: Now Merkel warns tha EUs 25 Jun 2016, Kings negate facing, an ir igration criss ror Africa god help us il 1116 CLI Longley we stay in the EU hetps://tco/acpac Walletico "Portraits ofa Ration Contemplating 3 5 BronEA€™ 23 Jn 2015, Boston © reutal by Unknown Author ia NYT The New York Times, 11.14 - CFST https: cojvochiasatif blackjuckie RT @Pelort/uglob: hllps://Les/vDlScebole 250020165, Geran 2 | negative iner #BritaininOut #GoodbycUK ¢RemainiNEU #EUref 114 - CEST hits. fft.cafIkiraSGI E Abukhamr RT @snarwiani: vated Boresir tac. 11 When 23 un 2016, 1 | negative ceunornics shrink, people gel Ural 20 WW issunk 11:14 CST away 2) As we can see, EU did't protect Wininglin RT @AndreVTP: The Ecstasy For Gold And Tha Braxit 23 Jun 2016, The 2 | positive Vote SGLU hitps:/ft.co/t2allisdse 131-Cest vault fish Davo RT @PPOffers: I's now 1/7 that the UK rerans inthe 23 fun 2016, 2 | negative EU, with exiting out o 5/11 hitps jt cofplotiOAck 11:31 - CEST rexit fimmieasdal The Interpreter: Making Sense of 3€”Braxich™ ind 23Jun2016, frizons, © | neutral ay Charts hoy: //Lcolph 3Baye 1031 cis usa soolllon RI @PrisunPlanet; Wealthy elles manipulating bodice 23 Jun 2016, Wakayst 197 | rege adds to make #¥ateRemain sear initable? 121 CEST a tps /71.00/1DS0016ika #Drexic davidleass, Frmpire like sours cos’ deserve ta desapesr 23102016, © | negative cur? hitps:it cojttumatiibl 131 cesT migrufiran @Alanivarsson haslicr hAVIer med, bydker dol 25 in 2016, Stockh negative fone lta Ant mk risk on att sings 13601370 sh 11:31- CEST m, idig rm bre re Sweden The max do lesbian on popmaster] “votes beats 2 un 2016, postive orm 11:31 cesT dandell RT @spiegelPeter. Nervous about ¥Browt much? 23 hun 2015, Vienna, negative Staring volatility hits.new highs avernigic. GFT T131-CFST ustria Trveblog: hittps:f/t.co/tZTOmIK? hitps://tiE SHillSprintd RT @BrcilbartLondon: God Scum: Lo Be Voling for 28 Jn 2016, LA. neutral 5 Brent hitps/cofepBnRoW2 11:31-CEST Mehda hUps 11 co/3ULL511 Lg wn TaleQPartl RI @Harketwatch: LS, socks set for gains after 23 Jun 2016, positive = Brest polls point to 3€”stay3€™ vote 11:31 cesT | epojfcaftpessaanec i— DavideRiball RT @MicalaMorraGa: Mrexic 231m 2016, positive ni Glfinglesi esereitanoil loro ditto df cltadinanca pur 1131 COST essendo sud dalla corona. Ano, che... nets: 5} SthicalT53 RT @enni: The nonBrit's guide 1o the EU referendum: 23 Jun 2016, Chigwell 7 [neutral hUps/fLoofsjLowhkeis SLUT na-as https:/t.co/uteTHNGnST England Smmahoka RT @W arketWatch: These are the stocks to buy inthe 23 Jun 2006, _ Abuja, ili 7 | negative nt wike of Dest, Trump and recession fears TI31-CFST geria hitps:1.o/PSjlb703Y hitps://t col NWLOOGHE | limmicasdal Brussels boss Lolls PM: NO more reform Lo Britain's CU 23 Jun 2016, Arizona, © neutral as mer-bership after Brexit vote 1131 CEST USA hips: {ft cofwavBOnaYep Nkodgo RI @kanckosed: Vieialic Tis Ba. fi isd § 23 Jan 2016, Stackhol 53 | neutral Vi IDA leis TAD if, ITA Te Je ™ 12:3 CEST im, 3 Re TEL Ai T1051 ret Sweden Synthinsani RT @bonbufe0: iongaunt Jon, a Germany car 231m 2016, 9 | positive a manufacture said after Broxit business as nomnal, and 11:31 CEST Turkey deal is ON.can we hold dave to Accs€! WCPoliicsU RT @NCPolRicsEU: AEUref summary. 2 Jn 2055, UK 17 [negative K 1131 -CFsT Polls say REWAINI2 Noveast 5248 Forcast 5347 bret 8 chanos 25 (1) Hits. 11.00 hUSOTPIRD hitoss€. chauchot m RI @coberah Cute; @UILD says I brits vote azainst 23 kn 2016, aly 5 | neaatiee aria Brexit, the Germans will ecognialsie the 1956 1:31 - CEST heartbreaker Wembley goal hftps://t.cofs3€} Weljtraw RT @SpingsiPeter: Nervous about Fest mich? 233m 2016, United & | negative Sterling volatility hits nw highs overnigt. @FT 131 COST Kingdo reblog: https: jt coftZATOmIK? hitps:/f13€ m monaleruri RT @KimiongUnique: En cas de WBrexit, Hollande sera 23 Jun 2016, neutral a “infleibie” selon Moon, Comme avec LiDonardy, 1131- CLS Wiartings, les antitas... ips: /t.cofGa€! loirehiiddl RT @DarthPutinkGe: Itis not those who vote that 23 Jun 2016, 53 | negative tad matter. It is those who count 11.48 - CPST Brest Allir_ta In sostanza il discorso Brest A” coshmrigssurribile: 23 Jun 2016, Messina © positive hitps://t.co/BsRF1mSAICD 11:48. CEST, Sicilia, Takia AMWatsaz1 RI @LouiseMensch Roses are red, 23 Jun 2016, 200 | positive 53375 violets are blue, 11:48 - CEST If yu love Furope: But not the EU #atel eave Hrexit and HTakeCantral tps f1t00/LRSOKAE Inlovendipe RT @jesusrarana. Na hay dia mis oportuno pars 23 Jun 2016, 7 | negative fa char un vistazo al dossier de £ _infolibrey 11:48. CEST @mediapart sobre el fBrexit iTps:f/1.co/gBITSAZIE] ellecome22 RT @Dwalingan: The Peoples ot Europe are hoping for 23 Jun 2016, negative 2 a #Brexil domino effect into 4hexil @hrexil eloelc, the 1148 - CLS #50 has failed us al etps/t5E TGn1Zl @BsverleyTruth ©0Davnd ONG THATIS TRULY Thon I0LE, England, postive WONDFRTUI NPWS |SFNSF A LANDSIIDF SARFXIT 11.48-CFST United Kingdo Sraye AT @robriraineyn Sl undeciaad? ABest AUT 23 Jom 01E, poste #ValeLeave Thisis correct way Lo complete blll 11:48 Cust hitps:/ft.co/BE3paTn rapacetris All the best a Brits braving The weather 1a vote Ion 00, England, postive ' Voted Sbrexit but os for whether that'll happen.ar 11.48-CFST United ol, would wan 16 bel ont, Kingdo m LalovendiPs RT @DebathiRojavive: Femilinde: Daz "Lo qua me | 23 Jun 201E, neutral fa preccapa hay es el ‘Drexit™ HEscuchs-CatalunyafRY 11.48 - CEST https:/it. cof ¥wsirdYil htips:/it.cofa€ Susdiforum CE To Sour To AEG A Pl If Brea Succeeds B25 Jom 2016, Austral pose https:ft.cofIFOVXBIMSN 11:48 -CFST a hitps:/t.co/Z0paXasim Fyanshedde RT @Dezzen: "Vote Leave fa vote for a theme park 23un 2016, Clapha 10 positive n Instead of a country" 3€” Sarr Jacob: 1148 CEST m, https:/it.co/VOwCY3aVo5 #Opinion England hitps.ft.ca/ I Tovhcasd] Pracvierl nag Prarvier angus Picture Special: Feary Prar-ar Laague. 23 Jun 2016, 0 | neutral ues player who could bu affected by Brexit revealed 11:48 CCST hutps:/t co/QEW KZOKZ3] ecanomist AT @IarraySOA: Bloor berg Msiaces Breve Tn 2016, Londen negative fa) https //t.cof320eLnb3n lanl lansond 1 11:48 - CEST @muharoradald https: jt co/TTCRSerVz A_G_Dugin Etsi le Brexit donnait aux FranASais la volontAE de 23Jun 2016, Heartlan neutral reconstruire 13€™Furope ? https://t.co/yaANRRCUR 11.dR -CFST d paclodfuss _ rexi il game pil lunga per Europa. “leave” 0 23 Jun 2016, Italy neural "Remain", all: urne 46,5 rrilioni di britannic 11:48 CLST https://t.co/edmiF LON ss via @repubblicait Soa IE Breit Wovie Inte, posting its #1 cafolBOLXY Vel 11.48 - cesT #21 pd fisherman 2destroy their boats while giving fishing gh 10 athers hits .c0 i¥hskhT8s. anthony3ds RI @LeavetUOfficial; Shameful stl from the 23 un 2016, Ihe positive 0518 Rervains, @GiselaStuart has made s commitmentto. 11:18. CEST Kingda the UX and ha exer right 10 back Sees. ESE} m Wosharraf0 AlFnglish : Beyand the #Rrexit debate. 231un2016, Dhaka, negative. 129 https:f{t.cofdsQsSchajl by kenanralik 5€; 11:48 CCST Banglad hitps:/ft.cofedSsNAIVO) hitps:/t.cofUuBSKentiy eh Jonabielr RT @WSI: Even f Briain votes against 'Brexit, the 23 Jn 2016, Same 7 [newwal market's relief would be shortlived, writes 1145 -CESI herein @Simon_Nixon. https://t.co/I3Xs0gwEtD the warld Newsdesk RT @rylimesorie: Brest ind charts: generational | 23 Jn 2016, negative on divide that's about mare Lan ze 1148 cust https/t.co/VtDQCEBOSH Wigas0 RT independant: Leave supporters are vary Tun 2006, Widiand | poste aupicions about the pencils t polling sation. 1.05 CFT « https: cofygRAXr 65 hitps:fjt co/mAFcG3 197) e550 RT @5lop_The_CU: Gn Breit the UK will becar-c the 28 Jun 2016, Kyolo, 85 | positive ELI biggest export market. 12:05 CEST Japan #VoteLeave hps/t.cofwITORKSTUM Trench RT @romwand: Tony Benn vould have voted FEret 23 Jun 2016, I [positive on findependenceDay! 17.05 CEST It the establishment wants it, do the opposite! #voteleave hitpeis€! Wonaliszal RT Knack Hoe kan u gokker op cen breman af 23 Jun 2016, negative ' bres? https: fe. cof AdpW 2005 2M 1.05 FST hilps/fLco/HYGTGyAHD Flo Wall RI @HMRahantoja- Fret ARAeslys on alkanl, 23 Jun 2016, 7 [regative Katsa, miten voi kayc=, jos brit INbhtevet taijos 12:05 - CEST he JRaavAat, hiLps://LcofjGSyrmON hilps3e arzowaymil RI @Virginia Repel E loche pensaeache ll Bret 23 Jun 2016, Milano 47 | positive ano fosse l cola dal state inarrivo dalla Gran 12:05 CEST Maly - Rretagna landon uk. rexitortios paresit Tranciana Jefiray Simpson: Will 3 Gng, loveless marrage end 23 Jn 201, Worn] Treg wilh Breit? hlps ft cu/CAG IDL 2os-ast de mahonnews RI @Julal 181: Yet another good reason to Vote 23002016, bru 1330 | positive 7 Leave. #Brext https:/t.co/ZppucosTes 12:05 cesT FooignalOnli Gold investors wrestle with rexit vote in wild options 23 Jun 2016, nine neutral re dealings haps: co/ngGOnAUmad 17:05 - FST Swirmerba The Brel Vate Is the Perfect Facuse to Resid This 23 Jun 2016, _ current neutral vars Sung by th Clash via TIME} 1205 CST location https: co/DATmeI3ye https:/t.co/aMKPOZAVXH Baulyforte RT @rdinhod: #Macron en cas de ABraxit, “a Franca 23 Jun 2016, negative sera inflexible” avec le Ropaume un! 12.05 - cesT AEnharche vers plus de ditature SUE httpsi/t.cac! Tewss3 Der BrexitEndspurt ist nichts fAsr Zimperliche: hn B06 on © [neutral Premier Car-aron kixmpft um jede Stirs, Baris 12:05 - CPST Twitter Johnson kRtsst ci... HUpsfLco/ SCAU aL Wall Dark Bull want Lo see resi. Lill be interesting lo see 23 Jun 2016, dalam © | positive how market react after that 12:05 CEST hati Amant desde VeoMoticias EN VIVO: ALE fin del sucht europe? Berit o 22002015, 0 0 | negative " “Bramain’, los brtinicos daciden su futuro 12:05 CEST Munda Blips 11 cofnhIVSH 501 4c hls Loo PXIH3 gh EableCentii Guy Varhatstadt Avs Ie RBrext passe, Cet 5102016, Europe negative ste pouting gui va rire 1205 cust Remain ¥ALDE FADLE https://t co/BGULTBPC SOWagnerAr RT @Good_Ant_b/an: Wie das schiechte Wetter In GB 23 Jun 2016, Garman T[regative ana die HreicAbetin-ung beeinluist 1.05 CFsT y #BrexitOrMt https co/hEObdTsqe WarkRlolly RT @BarryShecrman: If you dun want our national 23 Jun 2016, Craniicl 11 negative Valles to be set by the Daily Mail don't vote for the 12:05 CEST d narrowr-inded ilibera intolerantae} Univers or Bedford Twisicherh RT @de spank: INTERVIEW 3€2rtationl: 230m 2016, Das 17 | negative «il Aungstedta: Wiener Lurapubaperle: Bilen werden 1205 CLST Mele HANr EBrexitstimmen https:/1.coXLBLSAPR} Erentone] Bald tains Dane 230m 2016, Rh, 0 | postive #Brosit AVoteleave https:ift.co/sUztsUoaz 12:22 CEST Wales FietraBjorn Oi the parliamo quando parliara df Brent? Guida aia 23 Jun 2016, Cosenza © [negative natisi del giorno | |e erpss/ft cof MGURYy 120 -CFST IT Kantox_es RT @expansioncan: los bitKinicas cambian sus bras 23 Jun2016, landon, 53 | neutral por euros divkarcs snles del eferADndum del 1222 CST Cogland Breit https. co/FSEYOSHWoP mad_sshieig RT @internetough: ing ths 353 PSA because ben 23 Jun 2016, Glasgow 2 | positive h ll thinks “brexit Is sore sort of breakfast sandaich 1222 -CES{ https:t.co/OAQSHPEIPY Scotland Tocaueviics RT @Alexandreloubat. Dangers du RBrert sont 25 3un 005, 7 [negative 3 connus: funnel Mancha rebaich AE), pluie sautereles, 17.07 - CFST Are glaciaire, Royaume 3 la drive dansi€ CraoyealiZD RI @Leave UM cial: PLLASL WATCH and WReliaoel 25 1un 2016, 7 | positive Et) 36° and remember ta #otel eave for our 12:22 cesT independence! Heller Kiret https:t. cofiAhriH5 Lu Ei RT @aohru: DCOANEONIDDA DZD" WBrent] 530m 006, Bw 759 | positive TDDAD DO DUDEACT IAD, Re DED, 127-CFST eberEn® DINED, N+DADWO'D, DAD ele ReDuDTEE DY Ne 2 Foul 00" KBYEROIY DDB AREF hips col yQurighhbym dul hitps:/ft.3¢ Wenow? RT @Carina3a03: darat Bn 2016, Naver 7 [negative LANIBIEID HAN DANNIE 122. nd BritinjBritsh Exit SportTalkBri RT @RT_com: URGENT Final Wert pol puts T53un 016, Bel Are [neutral an SE" Re AINACT at 52%, 367 caves€™ at dR AC" Ipsos. 1227 -CFST KS, USA WOR for Cvering Standard hlps:4/Lco/UISWSIUdMI ucklhen RI @Shujattabbari: All lm going lo Luce abouts 23 An 2016, North 51 | positive #Brenit. If you Hivoted, vote your choice in previous 1222 - CEST Carling pall tweet. 10 ADrextOrtiot AkUref3e albericauipo RT @Raphael Rougier: Don't go brexit my heart] 23002016, Park, 1 | negative u https:ft cof NWEZNigegF 12:22 CEST London KelieRasew RT @ArsTechnizaUK: WBrexit Brussels tech folk fear 23 Jun 2016, Teas, posite ick possible UK vote Lo leave Luropean Union 12-as usa hitps/t.co/WBWIAUNE by @BrusselsGeel https. Teganis7 RT @RT_com: URGENT. Final @Brenit poll puts 23 Jun 2016, neutral SE RerainSE™ at 52%, 37] ave3E™ at 4R% 36" Ipsas. 17.97 - CPST WIORI for Evening Standard https://t.coft{BWSI Udi. Agencia An LLFOTO ANSA Broil, la Gran Brolagna al volo 23 Jn 2016, Via della neutral = hitps:/ft.cofPhlv3armvel hitps:ft.cofUWachnZdV¥ 1222 -CEST Dataria, 9 Roma ED) “Brest to oe followed by Grexit. Departugal. Faleave. 23 Jun 201E, posite Fruckof. Crechout. Qustria. finish. Slovacou, 12.22 CST Lateruia. Byegum. clgorbachee RT @business: Today is the day when Britain dogdes 28 hun 2016, neutral an its A3ypear mer-bership of the EU 1222. cesT Nits. 71.00/uMI 2B 80reat https. cojqWMOHKEE | KeiCrayons RT @catinmoran: Best Bren piece yet, by Than 2005, Galoria Teatral @paulmasonnews: "Real warking class rebellions tend 1:22 - CEST nol lo be run by the Lslablishrent’: hilps-a€ SHelulbol7 RI @Curnadobe uiler; Lu del Brexil es algo que 23 Jun 2016, Cartage poste deberiamos votar todos los ewropeos. Varmos, digo 12:22 -CEST na City, wo, ciudad sin ley Trankacobs RT @AutoWesk: ABraxit? 7 redsnan om tegen bedi 25 hun 3016, Amer, negative ol http: ft.caftKTPekcYa 122 -CFST Nether ands pros WRSXICO: Dep uA deol Browil, AZquAt alr 7 Jn 2016, Caracas, feats riesgos entrentar el precio del pectin? 3 1222-CEST Vensave tps ft. cofenCewene? #sestrellas 0) SAA tao Dazcbeo News Sindaco di Londra: La Breit ark un 23 Jun 2016, neutral "punto di svalta nellastoria del nosire Passe” 139 CFsT hltps:/fLoo/ IAM 3COwlai Kings_haneli RT @nhk_nows: 3643.00 550 8c avg 3€ 23 An2016, geifiit positive sh 5.00, 31%3, SHRI E5, 0000, 45MVET, 3,405 12:30 CEST _apEft Fite Sag 6 IR J, JE Le Sog¥ SALAS, al Er BR TIT OCH AAT "aio EUS AER FATS AE AANA, of SCAT IRATE, hips: o/pwn3BrPRXT hitps:/fL.ca€] Uiiillyses Wir, Bresit* 22 Jun 2016, neutral 1230 cesT besciva | ReferA@ndum del Braxit, =n directo 25 1un201€, Paterna, © regain https £1. o/f7wswCemi) vB @elperiodica 1239-CEST Comunl dad Valencia Tigelca7s ot that needed any convincing ta vote SRemain but 23 Jun 201€, Reading negative John Oliver being awesome about Brexil is well worth 12:39 - CLS 2 watch https.//t.co/972:DSWQy Tintodog RT @FarmersABritain: Don't rely on someone slses | 251un 2006, postive Vote 0 change the conree of story rake sure you 12.39 - CFST 0 out and cast yours! #voteleave #b3€] rencFregon Ania breil 28 hn 2016, Trento, negative ese 12:39 CEST Trentino Alle sdige Taramagut RT @husiness: Today 1s the day when bitain decides | 23 Jon 2016, where mewtral ani an ts ddyear mar bership of he FL 1039 CEST internet lps #1Lcofu Mk BNKIGL Broxil. speed is https:/t.co/avMOHXEE | a joke petaritier RT @missingfaktor. Erexit. Graxit Departugal 21un 2016, Bristol, S07 | positive aleve. Fruckoff. Cacho, Oustra. Tink. 1239-CEST England Slovakout. Latervia. Byegium. “CopimWeall George Soros wrong on Breit and UK scanamy, says 23 un 2005, Weal Tezative hax City economist https://z.coftiy7cTulnk 12:39 -CFST Midland. si Wolerh arplon Additedatr RI @lotoston: etsbelabgiti, fui FTA oils 23 san ue, Tie negative uth Brent Paleo, To SLE FILIP ff TAT: 12:30 CST Didi Pals Tle. LT Ti 141 11-7 10 PPA, at, Tal. TC, ERE. Pre ese! Tabi Tiel feisty abit terroh RI @colorbl shan: fori aupuro che vinca Bred 23 Jun 2016, negate cosi' da poter mandare atfanculo questa europa 12:39 - CEST markaa8236 RT @mundaufmachen: Aivoted : ABREXITI TODAY Go 23 Jun 2016, UK Hull 211 | positive a 1a our local pollig station and Atel ae! a9. erst #TakeConlrol Project Hope #indepundunce Day huts TalanoRqu RT Rais: Corton 1 borse, cia lo spread Bn 2016, Tay [eval la https ft. cof neGaiLowe 1239 - CSI Jonnith anyone undecided dieave eran Hbrest 23102016, 0 | negative y2k https:/t.co/SyshpUzsws 12:39 - CEST tor-stanifor _ @Benfurrells t's ike you have no ides of how (0 use 23 Jun 2016. Exeter & neutral a Gaogle? hiipsft co ICYD GA 1D39-CFST tom stanifur dcovk Juul aneelet RY @OusstFrance: Brant. Ouverture des bureau de 23 Jn 201, negative vote pour le rRGRSrendum sur IVE 1239 - cesT lps: f1LofxePHLwlnt hls cofgtlimes2P Brenda0222 Doss #DumbDanald now know what Breit 57 Tn 2006, NYC negative 1239 cesT CunadabeT RT @PepeCaute: CunadoDeTulter see. yi gana ol 23 Jn 2016, Espakea posite iter BreadLy se piran que se leven LambiADn su idiorra de 12:39 -CLS| nuestros colegios Tariararter URGENT: Final #8raxit pull puts 3€ Remaind€™ at 23 Jun 2016, Venezu © [meatal S25, 4671 cave 6 ot 385% 36” Ipsos MORI for ening, 12.39 CFST la Standard https:/ft cof Ye7igHRCA via @RT_com FunGuerillas RT @jfarchy: Today's viewin... ohn Olver on ABreil 23 Jun 2016, Location 7 | positive for same uch nescled sense and humour 12:36 CEST : Right hUpsfLoofdlayam KLE Behind You! FaBarrattl RT @jenny_wren_OL: Vote cast SKE 25 Jun 2016, postin a8 Eivated ta LEAVE the European Union 12.36 CEST seurel ABroxil Tancrozarsia Bret cokVhusunun yaAVanmasit ASok aun vadeli 25 hun 2016, istanbul positive n alrasa da zayA -flayan ABD biMyk¥me tahminieri 12:36 - CEST ellen pivasalarktn en fine kor olacok Alenmorris§ RT @louisehiensch: MC News Suppressed fitsn 23 4m 2016, negative H Drivers Attacked in Calais By Migrants Before 12:56 cost #FUReterendum https://1.co/g02cP NdyKw: #Rrexit wie} Fabkews RI patent wpalens in OW Iimes Daroaalc | 23 Jn 2016, Windsor 2 rel Party, 3€ Breit AE" M.A. Drate: Your Thursday 1256-CEST Briefing” by AGEEL HASSAN https //1.ca/phv1gIVPal Ontario Visine RT @leaveEUCfTicial: Today, we tum aur backs ona 23 Jun 2016, 207 | postive failing political project and reenter the world! SEUREf 12:36 CEST exit tps. fft.cafl Su TNTA) 30036 RT @TelePoltics: Polling station ordered to take down 23.1un 2016, UK 4 | neutral 3 Umparliali€ * Leland Hays 1296 Ls hitps:/ft.co/SINHATUBIG HEU tps £1.c0/ASIANIKGIN afrapeplace The atest lleard If Through The Grapesinel 231n2016, Virginia © | neural EY hitps:/it.co/DEicX0IsG wine whroxit 12:56 - cesT yicutisvahl _@masisita alss, voit lata Uutisvahlisovellukacsta 23 hun 2005, neutral i braxitnotifikaatior, Saat notskun aina heti kun uutta, 12:36 - CEST hp Loo Fpl G3AC James JM Another reason Lo vole Arent 23002016, London neutral ariow hitps//t.co/lUO7uUctK? 1256-CEST and Jerusale marcichatte. RT @SleveMaggs A typical BREKIT voter? ‘Orly ate 33 Jun 2016, negative ‘ keeps me alive... voteremain factanvho 1:36 - CPST sdeadlyassansin hllps://L oof bNBYOWr CoH sledohnson RI @Nnamdi LS Okoye: voleleave for my children 23 Jan 2016, Warcest positive 1990 and their families t prosper ABrexit 1256-CEST er hips £#t.co/Toniw2:0le pedro crd Seria muy interesante tener la opiniAln de aradona | 23 in2016, Patagon positive sobre ol Breit. 1256-CEST a frgentin a DoGera RT @restouOft: Br des millers oe votes par Im 201E, negative correspondance se perdent 1296 cs https:f/t.co/NWYDIEDBhr iret @Walter_VH_@piarreiovancvic SNigels€ Ga_jal E corungue, ultimo sondaggic: "Rerain® in testa al 23 Jun 2016. negative S25. wbraxit 1536 CFT TaiaTauh Avant une visite en Ecos, Donald Tramp oe dit 23 Jun 2016, positive favorable au An Breil ko Le Monde: re https:f/t.co/jS8IXPsQTe. Thesaleblon RT @Carinazcos: un 2006, Hunters 78 [pote d 5,00. 60.25,C0 0.73 J ¥APA 23 65 50 D2 OFURRE 12.38 -CFST dream drei, 5,783'Ch,a'8, 5, +a 5 £4 ¥5,T3 0a £8.73 88.73 1a» 8,78,0.08 28%0,40,%0 5,3 £3.50 3 8.185, E5758 Nr td Ba pd ee'ER, Ya, 0B, 2M $73 50,3 Ee BE REA bad ¥a aE) Prniass RI @Allmight: 100 Cheap Hn 2016, Tega Brest has hammered HFTSE so hard 16 of 100 stocks 12:36 - CEST Yield 395%... rot even ADJA stack > 55 uy SUK httpsiff.3€ foto Da the Math: An Economist's Guide to Brexit 231n2016, AceT:- positive Bloomberg, for iPad hitps://LcofyNnyDSIWAm L1313-CLSI 0.18838 9 8.4876 9 Agitpress Droht heule Nacht der kBroit © 25 Jun 2016. neutral hitps:/ft.ca/¥nKiA1CaBN htps:/ft.ca/OvuOwle 13:13 - CFST TrielianBerg Hanestly,s ft super weird that | can't sleep because of | 23 Jun 2016, negative or #brexit? Like it's dur, | couldn't even focus on Kung 13-13 - CLST fury and love that shit. Wainastial Today is a ance in = generation raferendurs what wil | 23 hn 006, Leeds, © [postive side ou be voting for? HFUReferendur revit A13-CFST_ Frgland steph arella RT @washingtonpost. What is Rrexit? The corplete 23Jun2016, Santiaga 17 | negative no ‘suid Lo Brilains€™s C.U. drama for confused 13:13 COST, Chile nonEuropeans hitps:/t.co/UvSTSRLYKI Telco Pusdies leer los Roltimos anilisis da 5102016, Wadd, posite @ ignaciomoling sobre &Brexil en nuestra especial: 1313 -CLS Spain https:/t. co/hZun5KIOAS hetos:fjt.co/Y1uABZyIYD. Stourbridge Brexitbacking Dudley MEP targeting the undecided in 23 Jun 2016, eutral News final push for votes: ANFXITbacking Dudley MFP RIL 13.13 - CFST Eth... hitps:/ftcofactl PnSFj2. Ack Cully Lo Breall, un Assiidohs pour Cva Thomponcl 23 Jun 2016, Mone neutral " Hex Taylor 13:13 CEST Gal, hips oo/HoguRjs | Br culture QuADb Zainaconda _ Brexit referendum today. Bors Johnson's [UKs 23 Jn 2016, far posite Doral rrp) VoleLeave wins, Cameron will step 14-13-€LS1 from down... tsgs://t.co/GZiMReuidT the maddin crowd Tamihetone RT @galub: Bret To be followed by Grexit. 73 Jan 2016, DIRTY 76 | positive alter Deparlugal lalcave. Fruckolf. Carchout. Ouria 1313 CST south Finish. Sloakout Lateruia. Byegium FA Tassosbilour RT @Kathimerini_Cy: RBrexit I/11- THT 231m 2016, Athens neutral is YETTA IGT MAL I+T/717 treferendur 13:13 - CPST hilps://Loo/kSryPKETLQ hips //LcoDTHXGOSpNY Fazal unkim Twondor i MIDS way carrying oul a cunning plan when 23 Jun 2016, T [posite he left the DWP? Hoping for ore power it Brexlt 13:13 - CEST wan? Worldarde RT @WorkdGardeners: Together ie can rake Britain 23 4un 2016, United 2 | postive ners Great" again by #Votelave today defying all 15:13 CEST Kingdo scaremongering Arex tl eaveFL) HF Ure ™ Tersabirkto RT @1378v: Claudio Borghi legal: “In una dersocrazia 23 Jn 2016, Roma a | negative Ail popolo che dove poler scuglice, non i 13 ost tecnocrati” PBrext hUps #fLoofrisaleAc] Karusconsul The latest KORUSCONSUILI tAgheh! 23 Jn 206, Ofterfin 0 negative t https: co/TESFevl 2€ Adoud ebresit 13:43 CEST 3 dperingla @dril when will your reveal your opinion on Breit] 23 hun 2016, London © neutral n 1313- CPST Fngland Actus_Culty Plus de 965% des artistes britanniques opposfi®s au 23Jun2016, Montrh © | negative © Broxit 13-Ast Gd, hetps:/ft.co/SFABCNs# Heulture Quigb eo Andy6763 RT @WSI. [rance daws eurozone economic rebound 23 un 2016, Norther 15 | negative amid 3€°Brexith™ uncertainty 15:13 CEST n https. ft caffem7FhBenk Ireland Teialton? RT @rwainwrghts?: Same sew repeated me and 23 Jun 2016, Fleer, a neutral Hi again by Lurupcan as well, UR securily chiefs 1513 GIST ogland hitps:/ft.co/KY7UFZODC. Orpheauz RT @Navashpakova: Wishing you the very best #UR 23 Jun 2016, neutral Youre just yards aay from the finch line, Arex: 13.30 - CEST From your neighbors across the pons€ nareshdnits The latest The Naresh dixit Daly! 25 Jun 2015, Bengal © neutral ) hip. f1.cafu57IqkDy Bi Thanks ta @DIpGhashBIP 1330 CFST ru @being2shubham @Vijendract bret Mbrexitomol south, Karnata ka Alroooh2 RI @CNGCArabla: PSU, UtUE UUs 0. 23 lun2016, kuwait 5 | positive @Uegs0L, B40, 1. 5°0°Gel. FLU 15:30 - CEST SE @ BESO BUSES https:jt.co/Pitykxaus! HONBCOS0"USPD #ERENIT Wonic Laat Pese s lias, confinean elecciones sobre "Brest en | 23 Jon 2016, Japs, © [reual H Rein Unico hips. co/ WLHSLEAGK> 1530-CLS1 abuso Comthiastils RE @tankero70: 10 ry Drtsh frends" oday I's nos 23 Jun 2016, 4 | positive 6 ar never” Is time to berate your country from the 13:30 - CEST FUSSRI Hest ote) eave 411 Bismarck NRT @JBusbpm: If you are unsure of faday then please. 23 Jun 2016, The 5 | negative L think carcfully for tomorrow Meret 15:30 COST Nether httpe:/ft.cofk7XEERMatp ands Toa_ch05 RT @chuksoleka: Ei NatworksManagar Wile 5100 2016, 16 | negative @avid_Cameran allows LK dtizens Tredor to 1330s acide on ABrexit he supports Nigeria killings cf éhiate BiRchapS7 RT @DavicloS 951945: RT Please take a pen tothe 23 JunJ016, ulster 631 | neural palling station with you tomorrow & don3€™t uses 13:30 CEST pencil Breit hitps://t.co/ OY Uynu0s Fiinessilon @CambridgeGreens Wetherspoons guy isnot getting 23 Jun 2016, London, negative don another penny of my money exer! €TimNartin 1330-CFST UK Wetherspoons Wrest ToGovern How wil ou vulc on ABroxil? Find oul how other 25 Jn 2016, The Tega voters say they vill Htpszi/t.cofegXiYASiL 15:30-CEST Baardro hUlps f1LcofnIRGPNumve om, Londen be unitaanline. @frexic Ure aperce nel Regina Unica. Fspuntaun 23 Jun 2016, positive nuove sondaggio 15:30 cesT https. ft.cofnProhy satiist indi RT @tcmecarthy_: tRerain voters are pushing the 23.Jun 2016, India negative an SUK ofl li. Vole Hleave, ABronit 1330 ast hetps:/ft.cofuvzKimg Shia gnc Oftimo pest di Lica Corbolants RBraxit, ¥eremains a 23 Jun 201, Tay negative ala Gerasi del media talon! pss cofeBXT BRINE 1330 CEST @terminologia sterminclogia Aids Finanalinks &-¥ Senses Closes Above 27000 Ahead Of Breit 25 un 2005, neutral fia Verdict; Nifty Up 56 Points: Indian shares rose sharply 13:30 - CEST und€} hg cu/xBl LLCO RTT Bothistele LU referendum; 5€°Leaved€ * & 3 Remainle™ make 23 lun 2016, Lure, neutral and final pitches day before Braxit pols open 13:30. CEST CA tps. £11.00 WADKyUEIC Welody1910 RT @Welt im Chaos. Auch interessant: Der #frexitist 23 Jun 2016, neutral 5 laut ¥Z0F cine Entscheidung Aber die 13:30 cesT “Fiwanderung” Non "Fluschtingen" reds: inewischa€! Ldyl Our friends un the continent showing sulidarily with 23 Jun 2016, UK negative the UE, let's not turn our backs on them 1330-CEST Bath & &vatekemain partiro hitps:/{t.cojyConPizsp? uth KevaRolls G7 podria cite comunicado 5 gana Bret” Thin 0G, Tabasco neutral hitps.ff1.co/PrSPHVO 1330. CPST Tanai12 RT @Bestinver. Beltrin da a Lastra ascribe sobre 23Jun 2016, Wadd, A Brel en @elpai_cconumia 1330 CST Lopudca hitps:/ft.co/EHIAIUKDL Ton payne] RT @lesveEUOTical PLEASE READ! A key arguments | 23 Jun 2016, neutral 1 made by @Slrongerin were demolished last night. 1347 CLS Know the facts before you vate! #EURe! hia€ | Saclalkickr The ‘Brexi referendum and ‘Game of Ihrones aren't 23 Jun 2016, neztive = all that different hitps:/jt.co/2e GHIXC2yx 13:47 - CEST baldonedos RT @danielmateos: #Brexit 0 #Bremain...mucho en 23 Jun 2016, negative ls mercados, financieras en juego. Me scaban de. 13:47 - CFST deci que hay Hodse Funds costeando encucie brenden_an RT @ShujaRabbani: All I'm going. Lo Lweel abuul is 23 Jun 2016, Washing. 658 | positive desur #Brenit. If you #ivated, vote your choice in previous 13:47 CEST ton poll tweet, 10 ADrexOrNoL? ALURETE | wabyhabnsu RT @Shulalabbani: #EUref is still trending. What's. 23 Jun 2016, Nevada 217 | negative u your Voted choice on Brest? To #EredtOrtiot? 13:47 - CEST Vote an previous tweet. HFUrsferandum £161 AndreToms RT @RaiPortaaPorts: Stasera alle 195 su @hailina 23 hun 2016, 4 | positive ‘ Speciale Aportaaports ABrexl 1247 cst hitps:/ft.co/GPHLZTCFOR RelmagineG RT @Frasarielzan: UPDATE: Chances of MGrexitnow 25 Jun 2016, Londen 10 | positive a down 10195 according 10 he Spectator’s he odds 13.47 -CES( 3€. and tracker: https://t.co/bishanDS https:3€ everyoh ere else seeks RerSiem, gy i marad hitps:fftco/pflVEsolds 234m 2016, Rudapes © | positive 147 cost coldfusion Lxactly whal the brexil supporters wanl you lo do. 23 Jn 2016, London © | negative: 8 Trade avanything for 2 nebulous futura for your 15047 - CEST children. Idiots. htpsi//t.cof1 ZPCMwhIl Ted Terr RI @V of Europe: Brexit spreads across Europe: Italy, 23 Jun 2016, Noord 260 | neutral Francs, Holland and Denmark ALL call for referendums 13:47 - CEST Brabant, rips f1cof AF wucSic p bps. 156 Nederla nd tric Cleon RY @lrancelyinfo: [QUIZ] Ces people anglaf sontls 23 Jun 2016, one 2 | negative t pour au contra #Bresit ? 15:47 CEST Gal Testez vous sur actu 35 https: coHWFTDAUEKS https £4¢ | John geoff Another good video with all the info sbout what 23Jn2016, |andon, © | positive er #Brexit would entail htips://t.co/6h31Ag1260 13:47 - CEST UK Peleriendl #Breait, for the WIN! 23Jun 2016, Coastal © | positive Where 13:47 CEST NC Vote | FAVE miss sb RT @thalastral: Frustrated to finda Lio Dam leaflet 25 Jun 2016, Brighou 1 | negative through ry door promising that Brexit would lead lo 13:47 - CLSI se, West Scottish independence in 2 years. a€} Vorkshir beriraamo So UICwill eather be ves po amsrica than ba 230m7016, the © | negative 1 brother to their curopean brothers? dorexit 13:47 CEST netherla nd WarrdgePik RT @Teleroltis: Polling station ordered to take down 25 Jun 2016, North 16 [neural © S€ Impurtiali€' England Has 1547 -CLST orkshir e Ritps:/t.co/SINHOTUBIG FEUrel hUps Loo fA530NIKGN Pauloxe @1leesdaled 1 James, "Ns kioking excellent”, bo you 23 Jn 2016, UK 0 positive know somathing | don't know? Le, that is axcallant 13:17 - CEST news for Brexit? Haok_Fcho8 | say go and good riddance tfrexit=>0n sue of 23102016, North © neutral defining British CU referendum, rivals ace for final 13:47 CCST Alabam votes hitps: Jt cojdsAOkcKOpk @Reuters a FSimpsonEY RT gol: Brest 10 be followed by Grex. Z31an201E, Winnipe 373 | postive Uepartugal. laleave. buckoll. Caechout, Oustria, 1367 -CLS! 4, Finish. Slovakout Latervia. Byegium. Wanita baruha Sise van dea UF vera dondevana randarasus 23 Jn 2016, 0 | negative hardas de borrachus!! aroxit 15:47 cos SharanBurr RT @equallimes: b voli for #Beel worth the risk of 23 Jun 2016, 1 | negative w losing Kjobs, srights and #wages? 14:01 - CEST hits. 1.080 fr https. cofs31JUNXNpr Warduja RT @elconfidencial: 0 racordamas cue ol Brexit 23102016, Valladoli 11 positive podris hacer que Cspatasporle mBis dincro dul 14:06 CCST d, Que recibe en a UE hitps:j/t.cofranL KIYCBp fac | Castita vLedtn lierdra ~~ @ntdemon Any new applicants to the EU do, [mean 23 Jun 2016, 0 neative that it Scotland brake after bresit and negotiated to 14:04 - CEST ein. festivaldepa RT @Brainandhloney: Forget RRFXIT Just Trade with 23 Jun 2016, 39 | negative 2 Trading levels Nothing che. 1406 cos https://t.ca/0s IEbRUXN https:f{t.cojpayiPEerfy Funkybanan RT @jackson_heather: Whatever your 23102016, yarishir 2 | negative ar sender etinicity, social mobility, sexuality please 1808-CST uk rarariser to vot today whsther #remain ar #trese] 166RO7S150 Jt placect my vate Aresit a5 long you stand by 23 Jan 016, Luton © | negative your conviction theres no right or wrong answer 14:04 CST Town EritainDecides anthonybilja RT @RT_com: FBREXIT outperforming FREMAN but 23 Jun 2016, 39 [negative nm UK polls point towards Brussel, Live updates 1408-151 hitps:/{t.co/t1BWBIUGM! SRTUKnews https. /ft.0of5€1 Ciecio? RT @sole)dare: Brent, aces core si sano schieratii 23 Jun2016, Ragusa 1 | neutral siornali ingles hits: /4.co/HADAGUGHOL 14:08 CEST aly hits. f1.cafIFPISGRYSS Nacho Pose RT @CunadoDeTuiter: Lo del Brest e 7180 us 23 Jn 2016, 756 | postive < deberRamas volar Luda: los ewropeos. Var-os, digs 14-04 - CLST Yo. PA RT @ashimiaul 20; mbecy ae 23 Jun 2016, 5 | neutral “CLA 73874 3 Had TAT 1008, CHART 14.04 - CEST BIER [23 ace mo BE AE a “3€2a:SegE GSN Turnoutin is $5503 3 SCP Brecher CH AH] AB A DR SEATS aS ST, IF | ¢ SME Sw nS WER STE, ES | EERE A Ne Ep El A REE RE ELIE of 8.3€73¢ Fieralating RT @suffragetiacing: Together batter Tun BLE, negative enobrexit 14.04 CPST Brent hrexitONo hips: cofFAumVFWDie Uhlapars RT @tr press. licona del dda @hberdichendky 23 Jn 2016, Paris neutral https:/it.co/IM¥90u3CakC https://tcofalime3mrd 14:04 - CEST Tagiabhosa RT @lamestchile: The Breit campaign dossnthave | 23 Jun 2016, Cardiff 300 [regains ni any politician that auld rake it to the end af a Wily 14.04 - CFST worl factory tour. Kwialic RT @cuecinharry: TheTimes today! #8rcxi. 28002016, New 21 | positive https://t.cofhDSAcesz0R 14:04 - CEST Zealand Taleyt1 RT @lasveEUottical: Tr rive race, Famale, 25 Jn 2016, Goletho poste leftwing, a 19yearold student and yes, | really arm 1404 CES pe voting for Brexit.' #EURSf https:/i't 5€. oranivarist Considering the weather inthe South East, looks Ike 23 Jun 2016, Glouees © [negative The Almighty right have decided 10 back ¢Brewt 14.04- CFST tershire uk SnowkreoTh RI @LouieMonschs Roses are red, 2 Jun 2016, 45a | postive inker violets are bie, 11:01 - CEST If you love burope But not the EU tel eave #arexit and ATakeControl hllps-f/Loo/LRIOKAE Smibier RI @HubCrawdunding In or OUP ILis ALL Abou the 23 1un 2016, negli Braxt aff Lynn of Seadrs Responds 11:04 - CEST its //.cofANpDCER ou Serosdfunding startup annameini WS) D3 Brexi: RIYRER fl, Den 230m2016, MiikTD negative k DeDKOIED, DTW B, DLOHDHBHENONY, 1:08 CEST fib £0300 A4D B, hte t.cof TGIOFURKE andrzejman Thunderstanvs and flooding cause polling day travel 23Jun201€, London, negative ka disruption live hilps://LcofLavlOjH2je 1308 -CLST Logland leacangelin RI @DonChampion|V: Lager to see the results of the 23 lun 2016, naples fl positive N #Breit uote today. 11:21 cesT Sharorow] RT @TheEconorist #6rexit n bref: he 17 Tings you | 25 hun 2016, UK 18 [nesta pe need ta knw before you vate tory HFUref 1401 CFsT tps: co/ KK KSlosa hips: ff Loo igesie Avy_Nalalin RI @Inlernaciunale: La prima volta dels Broxil, il 23 Jn 2016, Crolone 15 | positive: a piugno 1975. Le foto: https://t.co/0CAEONTUX. LA:21- CEST Kr tps #1Lca/ TECH 1x Halla IstClown TOR TUCK'S SAKE WIIAT MORE DO YOU SDREXIT 23 Jun 2016, England. © | negative: BASTARDS WANT? M:21-CEST Europe. @lzryTheRatl @TheOlifant @PepA_2807 https: ft.cofippparhicy eraigorius @sniftpetral Although maybe the most Brexit cariss 23 Jun 2016, © [ neutral Isla coming oul of autopilot, "ake ontrol”, 1321 Cust Savon ufc RT @ThaCraggus: Thanks to bath sides of the 2510201, Batten 310 positive LUreferendum campaign, Briain is this guy. 1821 Cust #5impsons ABrexi: ABetterln hitps:f/t co/JXL2ISLE1 en Freedom of movement enables students from all over 23 Jun 2016, london] © [negative thes UCB FI to study abroad via the ERASMUS 1401-CFST lor scher-e Brexit would complicate this (1; Frosenll RT @DessinsScidoon: Coat aujourdhui le vole du 23 Jun 2016, 15 | negative rexit MirexitOrNiot hitpe:/jt.cojhbiugHi3i 14:21 - cesT htlps-f{Loof£SIIC2r9m Wareas7Tru RI @norcoreano: 2015: Ll breil vente, Reino Unido 25 kin 2016, log 76 | negative <a sale de Europa. Inigrantes flegales sspailzoles satan 14:21 - CEST In wala oe Gibraltar para comprarse dfpamk RT @Shuabbani: ¢FUiref sil rancling. What's 31n2016, Penns 20a | negative: your #iVated choice on #Brexit? To #BroxitQr Not? 14:21 CEST vania Vota on previous twast, #EUraterandum #36} jacobinmag Rightwing forces are leading both sides of the Brexit 23Jun 2016, New neutral debate. hits: ft cofafl MNINMQ 1-CFST York cy ForcxAnalyli #AUD 240 slepping up nicely nol just KBrexit 23 Jun 2016, United © | neutral x1 #ThesalinesWork Please AT https:/ft.co/aHFaIDAK2d 14:21. CEST Kingda m coachhryer RI @steverurfley: After all the Sbrexit hype, it comes 23 Jun 2016, 1 | negative: down to this https:/t co/stoytnohill 1:21 - CEST Fndreesanl RADIADrendum Brox le RayaumeUni reticni son 23 Jun 2016, postive souffle https:/ft.coffulnw6Tud via 1 eDevoir 141 - CFST SayFdds Parsi quieres hacer apuestas en los mercados antes 23 n2016, Fepafica negative do que pase ol Breil No bresit 1821 COST Madrid hitps:/ft.co/AVENCrRINL DeCatherin RT @jeanlassall: Et si aufond le brant ATtatle 23 Jun2016, Bratagn negative AEEbut d'une nauselle &'re pour TET Une prise de 14 21-CEST #, conscience #BrextOMNiot France itp. fft.caf3€} retwesting] RT @)geckosjave: How many people remember the. 23 Jun 2016, negative © 1973 HBr referendum? 67% for Remain’ 12 cst Erexitortiot Oster RT @MylesUclland: Brexit supporters are urging voters 23 Jun 201€, Los. negative ta take pens to polling stations over fears of an Mis 1421-CESI Angeles conspiracy https:/it.co/UKLOHS3N 4€. BWPublicati RT @JohnKremer: Sodial media companies really want 23 Jun 2016, positive ans ou ta know that is Brest ving day: 401 cFsT LONDON 3€” Cn the day of the his... https//L3€] butbyes @chopones? Dlordiesteds Ive been an done the 23 Jun 2016, St neutral dacent thing #6raxit Abottambei 1:21 CEST atthe ws Leice stent GLAND WutedOpti RT @Barnsley: Brexit” 23 Jun 2016, Oxford 302 | positive mist 438 - CPST #Wha an overweight Barnsley ass does when she sits an 3 whit plastic garden chair. #harnsleyisbrill nicks Apparently people of my pen arc inclined lo Abroxil 23 Jun 2016, Tueeella © | negative appeasement was wrong in 1030's wiong today. 11:38 CEST nd Vote for against fear vote Siterain Wahwer RT @nissingfaktor: Brest. Great, Depart, 230m 2016, England, 5385 | postive Italeave. Fruckoff. Czechout. Oustria. Finish. 14:38 - CEST United Slauakos, | revi, Byngium. Kingda m dopayworey RI @GraTire: The People's Convention want Breil 23 Jun 2016, Lurlh 14 | negative dooca Referendum & supports FBrexit, Wa ran out at flyers 11:38 - CEST on Saturday, big demand. hitps-//1.cod¢ | PRG RI @OuchiknKarim: Day. AE quand le 231un2016, Monaco 17 | neutral dhiCharquement de la di @mocratic AQHA Drendaire 14:38 - CEST sur las plages de France 2 Birexit | rosiewhiteh RT @b_judah: My @POIITICOFurape 23Jun2016, landen, 2 | negative use #ReferendurRoalrip rolls intu Romford. Rage, 14:38 CCST Cogland Romanians and rar-pant conspiracy theories. rps fft.00/7N F141 56} phy_slysia RT @HappylionTweet: #Sang for this important day: 23 Jun 2016, Silicon 37 | negative. Should stay or should 1 50 row? 1438 COST Valley arent MT @Puniandsturf #TheClash hittps://t.co/Lnlgs€ | _Marketfdg @Bedalchall if #Brexit vote = leave does that mean 23Jun 2016. USA, positive : aur colleagues. from the cantinent can na longer drink 14:3 - CFST UK, @YorkshireGin?? @earolincrr acc Brasil, Switzer! and myramyre Oya, skeng ya referendum brexit 23 Jun 2016, surabay NA 138 -CEST a =) FoF aciChecking Brew The Condusiones by 25 hun 2015, Obscure neutral @hughancack hitps:d/t.cofNT74FHHMp. 1438-CFST bad in thes k system Savusiaba AT @norcoreane: 2015: 1 brexit vanes, Reino Unidas 23 Jn 2016, Espafi-a negate cals sale de Luropa, Inigrantes legales espaiboles saltan 18-38 - CLS Ia all ce Gibraltar para corprarac GeelAn_DE #Brexit. How will itend ? htips:i/t.co/658dmBleq 23 Jun 2016, Everywh neutral n 1438 -CFST ere aioleil RT @albertopradilla: No entienda par quit los 23Jun2016, Tizur 37 | negative. espaitoles ro colin volando sobre cl ABredl ics 14:38 COST Nagusia alga que les atecta tamsiAn a tedos. (Navarr al Kevinbantz Youre on your own SPX FADE BREXIT and buy SVX 25 Jn 2016, Lake neutral upton hlpsif/LcoltANsAIaY 1435 CLS1 Havasu cic 52 Glendathor Busnas kas PBritAiricos Getiden su Tatura y dela 230un 2016, Atlanta posting > Uni Furapes referendum Alrexit 1438 CPST https:/fL.co/2IV/OUAFKDY 2500i0c hits: ca/NNAaGOUAOU zaundersl Britain is oa rest ta vate far Brexitl Check out the 23 Jun 2016, positive a iemportunt opinion pices by @Avae LD Kicken Patel: 14:38 CLS1 https: ft.co/ XIN3OSIFSI PeopieEngin Starling Rises to Record 2016 High Ouing Brat Vote 23 Jun 2016, postin cor tps. //1.00/GRYPBIKIAL TIME 14.38 - CEST hips /11.c0/SLAS Rube moore_patii RT @BlucgilRiscs: Britain has giver the world so much _ 23 Jun 2016, 13 positive dia and rust stand tall Wotelaave 1:35 - CEST #Brexit BEUref AndependienceDay @Nigel_Farage hrrac. IMAPictures. RT @Int¥ogabay: The Sigh OF Mire How May Fifect 23 Jun2016, Delhi 3 | neural UK, BankingSyslern, Sec From This Uned Up In AQue 14:58 CLST Murrbai Today self) @Bharatsolar_hutps:3€ Kolkata Chennai fnalcountdd RI @DitzEuotidianc: brext, ll anflEuropa dieona 23 Jun 2016, Piinia 2 | neaative wn voto truccato dai servizi segreti 14:35 cesT itp. fft ofthc Oke RedDave1d RT @brian_bilcton: Hera is an FU Referendum ballot. 23 Jun2016, iPhone: 0 | negative papr which | have conver into a poem. 135 COST SL8137 hitpe:/ft.co/QUTAOGIE! a2. rex sbremain Bacco 2 Repeal the RT Bessacerdstal Dear WRermaim with love from Zum BIE, 75 [poste fet frnedam losing people cveryhere Alexi: 14.35 CPST #Votcleave hitpsiLcoftigaBYTpr3 harshkone RT @iar-srk: | cs rend in News where lcaving of 23 Jun 2016, 3631 | positive somaone ar something is headlined as Rex ar 1:35 - CEST Bread So i | eave ror sur-swhere am 136} Shreyasonu RI @armsrk: his tend in News where leasing of 23 un 2016, Karachi, 3661 | positive Holic somacne or somthing is headlined as Rest ar 4:35 CEST Pakistan Brest So If lease from surwhere am I3€} Asho0038 RT @Hhjpimganrd: I'm holding aut or the. 23102016, Negal a | negative #BunnicsAgainsiBrexit https] Lco/eokTSDIMKie 14:35 CEST eUrer Toveza | Very interesting Hsocameda sentiment analysis of 23 Jun 2016, Dubai, posite rex ALUreferendum ALUreT Woot uA itp: ft.co/2vCZpHRIL Tail LIVE: rits EUreferendur wal of geen Braxit James 23 Jun 2016, Amaterd [oy Rand i profi, asi Fairy gaat . 1435-CPST am, https: co/GudxawPn3y https: cofhvy FQpyin2 Nether! ands DGTrading] Equities pratty quits here shead of Fhrett good 23 Jan 2016, New © [negative a riddance, 2am can corr soon enough Lash CST Jersey CARLGRGUZ RT @Ananpress: Fhe UK media vias more concemed | 23 Jn 2016, Xalapa negative WANL with ell people the acts rather than wha todo 14-55 -CLS| paople might bea litte ess unsura€ SPulnIC Jp #BREAIT SGERECERS,3FA3 3,3] SIVELEl- Tun BLE, posting SHIPS, HET ein B33. PT 80 1435 CFsT https:/fLco/b7UF2Lnyi itp: t cofSHiluTymsh Hitech guru Brexil Would Leave Geran Stranded Against 2510 2016, Toronlo positive Fresioading South 1535 -CEST Canada hitps:/ft.co/ey EYIFDSR JakeRicholls RT @LouiseNlensch TIS pall Tkely voters FUoteleave | 23 Jun 2016, Ipswich, neutral a 49, Woteherain 47 frexit SProjectilopa 1435-CEST UK hips 11 cofulDleax } DavidS25t0 Yep old Ben got that right Hope Britain gots right 23 kn 2016, Georgia, positive ne today #Brexit AMAGA hitps://t co/LAnSIXBGHX M35 CEST Usa mamitamu RT @todonaticias: Brext Ira votar con supery | 23 Jun 2016, CARA postive mu sacarle una fata, un extrakta tradicifOn britkinica 14.35 CPST rgentin hilps:/{L.co/310VpBELCR hilps:/jL cof3€} a hoisser RT @PalvPelers Brel: Decision Day En 006, neta https:/ft.co/NCOQENTEFC. 42:35 - CEST Wyrvangar RT @RT_com: ‘Hysteria and halftruth Refuges wil 23 Jun 2016, Earthiin negative anika nat disappear whatever the Abrexil ole outcome 867 14.55 -CES| 5 charity hitps://t.cojuOEdTEERTG bookishipo RT @Avaar: Let's make sure we're on the right side of | 23 ln 2016, UK 737 | negative anie history. Chaase love en £VoteRemain, 4FURef 1435 - CFT Breall AStronger iN hilps://L col DOBWADGHA TouGandelr Brox good riddance or a now Luropel TnI, San Tegalive an https:/ft.co/FObmaoitas 15:12 CEST Diego, ca frenchfll RI @nigelshortehess: [he most vicious, divisive, 23 1un 2016, positive mendacious campaign will enc today. Whatever the 15:12 - CEST autem, amy peaple in the UK will be 3n3e. Magu men RT @F| Universal Nix: FQueNoSeTePase Fncuentra 23 Jun 2016, negative doc aud Lodu bo que debs saber sobre of #Brexil 112 cst hitps:/ft.coNDAEIOpDEn Col_irreleva RT @WooTube: | had reasons to vore for RBrext but 23 Jun 2016, Europe negative they were massvely overwhelmed bya strong need to. 15-12 - CES crush racism & economic das of thed€} (3725505 RT @assemblea: No referendum No democracy ABrerit 23 Jun 2016, WA hitps./ft.cofRsndrrsal 15:17 CPST Ganbata_so Bret Poll Shaws RO% OF Americans Think Bricain 23 1un 2016, positive ul Should Leave LU hllpsif/Lcof¥a75nKI Ga 112 cust chet RI @Wilkil: @CBGMormingshon Dobhih Abrexit 23 Jun 2016, neutral "With Or Without You" https: co/cOS3HZTIe 15:12 cesT Wapnitops RT @ElzabethHurley: Vote tororrowahataver your | 23 Jun 2016, Clevelan T00 | negative ulus. perssacion. + for Bfrexit & pramice to nether flast 15.1 CPST d, Dl nor whinge. But VOTE! hitps:3€} Surclicela RT @Danit_Porlran: hitps://LeafhC30FINFr Being 23 Jun 2016, RAD 5 | negative nie putan the samalist 3s Jamas Bond and Hermione 15:12 -CEST Granger made rae fowl quite cool, Bering) Parken ne Clockeowerc "World Leaders on ‘Brexit Vote” by THE NEW YORK 23 Jun 2016, [positive a 1IMLS via NY hllps Loon 7BRIBOE 112 - ast Dackalfice; RI @burgercombeeu: Come on dear friends Inthe UK, 23 Jun 2016, Neder 16 | positive 3 Lead by example. Leave the EU! Wa arc hoping fora 15:12-CEST nd rex! Then a #llexi Tressidelo @jerer ycorbyn twafaced hypocite. Howrmuch is 23 Jn 2016, (Tressid © positive. © @GoldmanSachs paying you? AVolcloave #Broxit 15:12 COST © FaublauDK RI @yo_LLOR; Pleas Briksin voto lo stay ww, so we 23 Jn 2016, copenha 1 negative can hang and chill and have gad old fun Europa tives 15:12 -CEST gen rexit Abremain hitps://Lcof5€ noraleland RI @ahe es: Los Aeltimas sonceos dan la wictorlaa la 23 1un 2016, 42 | neutral v permanencia de Reina Unido en fa Unikén Europea 15:12 - CEST hits. /f1.c0/ONpomIACs: Hrexit nit "jorld leaders on ‘Brexit ate" by THE NFW YORK 23 Jun2016, _Santiaga © neutral TIMES via NYT The Hew York Tires 15:12 COST de Chile hitps:it.co/NQSPalswOn Tabiencham _ #Brexit Harlem DADsir (Afaires earophennes) sor 23 Jun 2016, Paris neutral Blanc. der son silence: "Hollande verra Merkel avant ls 15:42 CST Comcil curopBDen de rardi Sministrcluntome TwhiteAliee RI @brexohil: 11m voling ¥Brext Lumorrow because 23 Jun 2016, Teg ub the EU want to replace our British Jesus with Zeus, sell 15:12 - CEST us cheese with holes in & they 54 | tyrele123 RT @AMTrumpdPRES: This is yaur future, believe For 23 4un 2016, Audiral positive notislam NEVER invades to be cqual but 2 DOMINATE! 15:12 CEST a Breit Wael eave Hanlslam hitpsi€. Flemingtond RT @Sputnikint: If Ritain goes: Three passible 2312016, Sydney, negative ES soenarios of #Brexihilps Loo HIVGsixlra 1512 CST New #BrexitOrNot https://t.co/ESLVEWShD South Wales, cluffetellima rexit.un da de perros para votar 23 Jun 2016, CARACA neutral ss hitps:it.co/OnbvuHuly. 15:42 CEST swaLa kebarberita BE katakan roxit tidak bordsmpak langsung bagi 23 Jun 2016, South negative Indonesia https: /1.cofVIOH3r zed 1529-CFST Fast sein Trestodlcal Broxily L quando ra ci sora enlrall nA Luropa? 7 Jan 2016, Milano, | negative te hitps:/{t.co/FuSuPYCRe https:/ft.cofiSoTTTACOR 15:20 -CEST Italia, Wiondo, Owunqu smartaurs @CNRCi Verdict i fret 931un 2016, Waridwi of wn 1529 CST de Barburat31 RI @AMIrurpaPRLS: As mushien population 23 Jun 2016, Virginia 55 | psitive averwihelms al of EuropeUK has 2 chance 2 take 1529. CEST control. wil they have the courage? Beat hitps:/a€ | Tatika UK voters head to pols for Srexit referendum by via 23 Jun 2016, 22 kom neutral Stars and Stripes https://1.c0/SPhyIRFDDN 1529 -CFST SSWof nowher e special CNECTVISL _Brexit Vating Underway: DAX 10104 68 +1.23K: FISE 23 Jun2016, India © neutral vo MI 1772.83 2.80% 1529-cu51 Tangs Sleapless right ahead! Referendum results guide 23 Jn 2016, Ace © [reual when Lo up and Lhe places to watch 12-ast 521918 hitps:/ft. cof LXEB]AYAp Kbresit referendum alerts 2012 4541 EnicksTaR RT @hamyapt: or Brexie Day, nt367%% play my 23m 2016, New 333 | postive favorite game: Zoom in on a random patch of the UK 15:23 CEST York and laugh at the place names. biips: ft ca0sé TevanforTru Watching from acrass the pend Vote cut! Say NOts 23m 2016, Gad positive mo NWO Let Turkey hive your spol! iBrexil Auleleave 1529 CLT Blew #oteout America ngelavaido RT @Emor AERO | Los claves para entender ls 231un 2016, Chie postin wine consecuencias del Brexit hich ff oofgocZémixse 15.09 CEST hips /1Loofhn7Cniyo disranticeu RT @FeistyDannc: Another fw voles for WBraxit thal 23 Jun 2016, 12 [positive felt good Kivoted W/otaLeave 4TakeSackCantrol 15:20. CesT Hits 11.00 /BDIZRGNIWX ninabizzinti RT @repubblicat. hres, i Cinque Stella searicano. ~~ 23 Jun 2016, Reggio 13 | neutral no Farage: "Luropa sf carsbia solo restandonellUc” 15:29 COST Calabria hitps:/t.ca/oqI7GhahHS Elacpalai Tal VL Tl HCL Bl 1, i, 23m 2016, Tid. © | neutral FT Iui TACT TAT ie eT. 21 east iis TaD | MgiePTT: PRATAT bs el Tighe bret Abteror RT @mankeiser: Good morming. Chance of a @hrextis 23 kn 2016, New 8% | negative 03%. The idea that Srits step off this gravy train is 15:25 CEST York, NY absurd. Go back to sleep. TanioHQ @iohnkassd8 SHalsrathink Prediction markets hava 23 Jun 2016, © | negative say aL 50%, IU nul close al all breil 129 ast Ghvehrana RI @Adrianbeenen: De awokste schakel in de 28 0n 2016, Heder fezitive #democrats i di omvatands burger. 15:20. CEST nd Geen diet. Alblelucy Hos Furope will break on fest according fa 231n 2016, Brussels negative @POLITICOLurope hitps:/{L.cofHinyDpTYRS via 1529 cost, Belgium Freedom Wri RT @Schuidensuehner: Final Ipsos Mari RBrexit phone 23 Jun 2016, neutral teres poll just published shows Rerrain al 52%, Leave al 15:29 -€LST 13% s Poll from JunLE had Remains€ Tevsarahga "Ereitis propelled by the same vagus antimrigrant, 23 Jun 2015, Austin, negative ¥ nationalst sentiment that Fotivates ... Turp voters.” 15.9 - CFST TX hitps:/iL cojwkSsIUBHKD Vasaraham RT @Davidlo52851835: Stuff i up your luncer 28 Jun 2016, positive mer hitps:/ft.co/RhTEBLEch 1529 cesT SWStrongen RT @BECCormwal: ? Corral has bensitied hugely 23 Jn 2016, poste n from EU funds] a postarexit government maintain 15:47 -CLS1 same levels of support? PEUREISH Phaeria_ka Im #ahosrix Studia spricht Sonja Fubrreann mit Tun 2006, Bonn neutral ™ Holger Gei flor @YouGav DF & Tanja Bfiel 15.47 CPST @FU_Berln 16h ¢Broit https://t.co/jeqar- bing forexDailyT FISE: Global Stocks Jump as Broxil Odds Tank 28 Jun 2016, neutral A https: ft.co/S2Sm Such 15:47 CEST Ciistina Cus Goital EI primer cue man pantufat aul noms 23 Jun 2016, Sarmi - posite w@ arribar a ka City {previa pregunty, of coursel¥Brexil 1547 -CLSI Barcelo https:f/t.co/rNWz2Xij5k na- Catalun va asplandSG RT @Wotameron: Us at moron think all mp'sare alla 23 Jun 2016. England 83 | negative waste af ime, bUE hare is our fay. rexic 5:47 - CPST ilps: cord HIAEYNZ hada RI bk news: SE0330-51-364 25002006, wait 138 | negative 515,315, 3 bam “zeSegy 56" 15:47 - CEST Sendai, AT HEFER ACL AG BAA EAS gi Aes, STET ACH, AS, Sat Ba, AAs wl SA MEOH CLALETE | 3, S43 HE, itp. co/IPOGAD/la Snhk_news https //t.cofKLykn | Suhl Tres Torres The question is In or ue ese ¥brexit tain 23 JUnJ016, Frgland © | postive ter 15:47 CEST meifanOshic SIS. 5995 wreck S|ESIERYS, 83732§Bronitie"d 23 Jun 2016. &, negative hong FSIS, 3000, 5 5, 15:47 CEST aneen El-ded ej oti water Aer wmorillo "Quie: The S€Brexit3€™ Vole Is Here. How Much Do 23 Jun 2016. Cn algun positive You Know? by STEVEN ERLANGER and HANNAH 15:47 CEST ugar dla OUNLNRLS via RYI hilps://Lco/TUCILAGIEL Wancha creo ait Gh =hit. ABrexit ABrexicOrNot AVateRer ain 23 Jun 201, LON/DX. T [negative itp fico 783759 15.47 CEST D/DARS . Heo AUbcbe WUKWBraxit VILE Bilfonaire Open Borders Funder 23un 2016, Proud 0 postive Soros Tells Britain To Stay In FUSE Or Flse: 15:47 CPST ubum Fur SOROS BVeleLeave hilps:{/Lco/GNVPQHLEHT Tiger war tagle! dbenle RT @arketWatch: Stocks In rally rode as Drexic vote 23 Jn 2016, NY 11 | positive gets under way https://t co/UyUzxRNBgu 15:47 - CEST BrendaPach AT @sleconomista: Con o sin ABrexi, Ia Uniien 25 Jun 2006, Wiexico negative 2coP Europea no ser la misma... Te decimos por QuAS: 15:47 - CEST city https £t.cafYAaabasdmLI hitps:fft.cof IpCfCAU3ae] AnnaSophia RT @HaliansaTrummp: God Sears ta Na Veting for 23Jun 2016, Toronto positive _Tors Brent Breitbart 15:47. cesT 60D WL NCLD YOU AT THIS MOMCNT! Voteleave tleave FBrexit FERS! hips:/3€ | Choodieum @lohnClarke 1050 &YourkirEumbles Sor in London 23 Jun 2016, Camual positive ma in '32 1 soon learnt who could be trusted & who could 15:47 €ST | not. Brexit leaders r not ta be trusted. OnStar as RT EN arshallEla: rex voters ara the type of people 23 Jun 2016, Munerk a] poste bh who go on holiday to Spain und requesta full Lnglish ~~ 15:47 -CLS1 in land breakfast everyday. Sanderson RT @FFA_ORG: The #Braxit vote s today. Here ara the 251un 2016, Alanis, negative argument far and againet remaining in the Furopean 15.47 - CFT GA Union in one chart. https:/ft.co/23€ | happyburke RT @ionahaakblog: "want you to fire me." 2510 2016, Toronlo positive an @DanHamnanhIEP gives 3 superb ABrexit Lasve pitch 15:47 - CEST al Oxford Ontario https:/ft.co/HEUEACO TasTak RT @ronaldlaessig: In AGroAVbritanmien hat die 5100 2016, neutral #Brextabstieir ung begannen. 36,5 Mio GA irger 15.47 - CFST aber sich reiblricren ase und KSNinnen bis 226€; soottsicpker Da you find the term #Broxit annoying. {| vote yes!) 23Jun 2016. Des negative: 15:17 CEST Wioinas, loa NerdFlert if use get the expected Drexit Stay vote today. ashich 23 Jun 2016, negative we will noi about Jar tomorrow [ST .. smallcaps. 15:04 CEST will explode tororraw iro Shockster67 #ioted Wrexit Weave 23102016, Vorkshir positive wos ase lle las tall gbrexit hitps:/ft.coffilséaily 23 Jun 2016, negative ed 16:04 - CEST honlnbo RT @golub: 'Brexit’ to be followed by Grexit. 23)un 2016, 127.0.0. 1776 | positive Departuzsl taizave. Fruckaff, Crachaut. Oustra, 18.04 CFST 1 Finish. Slovakoul Latervia. Bycgium. Tavssen | 8€who conspiracydte: BRLXIT lradumark registrant 23 Jun 2016, Cologne neutral an using IP to defend paliical discussion World 16:01-CEST Trademark Review [53¢] hilpsifit.cofEXple) WI German ¥ WEEsen Traders eye bia opportunities afer Brest vote Tne, New rewtral #Hedgef unds #Mraxit ¥UIKAFU @rdc 15:04 - CFST York, NY https: ft cof Tejmrsiy Cevlrar #internacionales Inmigrante china a favor del Brexil 23)un2016, [nlavi neutral porque su “er pleado espafzal siempre esth; 16:04 CEST a darmido” hllps:/Lco/TAphsS LL} kazyl arr Stephanie | landers beim Hlandelsblatt: 3E2Ein Brexit 23 Jun 2016, Augsbur negative whrde die turke Enger verunsichernat 16:01 CEST 3 tps. ft.cofur rue Goren ¥ roxyloveslue @CliunaBenadur @dswngpsalmé3 . Please #Broxit!!! 23 Jun 2016. Indiana. neutral ¥ its thair fast hope. 16:08 - CEST Cyberhctual https://t cofpNooScopeh UBNDration fr: Un Braxit 23 Jun 2016, negative ite coRmlerait 19 du PIL aux Busses 1504 -cist hitps://t.co/TrQeSEbydG Tarbas RT @Daviichat: PBrext down to 157%, lowest Tun 2005, 522207 hegative kelihood of leaving since BPredictiVice trading 15.04 -CFST 35415. started 1/1/15. Aso, Pounds just hil yearly ha 458034 5 Seren Dipit_#Noticias Inmiarante china 3 favor del Brevtporque | 23 Jn 2016, Caracas. neutral va? st "erpleads espadol siempre est; dormid” 1504 cust hitps:/ft.co/olPuaUCIFS #0eTod olinboc Johnny_mat thinking about my friends wha voted in todays€™s 25 hn 2016, San © postive thraxituote 16:04 CPST Francice o.cA jeremynwal RI @ietSellerkyan: 805% of Aricricans think the UK. 23 Jun 2016, 51 | positive ker should leave the EL. Theyre right. fread 16:01 - CEST £ChooseWisely https://t.cof7pHIROGKFm bolsarmania RT @lunalosefi 10 fondo. de inversi®n para ganar 23 Jun 2016, tadrd 2 | neutral dinero con ol reforADndum un Reino Unido, hayaa 15:04 - CLS no Brexit https cof MjShtx JE Aa SBals€ Fle RT @6_Dussausaye: a rAGponse & GVOANews: 23 Jun 2016, barseil 7 [negative 360m wl ive the British freedom, and it willshow 15.04 -CEST we can renegotiate EU treaties. #Bresit huipse ot ares RI @CalcGoopalilico: BBrexil por TAIa A regh 28 1un 2016, Poste #Regnolnito rianga o esca dail ¢UE? Diteci a vostra__ 16:04 - CEST Tambo_unch I'm weirdly excited about the #Srexit vata today? 23 Jun 2016, positive ained 15.04 - CEST Fianfichard Drie in Germany eft furving! by Brexicpoling card 23 Jan 2016, 1eksinkd, negative son fiasco hitps://t.co/YbOGDNATe via 16:04 CEST Finland @ThelocalGermany Horonzoud RT @valkskrant: Erdogan overwaest Ak en 23 Jun 2016, negative referendum over de LU Le howden Mliveblog Abend 1521 €LST hitps:/ft.co/WKUP3TLID tps: cojySFTuHrmhg nkermttus RT @galub: ‘Brexit to be followed by Grexit. Tun IE, Card ToT | postive es Departugal. aleave. [ruckoff. Czechout. Oustia. 15.21 - CEST Finish. Slovakout. Latervia, Byegium. machincOL_ RT @Snomdon No matter the outcore, werent polls 23 Jun 2015, 5 | neutral Pz demonstrate how quickly half of any population can 16:21 - CEST be convinced Lo vale: against ise, GRE} mwengway @ReDelineLurope @LUWalchers @Sharel his Bulbhil 23 Jun 2016, vlna | eBret 16:21 cesT ‘Seprimecam Devemos ficar atentos 5373 3 pequEns, mas posevel 25 4un 204, Forte © reutral bio. hinAPtese de "Drexic” (sais do Reuni Unida da 1521-CFST Alegre Unid€o EuropADial arranha. {continua sreatidtya RT @phiblockworld: O Broxit Day! Callooh! Calley! 23 Jun 2016, Wichisa 26 | positive u SSCHN $5PY SCLF Futures hitpssfftco/NVWINps) 1621 -CEST hlips/fLeofjeder2LnsL Yewetletery RI @Snowden: No maller the aulcore, #8rexit polls 23 un 2016, Sion 6 | neutral quiz demonstrate how quickly halt of any population an 16:21- CEST Valley. be convinced to vate gaint self, QE] peoss Presi Feplainecd 230m 2016, SCT © | negative hitps:/Lco/DEOCHWSIKK. 162 Cos fii Tee is GARCIac RT @ClementCin: Ja sus contra Ie FBresft mals je suis 23 Jn 2016, negative ueli2 pour fa Darr du modi'le europADen | 1521 -aust #BrexitOrMot Tacketnews Even France would LEAVE tha 3€ 5aa2¢~ EU Fit had a | 23 Jun 2016, © [poste refersncum, top french philosopher say: 3821 -CFST hitps:.co/ FN QBMLis NolihoyPeru Cncucsta | 55 % de los bridhnicos estiin encontra 23 Jn 2016, Lima, © | neutral del Brexit >>» http t.cojActeznsyl 1621. CEST perke hips: {ft.cof\g3chrORKg notihoguieh Encuesta | 55 % de los briinicos estiin encontra 25 kin20l6, Veneaue © | neutral dl Brenit 23» httpsit.co/COenGFUD| 16:21-CEST a tps. f/1.00/17pP5YbLIm bethancrow RT @WilfredFrost: What could follow rex? leave. 23 Jun 2016, | positive don Cechout. Qustria. Finch. Slovakout. Latcrvia. 12 cos Byegium. Or roy persons favourite D3€ | Ceifrance RT @CCR_NardFrance: SEREXIT Quan persent les 250un 2006, Franca neutral entrepreneurs franfgais vin @ccifrance 181-CFST Paris hblps:/71.co/NZTORINK hitps: Lol TomuCRi wi Sillinger CORK Fisch ab Presse: Dic Zeilungen haben den 23 Jun 2006, Clings neta Brexitoden gelegt htips:jt.cofS APE 1621-CEST n WelyndaCar AT @scottdgordon38: | tain for the #Brext AEURE! | 23 Jun 2016, Siicon positive diel vate with @Umdstr & unlocked ry awn lg Profile 1621+ CEST Valley pict What wil you vote ? voted hits€ Sater AT @paulwaugh: Cus to how strong the Breit vote 23 Jun 2016, postive In Berr-ondsay newsagents this am, shopkeeper, his. 151 - CFST wile + all customers buying paper wi€ | Way Kidd 23 Jun ast yr made a Broil of my awn] Carl Tn I06, Sydney, Tegalive B believe i's been avr, full of 16:21-CEST Australi adventureschlengesice” §°€3037E 10 the neat.) a simonhal19 an these people are being allowed tovote taday 23 Jun 2016, positive 7 #helpus Abraxit hitps:/Jt cojeX5e3RTY 16:21 cesT DanclaEl RT @Snowden: No maticr the outcore, ¥Brext polls 23 hun 2016, Wadid 5 | neutral demonstrate how quickly half of any population an 16:1 - CFST be convinced lo vole against sel, GE! Theayred RI Bovertonlez: sal shoul who do you nie the 23 Jan 2016, Tega mast #Brexit ARemain fcidebate 16:38 - CEST ilps /1tcofv2la crit fosyiour RT @pascalbauche Qual de rien pour lstrer fe 23 Jun 2016, neutral chois historique qu offre aux Anglais! #Brexit 16:38 CEST #Gofirexit HFA https. //1.co/0TUXRKGCls Gide carlo RT @Australlaumuiak: fotel eave foday To secure 23 Jn 2016, 7 [poste Breil Thisis the Fulure nal swaily ws should we 1638. CLST #otaramain @Strongarin hitps:fjt o/c! Stephend2] @LeeReynoldsDUT Spoke to Cary Simon says she’s 23 Jun 2016, _ Belfast negative sar? “leaving on a Jet plane doesn't known when shell be 15.38 CEST Norther back to EU again” #Brexit n Ireland Whoshauldl RT @USA_FRFFDOM NOW: Godspeed, Whrexit Stick 23 Jn 2016, _ United positive Volos iL Lo the global. We §Trrp warriors stand united 15:38. GIST Slates with you. Slexcapron Les Brith, vous prendre bien un croissant 7 3102016, Parks reual operationcruissant #rex Ort Greil 1635 cus https: co/ceOVKU3DFG TaviclohnIL Funny how Europe are all ver us with supportand | 23 Jun 20LE, _ Biring © [postive ans praise 0 sta... where was all this interact when we 15.38 CFST ham, performed in the Eurovision #hrexit England UscikY Brot: Things To Know About rilsh Vole On Jn 206, brasil © [ negative Leaving Eurcpean Union: A major vote wil go down 16:38 - CEST inn... hillps/fLoofQEYSOVIBNG AN aliwSdy StuySquore We snlicipate the Arex woie wil be lostoybys 23 n20L6, New 0 | positive narrow marin. #Erussels chastened. Britain 16:38 CEST York empowered. A goad outoame al around. Ronin IP Could the ¥hrexit bookies be 230mo0t8, CT © | negatie manipulated *hitps://t.co/L7PoTBHIs1 15:38 CEST Sucvanler RT @NOS: Ongeach do uilkormsL van hl 25002016, London, 5 | negative t brexitreferencum wil Merke! met regeringsleiders 16:38 - CEST England praten over de toskarst van da FL hilps:/iLco/LGLAE! johnodonne 1s cinema shooler in germ any going Lo influence 23n2016, Brussel negative 21 resi referendum? His motives unclear. 1638 CEST & Hrankiur : Gretel and @BrtslovePals fingers and toes al crossed for 510m LE, postive en bres. You con do hic Britain. You sel have what 18.38 CFT made you great. Pepecongal RT @NissRoxyW usic: Si ol Brexil jode al dAflar, usted 23 Jun 2016, Guadala, negative eo va sabe lo que sigue. 1638- CEST jara de Indiss matiels7 #Brexit right be the best thing for the UK..but it 23 Jun 2016, Johanne: negative dosn't lock good for the EU 16:38 CEST _sburg Cantiingh Comently Orifing towards EU__ABret Core, my 23 un 2016, rewtral fiends, Tis nat ton ta 0 seek 3 ewer workd 83R-CFST SINGAP https:f{t cojyscstaneF ore Wodlangsa RT @alpfr: Hollande souhaile que les britanniques 230un 2016, Aberysl positive ber restent Le DIRECT MAFP sur fe Prexic 16:38 CEST wth, htlps-#/LoofSd8IpHhenh hilps://Lco/Du?sX2IHSE] Wales Johnjonnyl RI @limburtado: krdopan aulere un refer@ndum 23 un 2016, Un negative sobre i ‘Bren. Sin ser af®n de la UE. Prequntar 3 16:35 CEST ecustarl tures si quieren tegui con proceso de i3€ | ano miisen Valencia Bungaan Breit, you ask? Fallow the maney. 33Jn 201, Somew reual hllps/fLaofqPesel PLE 160% CLST here near Sacrame nto haydenker peak when a 97 year old who could die tomorrow can 23 Jun 2016, negative or vote but 16/17 year olds can't Aen sin Hirexit 16:35 - CAST Tijunazem RT @aToro: In or out? Either way, 1 affects the 310n2016, Earth 78 negative SGUPUSD What wil the UK vole in the HLURe 1 rer Brent itps /11.00/qOELanEI 11 Warsiopadi RT @SacFcontiag: Stee | dies of GRMTunion 23m 2016, leicestn 33 | positive : makes the trade union case for dlexit 1655 CEST. Fngland VoleLeave UBresil BLUrl hits. /f1.ca/0) Ofwlay hts 36 Womicht AT @PaulbernalUK: fBresit people want to fusepens 23 n2016, Furope 7 | negative because MIS are rubbing oul Uheir voles bul voling lo 16:55 CLST ero ane of the few areas of awa | Jameslewis AT @Daily_Express: Holland SACKS Brexit Dutch 23102016, Hamilto 38 | negative wre people urge Britons 1 QUI doomed bloc SEUref 18.95 -CESI Ritps:/t.co/VhYIHigens htps:ft.co/GaPuwi1se | Caledon i invest Ma The Impact of a Breit on the Furopean Fidoney 23 1m 2016, © | positive 2 Market hips ft. cofAba(CXCQRN 15:55 cost AGIubal_ The Impact of Breton the Luropean Looney 25 un 2016, Poste Neda Market hitps:/t.co/skyFGTEIS0 16:35 - CEST tropicalzoe | ActzOut for the #Brext AEURel vote with @Brdsir 23 Jun 2016, _rosewo positive Seunloded rey own (lag Profle picl What wil you 18.55 -CEST od ote? fivated hteps/t.colgOsOEBLGS! Wumirere _ @cucoprasident Todzy is the day to repeat ths 75 un 005, negative nour message Fit isthe truth @eucoprasident 16:35 - CPST irclercndur Mirain Breil Soccer_pl RI @BIoudley North: Car paign Loar in Stourbridgs 22 Jun 2016, Pose ve #Bresit winning htpsift.co/STEOOVOZIC 16:55 - CEST ‘dnetuork [#SmallBusiness #Erexit PUK] How The rex Vota 23 Jun 2016, negative Could 1urt Smal Business ening In The U.S. 15.55 - CEST @forbes httys:/t.cofPH/IDOGTZ minthceab RT @stcphonBulld: ir Cameron said | might lose 23 kn 2016, Kent positive few QuIG | vote leave. Just remember what we asked 16:35 - CEST these guys o give, Brent WIDE, Libhands Du Up Bip as Breil bears Wane. 230n 2016, Orlando negative https. co/L7jeSXuni3 SDIA #ETF RETEs Stocks 16:35 CEST FL Congr RT @HuwGruffydd: UK Brest vote: WV usii- 25 Jun 2016, 1 [negative hatepreacher backs 3 RemainS€™ 36 Says FU courts. 15.35 - CFST bencit lar and are softa€. https://.co/qu22 1X Cue) wae} Storahagen RT @ThaSwadishAhing: Nt @andersindoerg BINAET 23 Jn 2016, Nora, 7 [negative Remain Bar en yd konleaindikalor pA hur otrolisl 1655 CLST (Raven ii #Braxit Sur tr vA¥r tramtid heta€ | Gotland » Sverige lth @cardlaurrejols ofc 4 RDeicaments hoy ss 25 un 2006, postve referh Dndum de permanencia de UK a a UF. Brexitsa 15:35 - CFST fice al escenario de q gane la 0pciA’n Sale lcaroic Ln Reino Unido of breil y aqui Muskie Leiva, 28002016, eekerral neutral fraterendur 16:55 CEST dea Fhansalfl RT @rissinglakior, Brent. revit Deparugal Tn 201, Moral posite leave. ruckolf, Cvehuul, Our, nish. 15h CST indi. Slovakout. Latervia. Byegium. Tasadiaka | PVotaln for the #Erait AEURGF vot with @Brmdstr & | 23 Jun 2016, © [poste unlocked ry own [ag Profile picl What ill you vote? | 17.17 - CEST sivoted https:/f.co/Gh VeCImKTY Dunc RT @missnafaklor. Breil. Grit, Deparusal 22002006, Nolin 5723 | positive Italsaue. Fruckoff. Crechau, Oustiia Finch, ATAD-CEST Kansas Skovakoul, Laleruia, Bregiom, Anprar Geanowila RT @Geeaay013: Rare we go folks, Next They wil 23 1un 2016, _southa postin ms? be arresting people far ating leave] dbrexic 17.12 CEST mpton #VoleLeave hips f1.cofuBbLACAL02 cdavids7ed RT @nylimes: Maing Brifing: Here's whalyou 28 hun 2016, 38 | positive aid nasdito know to start your day 17:12. CEST Hits. f7100/fPNQUXS hts: cof DRITHAX commodity RT @jrhapkin: #hrest: a handy way af allowing the 931m 2016, India 1 | negative ways) poor togel angry shout incauality without challenging 17:12 CEST the people responsible? hitps://13¢. spina AT @toadmeister: WioteLeave WBrexit 23102016, Erighten 178 | posites independence Day hips 1 cofieN | CERNL 12a Wikelelosegl RI @hugor abarca: Los que dicen que todos los 23 hn 2016, Gastelz 52 | positive ap expaliLoles tenemos que votar sobre Cataluhza 17:02 CEST (Euskal parce nas influye Adexigen que vatemos of Brexit? Herria} bosepdd RT @Finabethuriey: Vota tamorrawwhataver your 3 Jn 2016, 3515 | negative persuasion. I'm for #BrexlL& promise to neither gloat 17:12. COST nor whings. But VOTE: hitps.3€! GarethFearn @sarhinc10 Presume yourwillbe backing bret? 23 Jun 2016, Manche © | positive Gon be alo of maney in cartography we leave, 17:12-CLS1 ster, will nzed brand new rags! England TanKing383 You ruled ost of the world by yourself, why doyou 23 Jun 2016, Tegative need the FU now? firexit 12.17 crsT muse RT @MONFY: 3 reasons Americans should care about 23 un 2016, |agos, neutral the BEUre! hitpsi//L.colaSisgo304C 17:12 COST Nigeria Taylormarsh RI BENBC: A Breil could be coslly, warns 2H un 2016, Washing Tega @Davie_Cameron. Everything you need to know 7:12 -CEST ton, D.C about FEU: hits: //LcofATLOHS BAT Beltway. https:ft cofla€ Fishad0uk #iVoted for #Brexit today! Britain should not by ruled 25 hun 2016, Toronto negative aver by foreign glabalist sites! Areferendur TA CFST Canada, Leeds England Trail RT GANNYGO0: Eran: en plein scrutin, I Barclays 23 Jn 2016, negative brondit lb menace di€une torrente mondiale 17-12 CLS {@novopress https:t.co/ovaqAsPn Sanaliaaza RT @WifredFrost: What could follow Breit? taleave. 23 1un 2016, 312 | positive Crachout. Qusiria. Finish. Sovakout. | atervia. 12.17 CPST Bycgium. Or my personal favourite DIE} POLSEdmon hy volersa€™ 3 inch facture wil doom Bruit: 23 Jun 2016, Cdiront © | neutral ton Britin's Braxit referendum oaks too closead. 17:12 -CEST an, Rp 11 cofyLrNio3d lps /1cof GINA DESR Canada Weaitass RT @ViaWeb: Sraulromeva: 566 #Brexit 23 Jun 2016, neutral desmenteix que una Catalunya independent sorliia 17-12 - CLS d Ia UESE™ heaps: cof EwyASF3I0D BRESU_ RT @Daily_Express: Turkish migrants to CRIPPLE the 23 Jun 2016, UNITED 50 | neutral NHS’ €irexit minister's stark WARNING about FU 12.12 -CFST KINGDO ascension https:fft.co/MnHiwiPDra https:4€ ml FOIOW Back usalCaling RI @808alohadonlsSo he was speeding up raining 23 Jan 2016, USA 84 | negative an vino? 17:12 cesT #Broxil @BarbMuenchen @ Palriotic_Me @dawnrarieihl @surlerrom?? @stephdavss hitac TAbourse | #Forex: (3 Aeurs majoritarement en hausse, levels 231m 2016, France postive tr le Breit domine hitps:/fe cofbrCWh gE 12.9 -cFsT hitps:/{t cojpbimoimuigk. FireCask _ Bovaing for Abrexit o bladderod for foreman? 23 Jun 2015, Wanche negative Whichever way, play the Ulti-ate EU Referendum 17:20- CEST ster, UK Urinking Gare. BLUR! hips://LcofboPavmis oul RI @eulb: Brexi' o he followed by Greil, 23 Jun 2016, 2723 positive Departugal. taleave. Fruckaff. Czechout. Oustria 17:20 cesT irish, Slosakout, Lateruia, Byegium. kraftwddre #freit Breit fireait Ich kann's nicht mehr hfrent 23 Jun 2016, Nieders © | negative Lass! sie doch sichen Wann. Dic Wel drcht sich 17:29 CEST achsen, weiter. Laberiaber. Macht ander Arbeit Deutsch and Hilankaren | voled oul ¥VoleLeave Bex iret 23 Jun 2016, Newest © positive #TakeBackControl htps://t.co/iMOSFureni 17:20 CEST le Upon Tyne, England aimutmocl RT @1152: #Brerit and me longht on Gdv_giobal 23 Jun 2016, Berlin {neutral or unl dawn, Berlin time Beck 1229 CST hlps-/fLoofBCERNSAbYL cenmug Here's how a Bilbh exit from LU could affect the UK 23 in 2016, Washing © | negative chemical industry & scientists 17:29 CEST ton DC. Hitps £11.00/5BIVSORU1 Fret hitps://t.co/AQYRIOKInE Ohitsanissa | A¥oteln for the #Broxt FEUREF vote with @Brmdstr & 23 Jun 2005, S.LON © positive unlocked 1 own Flag Profile pic! What will you vote? 129 - CFST sivoted hups://LcofcOCToaFldo Kisushima RI @Snowdenr No maller the oulcore, #Brexil pulls 23 Jun 2016, Norwich 3235 | neutral dam onstrate how quickly half of any population can 17:20 - CEST be convinced Lo vate against itself, QE, Hononsakuz RI @faky¥uno: idea. Sbrexit 23 Jn 2016, Moscow 2 | neutral wes 17:28 CST, Rusia contedalina How Brea would Inflare populisr sbroad 46 and 23 hun 2015, Chicago, negative here in the US heps:/t.co/DW2Dngtng 1720. cEST IL HOUSE_OVERSIGHT_01124¢ Danaperson Svenska partiedama: siors ord T4fr an braxtt 300m 2016, GATIeh negative a hllps Loo /ACKESLYGIT 1729S ur Tummarna £41 England, Uismna d&rsiapen. Swerige Trirpies RT @DonaldClarkeb3: Its pancigata. fraxit Tun BLE, neutral nites suggesting pencils, ther than pens, have 17.9 - CEST been provided to fadilitate fraud. https:a€ sure My_ #UKexpals in Spain walching Broxil vole anwiously 23 Jun 2016, UK neutral vill https: ft.cof Op TXAM Pain 17:29. cesT htlps-f{Looftsildbamiie Keevobrow European family in park. Mum says to ids "come an, 23 kn 2016, Whiley. neutral ns2 its time to 50 home" 17:20 CEST Covent Come tomorrow morning if may be truer than you V.UK susgested dorenil pialikcspizza RT @AlisonNotaBird: the real stake of dbroxit is if 23Jun2016. THE neutral @pialiespizza keeps or foses her stats ot having the | 17:20 - CEST WOMEN twa mast pawertul passports in £361 T fickire Whit doss "brexit” ean? rakes me think of 231m2016, scotland positive breakfast 17:29 cost cleanorpd RT @suphic_sparkvs: Last nigh, Remain tweets finally 23 lun 2016, Mercer 1 | negative: autstipped Leave tweets. Wonder it this is indicative 17:20 - CEST sland, uf how Sbrexit will go? hilps-i€ WA TheGreglon People of Britain: how about celebrating with a 23 Jun 2016, London © | negative: o continental breakast for #Bremain and a consolstory 17:20 - CEST full English FIs Area? Ger SPIFGFI Pal RT @Augstein: Um dir Rechten 2u stappen muss. 23Jun2016, Hambur 2 | neutral tik Curopa stAzrker UND sozialer werden 17:29 CCST gund hitps:/ft.cafAKnK3NurS] Berlin conderbox RT @gibori: a cosapatetica "che fal Blog i 231un2016, 435221 7 | negative Grillo&Del alo che la Meloni non appogaiano la Brexit 17-46 - CEST 7,138.23 perch hanno Ia sensasione che para€! 519 Widierod @realdsaidanny seriously make sure you use a pen | 23 ln 206, Here, rege ar NOT joking, Drexit 17.46-CFST thers and back } again Hansalyse Sider pA¥ en strand i Israel, Hyor kan jeg finde en 23 lun2016, 3G negative bret aitpoll? 17:46. CEST 283132 as Meaustall rex: The high and lows of the referendurs 23402016, Ireband negative campaign so far: https://t.co/8AFANNSV2 17:46 - CEST https:ft.cafrm acFkGWe Kebiegalio RT @etisntukenya: BREXTT: Wr the consequential | 23 Jun 2016, _Wiale 7 [reural n wole rans hips: /fLeo/ Hx BWISH 17:46 CLST https:/t.co/T2VGJaCTcO Wistcom Wall Strat Climbs as Brent Vote Eyed Fox Business 230un 2016, digial neutral #Brexit htps:/t.c0/Se0wI IMrfr 17.46 - CEST https:fit. cof L5I03Wyurk https://t.co/UBVKdi2oW! facilitators The latest The facilitatore Daily! 23 hn 2016, Ti positive https:/ft.co{7Hax0g2d?4 Thanks to Sgmboccanera 17:46 - CEST risalva @perugini dorexil dmds. problerr OHOCG AT @Evencmagarine: Final WBrexit countdown 730m 2016, Unked [neutral Weventprofs: Have you voled? kivoted #Lirel 17°46 CLST Kingdy #experiential m| Great Sritsin NEStrongerl North East faith figures sign letter urging against 23Jun2016. North © | neutral n Brent https: fe.cofil JimdcOle 17:46 CPST Fast, Copland Dylan_nick RI @gulub: 'Brexil’ to be followed by Grexil 23 Jun 2016, Gallifrey 2822 | pusilive: Departugal taleave. Fruckoft. Czechout. Qustra. 17:05 - CEST Finish. Slavakou. ater, Byegium. wajpdi RT @Amblohnohion: Retueet 10 show your support 23 Jun 2016, New 284 | positive for Arent across Ue pond a Uhey vole in lodey's 17:46 CLST York, NY #Ukreterendum, eVoteleave ¢Brext Wargueritap RT @lemondsr: La presse britannique vote A+ #Braxt 23 Jun 2016, France, [neutral erle Ao hetpse/jt.coflopGiar LI 17.46-CEST Fury WerpingSa @sophiabotha?d Racists, truly believe it's okay ta 231un2016, Ohio © | negative. shin RACIALLY PROFILE, -aforty WHITE RATIONS. 17:45 cost INTERNATIONAL HATE CRIME. SBrevic maletalt Rego Unita: code agli sporteli per rtvare denaro, 23 Jun 2016, © | negative Lit © dobre fabiadte hitps-//1.ooflICLyIL BLL 17:46 CLI Shoobridge Why vote out? hitps://t.cofizseMudo) Birexit 23 Jun2016, United © | negative: #weantout 7AG- CEST States mendes_sol RT @GlarourMagUK: #lVoted Team GLAMOUR votes 23 Jun 2016. oxford, negative diers, Remain. Here's why: hip. 1.cof SGI 17.48 CFST uk htlps:f{L.oo/ Ql FSHPMZ Toke_sw2 RT @uiScllerRyan B0% of Americans (ink the UK. 23 Jun 2016, SC, USA 70 | positive should leave the EU. They're right. #Brexit 17:46 - CEST #ChooseWisely hitps:f/LcofepHiBOGXEm DestlifaWag | #VoteOut for the #Brext AEURef vote with @Drndstr 23 Jun 2016, © | positive erst & unlocked my oun Flag Profle pic! What wil you 17:45 - CEST vote? voted hse Jt cofabuPS ly UKIPNFKN Commons confidential: Roriss blond Pfrexit ambition 23 Jun2016, United © | negative 17:46 CCST Kingdy 5trongerlN #¥otalN HEUret HINarOUT fLaboui m #IN Together hps:/fLoo/Ys WHuaOmSE Iuochinho RI @aguzranbas: | altan § horas para el clerre delos 23 Jun 2016, lorre de 5 | negative: colegios an cl Reino Unido, Las Akiras encuestas 17:15 - CEST HAGreu dan una ligera venti ol arain' 46} ee englishjohn RT @Davicllo§Y951945: Palice question UKIP 23 Jun 2016, Frgland 9d | negative a7 supporter who gave volers 3 pen oulside the polling 18:03 CLST sionsound: very suspicious htips:/t.co/25¢ | Terugacate RT @n_nevs: 301815, 575, Bim beck Hn iE, wei 2 [negative efEde-ne’ A803 CLS Edad Ba, 35, 8 EER, SALAD Sa NIGHT AE, SEITE CD, CHIT 00, 4n23-5- *ud,gF 5 SERIES de, 30 SEL, oe ES, 2 ATRCFTRAT ACE 5,5, 5728, 5 4a 57S apr BSE" 5%, RG | A BAER | A RE, hitpe:/ft.cofi meXHYPOS fiahk_news Triorwaren Index sls, Brest vote could rake Fridsy freakyon | 25 Jan 201, _Orenipr © negative on wall Street hUpsfftoofbssMIeGse 18035 CLST evelant the ocd edi RI @Uritannica: Curious about today's Are 23 hun 2016, 1 [positive tor raferencum inthe UK. We've got som badiground. 15:03 - CEST Eeportighe Fetps:/f.cofPVRpMi 1 https: 56 a molinam AT @ReactionaryTree: I'd hanestly be surprisecifthe 23 Jun 2016, Merida, 2 | positive UK we allowed to Wrexit even if thoy vole o leave, | 18:03 CEST Micsicn doubt the EU bureaucrats wilie Wrardan RT @ianiAmrani: This morning's discussion with 23 Jon 2016, Al var poste @iilerdjoni for @afticanews on Bbrexi | love thal 1803 -CLS! The they dubbed me wija man's voice) https:i/3€ Piace Tanivegenl @massvegeniua? Faud uvoted? fivote Auoted 23 Jun 2015, forth Tegatie 77 hrexitOrtion rex BSteonzerin 8.08 -CFST Weald, East drechsckdi passed cur breil ein bild meincs enylischin 23 Jun 2016, positive ngs Sarton. https:jt.co/nloly2406d 15:03 cesT Study iT AT @EconomistLake: What a day. 2 Jun 2016, posting on UK Breit vote 18.03 - CPST Supreme Courl blocks Obama immigration plan Hause Democrats stage sitin Trump visits goll ode | arispastor Usted lo unico ke que quem es a temperatura 23 Jn2016, bruelle neutral _inusual cn Bl! hitps://tco/helPKYGSUR 18:03 CEST 5 FouadBouss RT @Aihaakbarl7: Anjem Choudary, AUK sismist & 23 Jun 2016, Montre. negative atta ISIS Recruiter, endorses Remain. #Strongerin what 18:03 - CFST al, Qual Universe? | stand with #BRLXITIN bilps3€} ce Cana dsgalll TarisFrance Brat, Ios FranKbars de Londres riperplenes, 25102016, Paris neutral Hews nisereins https //1.CO/SAXCULLOZPL SGoogleAlerts 18.03 - CEST Muss 87 | Soteln for the rest 8FURe uora with @rmdste & 23 Jun 2016, Trankdur positive unlocked ry own Flag Profile pic! What will you vote? 18:03 CEST tam tivated Wain htlps:f/LoofippaALaswk Waanirlvin LURDPLANS Lo Britons 2 Jun 2016, negative has 15:03 - CEST What matters in the end Is YOUR OPINIONS. brexi flrenvain Aen nV resi sraferendum #BrexitOrNot #EUref Scbmonise RT @B0andra: @uklcave_cu BRENT Keep our 25 n 2005, Uk positive L] Sovereignty. https://t.co/IcEFiInT3U 18:03 - CEST UKIPRFKN RT @InFactsOrg: Another example of misleading 25 1201, United [raga Brea story gels corrected ust inUme for Url 1803-CLS1 Kingdo woters to not be misled! m hitps:fft.cafdac Tarazanacig RT @cosimocarial If aday PEraxt, tomorrow 5102016, War, 101 [ positive ars Greil wos cst HL Departugal Haleave Crecheut Ouaria Finish Slovakout Litervia Byegium via @ShaikhhHAE] Matthew RI @ Matthewbritton: [his is what you look like 23 Jun 2016, Wales 4 | positive tition when you #Vatelsave 18:03 - CEST #EUref #EUreferendum #Brexit #oteRemain hitps:/ft.coHXAFBSSIET Davinchi_A RT @pictoline: La Bacall del Brexit ha comenzado: 23 Jun 2016, Bogeta, 456 | neutral Reiny Unido esta] volando si se va se queda only 18:03 CST Colombi Uni Europes hips ft cojAudmrc0x20 a Godiquada @kaitheadams has been trolled 3l day since this 25300 2016, negative nei Tweet. Don't know how i’ take moral high ground 18.03 - CEST #Brexithttps://t co/ZKr356Z07R BarfoolPel #EUrofarendum WBrexit hilps://1.co/ 25 VONE 23 Jn 2016. Belfast, WA 1820-CFST Norther Iratand Tonzaloror Ls academia brtkinica alerta Ge 0% anomes fiesges | 23 Jun 2016, negative col clentificos del Brexit MIT Technology Review 1820 cesT https:/itco/NAIKEXBSF @red_ciencia sherloksam RT @TDAIKinahan: LIVE on #Pcriscope: Bank stress 23 Jun 2016. negative test and resin. hep: cof sDFFTipnO 1820 CFST WanesYann Belle promo antiBrexit https://t.co/sNdRYeuSva 23Jun2016, Bubry oO NA 1820 cust kedie_madu RI @Amoka_thowo: BLUR! 23 Jun 2016, 15 | positive Europe i not a nation. 18:20 CEST Vote leave #Freadom Rec Britain #iafrabit #Bialry #rceiafra Supportifra DeepTmp RT @KaspHaus: 2°00" D'DHND" 23 Jun 2016, 3 | neutral U2, DAV DEDI040, D2 wbrexit, Dp, 1820 - cesT 0:0i€f9.9, LIP, 6° 090, DHHED YD RTD%AFR, DN A, DREN. ADNAN £49,002 Dy» DLE DEDSIIED"D, ON BF 5 78 ByicH NEN 67 Dp0iR Op: hips 1G yactusfranc Brea: uelles consADquences pour les entreprises 23 in 2016, Park, © | neutral BH franAsaises ? https: cof eRIZgEutz 18:20. CEST lade france: sdalsularil AT @Hayleyh cmon: Meanwhile he Caterpilars are 23 Jun 2016, a | neutral 0122 busy Loday hitps://Lcof LEQ Z dbresit 1820 cost jovisryadi RT @TIVL: Thisis why the Bros vole could be just 28 In 2016, Jakarta 4 | negative the beginning for an angry Europe 18:20. CEST Bal, hltps f11.cofunue 855811 [Corrected tweet] Indonesi s Ticksnews Bret Poll Shows 80% OF Americans Thnk Britain 23 Jun 2015, Austin, Poste Shaul | ease FU Forbes hips: ft.cof 16GRwSbNMT 18.00 CFST Texas milanbpatel RT @ndt: frexic Na doubt if UK Pariment had 23 Jun 2016, Ac nell negative 0 decided iL would have voled Remain: Shiv Shankar 18:20 COST Wkherjes, ExEnvoy to Britain Teoncina_ RT @Daniel_Portman: hitps://t cof NESUFLNF Being 23 Jon 2016, Saint 17 [negative pit an the same list 3 James Rand and Hermions ~~ 1820-CFST Viadinei Granger made rc foul quite cool, BRer-inde Acadery Vv snOwballl AT @Davidlo52951015: Analysis of betting oddsthere 23Jun 2016, Ireland 26 | negative have been a large number of Breit bets emain no of 1820 - CES bts small but larger bts hitps:/f5€ Schur 1 Aioteln for the HBraxit #EURSF vote with @Bradstr & 23 Jun 2016, Neweast postive unlocked ry own Flag Profile pic! What will you vote? | 180 -CFST Ie, an sivotcd Harcour hitps:/ft.ca/osODSIeYa t a3 The latast The Id Daily. httpsi//tcofDADHXGVsab 23 Jun 2016, Sardigna positive Thanks to @ 1h3gerd @saracrivtakd Slabsarah Ahrexit 18:20 CEST sauret Sechutrane Bret: un scralinindRE1Gs hitps//LcolHT7yCEuBZ: | 230m 2016, Park, Tegative « 1820-CFST le-da- France clagic RT @OrBrian® ay: BRCXIT 7 Vy view ?Surple. Stayin 23 Jun 2016, negative Europe but then get id of Cameron and his gang of 15:20 - CEST proprivloge cronies, Let's el cle Glordieiably | #Voteln for the Krexit 4ELIRe? vote with @Urndstr & 23 Jun 2016, 15" %E positive BN unlocked ry own Flag Profile picl What will you vote? 16:20 - CEST D3 vated httpe:/f.cofusGeUINIT pa cat debralinne RT @gavthobrosil: BREAGING: Ducens TURNED AWAY | 23 hn 2016, Wo negative from voting in EU referncum because of registration 18:20 - CEST RIGGING 23h psi co/ GRMPYLKKS hlIpa€] nd rent Large amount of Urtih press nol even 280n 2016, India negative owned by residents, tney re padding les: Patrice 18:20 - CEST Trench, Author and histori balticharbar RT @sidnegabioot: There: should be mare optians. with 23 Jun 2016, positive an this Breit lark than “In” or "Qut”. Vaybe 3 3rd 18:38 cost choice of lust the tip". Works with t3€ iatieoidc | eteln for the Feraxit FEURSF vote with @Erndstr & | 23 Jon 2016, Cumbria posite om unlocked r= on Hog Profile picl What will you vole? 1638 -CLS1 #ivoted htips://t.co/IRNT2bX1n] SEIZIAGE RT @INTItsu: The refuges fisca srphasizes why the 25 Jun 2016, Wings, negative UK rust aly on foreign unelected fics to IRIR-CFST USA determine their fate ABREKIT httos:f/3€ VieCcunorri WallStreet: port par Mypothd'se dun non au 25 Jun 2016, negative awe Breit, hetps: jt coflekci23927 twlstrest 18:38 - CEST Carlaltdslike RT @WiredFrost: What could follow Sredt? taleave. | 23 Jun 2016, @aitarie poste Ceechout. Qustria. Vinish. Sovakout. Lotervia, W38-as on Byegium. OF ny personal favourite 03€] Tinie RT Snowden: No matter the outcore, #Grot polls 23 Jur 201, 370 | reutral dere onsrate how quick hall of any population can 18.38 - FST be convinced to vote against itself, GRE} RClustSayin #BrexLOrNoL dBi is 4 poor rove, now can we Lak 23 kin 2016, Phoenix 0 | negative £ about moving Pakistan ray be to Mars ? #okSorryéye 18:38 CEST Arizona ros 0 AT @aicdeans: Fuge new rex asset emerges 231 201€, Lierpo 215 | positive Vatel sun HF Uref Voted hitos.ffecofXdripaper 1838. CFST ol MESUTTASK @ProfElvanilas tskkurler ederim hocam bu arada 23 Jun 2016, © | positive Ran breil neysc bid yak ya. 138 cst Choblx Spinach, Lr ental, and mushroom galetles at Castle 23 Jun 2016, feitive Du toright. 18:38 - CEST None: of your shitty, bland, brexit butties for re. KDG Accou Furopean stacks are fing Hitpe/ft.cofARFakiatl 23 JunJ016, ver, neutral ntants 18:38 COST Bucking hamshie GreLakente | Reclai your soverignily; SVL Leave] Yay Wbroal 23 Wun 2016, Hurling poste arina 18:38 CEST intatha abyss Adarronann RT @Wiliam |13hre. Do the only sane thing and vote 23 Jun 2016, positive ars LEAVE today, British Friends! 18:38 cesT Against the CU 56° For re Curopean nations! KBrexil huipsse auracasey @Migel_Farage Social Data indicates that remain leads 23 Jun 2016, Balas negative 58742 https /11.00/nydRLNOBG Abrexil 1835 Ces hitpe:itco/K5d50pa0s0 Warta Bello RT @LukaszGrass: Koleiki do Kantor wymiany 23 Jun 2016, Warsaw, 3 [neutral n wialut wl andynie. SDamianSrymaskie 1R3R-CFST Poland Bllps:/1L cof UKSsGlsPwe htps:f/LcoliNAurcoF JackWilesto RI @ACuICares We've gol limited stock of soon lo 28 Jan 2016, Bourne 5 | positive bi very rare, Boris Jonson signed Eurovision 18:37 CEST mouth, compilation C05 topland pr aspecialtys hitpae wowalexisre RT @Braddlafty: To recap: 23Jun 2016, blackliv negative ally €SCOIUS immigration 1637 CLST esmatle 4C"SCOTUS affirm. action . 3€"Ireddle Gray verdict 46" Germmany gunman Amen A€"House sitin SEW setae] IRADLR_INS RI @MarkelWalch: Ihe dirly secrel aboul Lhe Brexil 23 Jun 2016, Wash negative 10g Vote: SCs ail sham, says @BreteArends 1pa7. CEST DC. https //1.cofSMCRCIIONI DARKGIUET RT @Warketibatcn: The dirty secret about the fret 23 Jun 2016, negative RADER vote: IL3€™s all a sham, says @BrettArends 18:37 - CEST hits. /f1.ca/SMCHCIHONH eibkiber AT @jamesdbays: A profound, sober aids on dvorca | 3 Jn 7016, _Tandan negative and #Brexil by the always engaging @alergus for 18:37 CLst spectator https://t.cofed WuLKYTM) Cortioialia_@Tono_Okero Aor Gui los partidarios del 25100 2016, WA 5 HBREXIT estin en negattoo en a arfifica 1855- CEST shan marke RT mashable: RT hiashblelI: #Dopsstpalingstations. 23 Jun 2016, Ha ter are helping their owners vote in the 'Brexit! 18:35 CEST referendum 5€} https:/ 1 cofssURQWUME ColumbiaGR AT @FareignPolicy: Hers C's how the Brexit cold 23 Jn 201, Naw [ derail production of @Gureollhrunes, 18-25 CLS York, NY @davidctrancis reports https://t.co/LOQICYoEI2 Cateronchie RT @Francofratin: Brest: stent ala€vetietto 23 Jn 2016, 7 [regatve fl S€stanto rumor per nullatEe. sCosRem ainda non 18:35 CEST cancer, problemi Luropa serve car bio di paso hae} Giuseppinal RT @Forerlive The Bred vote fs playing outin the 23 Jn 2016, _Siicon A ind3 market exactly lie the Scotch referendur: 1835 CEST Valley https:/it.co/TpOzeeySF] https //t.co/02i055€ | Tadybugl3s hips cofp DunAFUKE 5 Ton 2006, joan A 7 18:35 CPST sburg south ahiea Fillies RT @PoweliPoltics: Tha French said NO 231un 2016, 00 | A The Dutch sald NO 18.35 - cesT The Irish said NO The Dutch said HO Again All ignored or told to vote again. Comese! rebeccanom Wandering what effect the rain will have on voter 23 un 2016, Waterlo 1 Na ics turnout Wil Brexit voters display more old fashioned 18:35- CEST 0 British stocisin? FUreferendur Tandon dngrfld RT @Stop The FU:¥OTF | FAVF for Freedam™ 23Jun2016, Astana 21 | positive Suvcrcignly ~ Der-oeracy 1855 Cos Fusepens AVoted oteL eave FErex FEUel #referendur hlpsic] teelt RI @assemblea: No referendurr No democracy 2Drexit 23 un 2016, | errassa 183 | NA https:f/t.co/GRsnSrrsot 18:35 - CEST Corstin w Trcusclectric Si vais a poner de oda Io de poneros calcelings 23 Jn 2015, Cul OF, [3 largos con berudas en verano, deber/ias calabrar un 18:35 - CEST LA bral personal y abide lL, L avistion_dp What Would Brexil Mean for Commercial Aviation? 23 Jun 2016, NA fuk https: //t.cof ULNA jWeoT 18:35 - CEST Tor scoti0] RT @Vendavo: #01 Prices Fal on Supply Overhang, 25 un 2016, Daven, WA AE Tret3E™ Uncertainty: hitpe:/ft.colMIQDICNTS 1835 - CFT PA via @WS) anzisunbrok | BVoleln for the ¥Bruxil #LURCT vole with @Brdstr & 23 Jun 2016, Idhidn Of Na on unlocked iy own Flag Profle pic! What will you vote? 18:35 - CEST #ivuted hups:/fLco2e21eevvils Dograstss OF course the tax dodgers want us to stay In #8rexit 23 un 2016, UK ©] NA teve 18:35 - CEST taxhaven7? RT @AdamSmithsei: 2 23 Jun 2016, NA BS Sr 1835 CFT Ca vaEE Ete S313, SHAS 3, ae mane PVA, Athilps//LeolSrGTI0mIIE E0605 3KEm Be (EBrenitd ANE 20 [Er BONE ASET SETH ETS, i monE, m, VAT EWE, pn Fe" 355832 CRE, 28, SA ERIE S54, Hoa — ATP, APACE, A047, 36 | Touize_steve RT @uk_rantz. #oted to HLesve cos [want Ukta 23 Jn 2016, UK 7 [ poste m_ rerove 3rd World Luriffs & lel those whe work bloody 18-35 - €LS1 hard live some semblance of life. fe roservacup RT @AgentsecretOS: Fractura social en inglaterrs 3 23 Jun 2016, 13 {wa am casa dol bros, Lv lamas no se hablun entre ells] 185% €LS1 Palas en as calls. Queman bas | Amownstar#rest PoteLeave MourvoteCounts Aeureferendum 23 Jun 2016, London, [positive https. //t.cofpWaQzD82j4 18.55 - CEST England noname)10 RT @Farexl ive: The Brexit vote is playing out in the: 23 Jun 2016, 2 [HA m4 market exactly like the Scottish referendury 18:35 CEST hitps:{ft.cofTplreeySFl https:{/t.co/QiNS3€] preudamon RT @hcoselin: it aint brace, don't brexit. 2312016, London, lua a 112-05 UK PY Oficial Los rrereadiogos tambiADA opinan sobre el Dex 23 hun 2016, Yucatdi © | neutral https:it co/RBoLsEx7Gt 19:12 CEST n KeithARober supporting #Brexit wants me to help them spread the 23 Jun 2016. Glasgow NA tan ward then let me know | shall do sol was Scotiznd Tleios 1201 FSRERIT REUREF 23 Jn 2016, #OOTT A 1912-50 madness hutpsi/ft.co/VEKa3p306 2a7ikyden RI @Nigel | arage: IF time 10 get our borders back, 23 un 2016, Yorkshir NA Wadia our democracy back and our country back ret 10:12. CEST, tps. f1.0afeADIHIOY England Sfigshmnr RT @ajplus: London's mayor Sadia Khan crushed a 23 Jun 2016, Indians, [oy recent Abrexil debate 3€" while fasting, 1812-081 Usa Wc drop, please, https:{{Lco/eNSj mum) JoudcBrig RT @gokub: Breit to be followed by Groxt 2 0n 2006, Farts 3303 | posite Departugal. taizave. Fruckaff, Crachaut. Oustria 19:12 - CPST Finish, Slovakoul, Lalervia, Bpegiu. BariberNola @raymonddelauney hats off Lo @arorgesalloway for 23 Jun 2016, ulna n his stance an #EUref wbrexit fLexit this s the second 13:12 - CEST thre Ie agreed with hie, fuck elearning u ¢Universidadas | Brevi: que conseauiincias paraa 23 no016, Vila © | negative tad ensing superior: SA£o quem als bolsasr.. 18:42 CEST Real, https: fft.cofviSINHIGR | #Fnsinasuperiar Partugal Eyeintory RT @Darrenhiole: Lies 73 Jun 2016, [oy arld aks with Turkey wil startin das 1912 cust Breit WON'T spark trade war Ful HOT reform on open borders & deportation jobé€ RedBIAL RI @WeninBones: BLUrelererdur BLUFET 2H rn 2016, poste #BrextOrMot #Brent Moteleave 15:12 - CEST hips £1L00/nbo3 Vy. indongoada Wy full edicated view I Shrexit leave 231un 2016, lerefor positive i 19:12 CEST 4, Fogland angeltmoy AT @pictoline: La Balla del Brewitha comensado: 23 Jun2016, San wa Rein Unido cst volando ise va osc queda nla 19712 CLST Jon Uni Europea hetps:jt.cojucmre020 a Waracay LAragua ner] RT @cobbo3: Whats wrong with today's British 25 1un 2016, EIS lars? A critical resis vate § they haven't blocked 19.17 - CPST Tuitter and Facchook like some countride | Cato_Winor Dic Cheist aie die CU. 22 Jun 2016, of na Also wie sine belagert Burg: 19:12 - CEST ie: dros sin wollen rei unl ie din sid wollen raus. abrentt ampatchara revit 32.3, %0,33,1 003 ¥3,00,0.73,—A 3 Gare of | 23Jun 2016, BK.. of ua k Thrones https:/jt.co/duailaPYyx 18:02 CEST THAILA np GrlakesCs ateleave SCcwould not only ree the Brits fram3€ | 23 Jun 2016, Hurting positive arina LU, sould profoundly shake up the other 1812 CST nly the abyss Ter Bers3 ETRE ABlohEa an htlps-f/Lool £300ig700 hawkairl 198 | #Votefut for the £Brexit SEURe! vote with @Urndstr 23 Jun 2016, ShefTiel NA H &unloded my oun Flag Profile pict What willyou 13:12 CEST d, vate? fivoted Frgland hittps:/it.co/TNBSSRapCH nasosgrigy RT @pitsiikos: [04 TAPAS LIL Brox, Tela 23 Jn 2016, Viele] negative LT IB Te Thiele Ts TIER Jel 1920 cesT Tailed, FIAT, dbrestOrNol ABremaints Breil fii’ set fiels RafaelGirrz "Brext’, can i pacta Fanstario en mercados, 2310m2016, Wierioa HA alma especiahstay ~ wwas WUFC_E334 | #VoteOut for the #Broxit ACURA vote with @Brndstr 23 Jun 2016. MG NA &unlodd my own Flag Profle pict What wil you 13:20 - CEST vote? hfsoted https: cofty pT quramT TeathZ0Rab RT @PaullamesOskley: Avated Proud lo boone of | 23 Jum 2015, IN BE ert milan. of Brits looking forward to a bright fusire 1929 CEST ENGLAN wulside the LU. #Brexil hups+//Leof3€} o. Drieekiel | #VuleDul for the #rexit SLUReT vole with @Brndblr 23 Jun 2016, A nearly NA & unlocked my oun Flag Profle pic! Whatwil you 13:20 -CEST peaceful vote? fivated https://t.co/sRbutXi place pinsfinder @Pipsfindar Instant. BT |i iimeReport: John Rogers, 23 Jun 2016, WORD HA CEQ of ArielFunds gives his kbrexit s3€} 13:29 CEST WIDE itp. fuxpayPoHE hitps:t.co/SNVNDRGEHT) EAGCharlas RT @Citiansif21: Every vote countsi Make sure 23 Jun2016, Oxfords positive 8 everyone you know wilh a vole gels out there! 182 CST hie #oteleave PLabourteave HEUret ¥Bresit https 3 bethomas__ I'm actually terified that rex ray win on the back 23 Jun 2016, SHG [oy of extreme weather preventing people lke me) from 13.29 - CEST reaching a polling station SmurfyICK | #¥oteln for the Wrest #CURSY vote with @Brdsir & 23 Jun 2016, Bristol [ry unlocked my own Flag Profile pic! What will you vote? | 19:29 - CEST fivoted hps://Loo/706xBFUST BakoSLRCA LN DIRLCIL, parler amb @ polmorillay 28 Jun 2016, Calalun NA T @CidabBarcelona sobre #Brexit am Aptica catalana 13:20 -CEST va https //1.00/ 7d4P3reaty realdrichay Investors feeling positive aver resit outcome 231m 2016, na m ttps:fit.co/ HWMIUyPROT 19:29 - CEST pig_poclry RT @gulub: 'Brexil’ Lo be followed by Grexil. 23 Jun 2016. positive Departugal. taizave. Fruckaff. Caachout. Oustria. 1929. cesT Finish. Slovskuul, Latervia, Byegium, sectradeide Wall Street marches ahead as Brexit seen unlikely 23 Jun 2016, Novato, NA as https:/it.co/Aath/ O2urj2 via @Reuters 19:20. CEST CA GorzaWion | AVotzOut for the RErext AEURET vote with @Brndstr 23 4un 20.6, OE arc Se unlocked ry oun Flag Profile pict What willyou 19.09 - CFST ote? bivotod hitps/t cofyiaddntohD. coplaler 121 FETC 1c DA EICERAIN Brea IER 23 un 2006, Athens, of na Tula HATI Te, 19:20 CEST Grasce itlps Loo Cele Kr kphd Kroner, The atest Tha Kranetv Dail! 25100 2016, A https f/Loofey?NQBbIKA [hunks Lo @maryebrewer 1929 -CLSI @LeBroniames Abrenit #euro2016 TheAbsTime Braxit is just one example of the polical problems 25 Jun 201, Flordwl OE 5 Furope i facing https/t.cofStaRApIIE 1929-CFST de https: it. co/yvGwScabd logan @jfcarpio si gana cl Brxil scotia Handa plancan 23 Jun 2016. Lincoln, ona nuevos referendum sabre permanencia en LK, para 1920 - CEST NE wolver a LU juju agomes RI @infinofiy: Solari Anima-archa estudiontl, 23 Jan 2016, chile 1| na Bret Farc a Roja y Als AHORA én @mundoinfinta 13:29 - CEST con @7z0me2Q y Palenzuciogabl 4+ hics:S€} Toews AT @RayCropnerOT : Me and Ken just idked out 23 Jun 2016, v5 | HA the polling station for shitting in the ballot box. 19:29 CEST #Brevit https:fft cofkp2esUUIL slevenjohne RT @V_of_Lurupe: Who is the shualerin Germany? bs 23 Jun 2016, stoke on NA ale the German media censoring samc againto avoid a 19:46 - CEST trent ‘pro Brexit effect’ in the UK? hupsie] IrumptonC RI @disclalirerr-ag: tditorial- Damn the Houses of 23 un 2016, Irumpt negative. 8 #Brait and HBrar-ain by voting with enthusiasm 19:16 - CEST onshire estronzerinFuranes https ft.co/ CGUIFGKEmA3E Paulfsingh RT @b tweet: 5A ra my UK friends: fusepens for 23 lun J016, City of positive your Broril eave” vot or se squad of MIS agenls 19:46 CLST London armed with erasers will furiously eras Europe Pharmdca @paulwioll agree Paul. Everyone expecting bremain 23 Jun 2016, Californi negative not bret, iam cautious here: as nothing factored nif 19.46 -CLS1 a, USA we get a surprise brexit vote SOTWIFUN 1 hops the citizens of #Briain make the ight decision 23 Jun 2016, United [oy wy and doo Hhresic 19.46 CPST _ Staves FN_Nachric RAFXIT/ROUNDUP 4: Historisches FUReferandum 231un2016, 7Akrich NA hen spallet GrodToritannicn Renn en 18:45 cost https:/t.co/BGFyRLBHI 1 aria parts RT @gacera_es: El Brexit, 31a uz de 1a moral Hindi, TWh 8 https //t. cfr] DezRVe https £A.cofqDOkBaBNA 19°46 - CES! Corulda Galicia Fepait-a BenDeCusi #Brexi ppl who be lke "we wanl OUR DIVOCRACY 23 kn 2016, London © neutral mo BACK” https: coj3munOuing 19:05 - CEST DinaFancell RT @Eritishiwake: Absolutely pastivaly the ast 251002016, Unied negate u throw of the dice fror- Beran 1996 CEST Kingda m Braxit you have basn warnad! hips /7Lco/KaneeKLECN SalidSrakell Pencilgale erupts as palice called to LU referendum 23 Jun2016, Around NA Ie) palling station after woman lends othar voters her 19:15 - CEST the PENDS: /5.cofpieE1SrsGi warkd 7oecarkhill liked a @YouTube video https://t.co/WMeSIWSUd 93 Jun 2016, Rirring WA James Cordlen an Brexit: Vote to Stay in the EU 19:06 - CEST _ham, LK Victorbentto RT @auiuepeinade: 51 gan ol Brexit, Adlsandia pasa | 23 Jn 201, Arganda A 8 a cuarlus? 19:96 CLST del Rey L Amalgam Etant donnAD que les zens aul sant pour le Fsrexit 23 Jn 2016, IR... NA aur sont des arrifCrADs, vous ne les antendraz passur 13:16. CEST enfin ca @eanceinto ailen reste Aven iA rEee eRK@sumAG Wurivursic @H ateviiovak Glucijauss] do idbrane mes tdi jax 23 Jn 2016, A tajers [oy padpiram #Brexi. UpaAitevaje politifeno evolucii 19:46 - CFST ka naslednikor partcanoy pa? WikuPeres Brox {Brilan ex the LOT~ The Movie Fal lon 23 Jun 2016, Brasil [Ty https://t.co/FgbciOgelY via @ptc_net 19:16 - CEST Told RT @missingtaktor: Brexit. Graxit. Dapartugal 2 hn 2016, Kiwe positive aleve. [ruckofr. Czechout, Oustri. Tinh. 10.46. CEST Slovakout. Latervia. Byegium. Bake2 0 RT @robmanuck Avole for Brexilis a vats fora man 23 Jun 2015, Uncaln 7580 | HA wha doesn't understand how: capos work. 19:45 - CPST lps //L cof ONRLASL SGX SexeTioED ad Cameron eile su voto on el Arex Zn 2016, Uhr [oy wx https:ft. cof NVELLES 13:16 - CEST _ Federal Capezzone RT @lormichenews: Chi sofrirebbe di pik con la 23 Jun 2016, WA Breadt | intervento di Daniels Caperzane: 19.46 - CPST https:fit. col 2SIGHIWZM sallyshin RT @CNBCSocial: In 3 stunning turn of events, it's 23Jun 2016. New NA raining in Landon. That wan't stop CNBC's 19:46 - CEST York NY @kaylalausche from reporting #8rexil 3 hllps/3€} saints247 People are losing their minds and hum our aver 3Brexit 23 Jun 2016, Southa © | negative: Slagging each other off because you think differant to 20:03 - CEST mpton then, Shame. fearAnloat | Moteln for the iresit #FURGE vor with @hmdstr & 23 Jon 2016, Brighton © | positive hin unlocked ry own Flag Profile pic! What will you vote) 20:03 CEST 1G: vate hutps:/.co/P2UkDorAM Feartnl walhin yopsdles RI @ | heCanarySays: However britain voles loday, 23 Jun 2016, 25 | negative David Camaren is f* chad https://t.co/LOLMWIIA 20:03 - CEST ols Heuref Avoted remain Gbrexit @VoteLA€ TrenchiorTe RT @laredWyand: How3E™s it fesl Brits knowing the 23 Jun 2016, Miri, 87 | posits wp Wil population you let in is voting against your 20:03 CEST FL inciependence today? rexit Moteleavesc | amnecagie hitps://t.cofusNWJOGKY Fbrext Please dant leave. 231un 2016, Facfic poste 2005-CES1 North est TimBukOne ~~ SISESBK #STANBANK View article 23Jun2016, South neutral NEWS hitps.{f1.cofsRAHCTI7y https:fft cofdbdYCmVes 20.03 -CFST _fifrea davickski RT @Snowden: No matter the autcare, #Brexit polls 23 Jun 2016, Yardley neutral derronsirale how quickly hall of any population can 20:03 CLST Pa NYC be convinced to vote against itself. Qa€! &in- Tatas somlewsr RI @ianbrerrmer: [his s what the Drei ballot looks 23 kin 2016, Adela 151 | neutral like, for those curious. hitps://tcoXWHSWXLMCY 20:03 - CEST , South Austral leoohjouedl RT @Y_Curosceplics: Brox guaranties accountable 23 Jun 2016, 15 | negative leaders, controlling immigration, signing our own 20:03 - CEST lrade deals & no rrore curacune builould€ | Wopgielear RI @ARIQULS LONDON: Whal today right mean for 23 Jun 2016, # | neutral month artists https://t.co/nWiNLEA Lis via @hyperallergic 20:03 - CEST tps. 1.00/32 RP DpH Tuckfonts AT @RealAlexlomes: Hess insider: FU The 46"New 23 Jun 2016, 0 A'- 7 | neural Soviet UnionS€™ hitps://t.co/XtSleLaquu 20:03 CEST ‘an% TheTradingS RT @Slop_The_CU: Is lire Lo Lake back control 23 Jun 2016, 1852 | positive heep 20:05 - cesT #hrexit #atel eave https:/ft.co/Soanes kin? ephusis 18hrs and counting: i Liveblog berichten wir die 23un 2016, DA¥ssel © | positive Fanze Nacht durchgehend aus London. 2005-Ces( dort hittps:/it.co/r3EtnZvi2zH #HandelsblattUK Tonswneke Eee uit oude doos nog brandend actuselrext 23 Jn 2016, negative itp. /ft.ca/ROCUUIg,Sad 20.03 - CPST AKE7Gaone That sam paranaia that makes propia ignare what 73 Jun 2016, _ Guidiar negative r almost every major organisation advises on Sbrexitis 20:03 CST d now making them spoil their ota! Tajowski1s Breit Co moka ceekanT Polak mieszkalh. cych | 23 Jan 2016, Derby neutral 54 na Wyspach https://t.co/pksaliuiiol 2003- CEST UK Unknown RT @lesair. #vidA Pla Ackemain or fesveha: a pluie. 23 Jun 2016, negative - pourrait faire basculer le ABrexit 2003 ces hits: fea VGAKYEWIC hitps: fe cofIRFSSXI SF Sanity AT @washingtonpost § rexit voters reveal ther 23 Jn 2016, Ciudad 1 | egative thoughts on Lurope hilps//LeoNaaHUXMTS0 2003 CLT Auldn https: co/0iUtSLeuco ma de Buenos sira Tiros RT @OpenBritain Labour MPs with 2 genuine interest | 23 kn 2006 176 postive for workers understand the #FU 20.08 CPST cauntrin FERS! MBit Slax: HLabourl save Slabourlesve https fA€ | Anaad Bred 28002016, Meio neutral 2003 cost Ganhurrelll RT @WichellzDewbs: [Been frustrated by people who 23 Jun 2016, Richmo, 103 | negative os feel that voting for Brexit is somehow backward 2020 CEST nd, thinking’, I'm outward looking bul to thit] tngland antoniobbl RI @Ambiatet; Defense mAs Intepraci&¥ lens 23 Jun 2016, 4 | neaatiee 52 oposem als papulismes que volen destruir al projecte 20:20 - CEST europeu, cam auui mate veier Ae Hun3€} Caimanvalo Camvmanted on Market Prices Brexit Failure; For 73 3un201€, Colom neutral re Colombia, the War ls Over Beck's Daly briefing. 2020-€L51 a hitps:/ft.co/)BmLIMAPEL S56 SDEQ SEC SCIB Taizuahah RT @WSI: Why a Breit matters to the UK. auto Tun BLE, [neutral inclustry3€°] ve coverage of FU referendur vote: 20.00 - CEST https:fL co TitHSIPrnFn tas: coir HPADTGYGX cerscun RT @JaaRabadia: The @Encrgyinstitute 25 Jun 2016, 1 | negative #EnergyBarcmetar sugsests impacts of brexit negative 20:20 - CEST un the world of Lory hpi cordastoBark£ dredi Sleepless in the Cty Lets Iraders bet Dillons on bret 23 Jun 2016, Italy / © | neaative Result htps:f/t.co/xHAI2UVVIm fbusiness feracing 20:20 - CEST Europe &fnance HRhTechAst RT @Mewsueck FU referendum lie coverage. Britain 23 Jun 2016, Hauston 8 | neural cc heads to the polls for historic vote 00 cesT TX hitps:jit coh TNSL72PCa Breit Wowdogl Another reason to ABrext https //c.co/MwOSRNLS] 25 Jun 2006, neutral 200. CPST Jotehia Ra AT @telaSURNY: Canoce todo sobre la posibin sails 23 Jun 2016, Ciudad neutral ue del BRcinoUnido de la Uniidn Curopes, dBresil >>> 20:20 COST de hitps:/ft.co Cop N2 Pues https: ff. cofkac Woe 0. Vallbil new few post: Gold Ends Lower: WSkon Marketplace Just 23 Jun 2016, United neutral : Ahead Of revit Results httos: jt. co/HeuT2c12Ke 20:20. CEST States Hants amy You know what's offtopic interesting about Aorexitd 23 Jun 2016, Atlanta, negative remain tome as. an ferican? The UK sil voteson 20.90 CFST GA paper. | miss paper voting. Darrenea A man was seriously injursd aller being stabbed Tn 2016, Harden, Tegalive dowsi0 outsice apoling station. hetpsifjt.co/TMOS20RVYy 20:20-CEST Cauny wuham England Dincandidh | keep loaiing at my Spanish neighbaurs wandering if 23 Jan 016, Fspai-a negative am they're thinking "Lot's hope he pisses off back lo the 20:20 €LST UK: thresic Scartrod AT @D_Blanchfiower. dosn't often happen butwe 23 Jn 2016, hegative certainly agree Brext looks lke a polenlial dbaster in 2020 -€LST the making hitps://t co/XsFultIQAE dnd RT @pinobic:. GSkyTG2 dallo studio "code per 25 Jun OLE, negative cambiare Alina". 200 cesT Inviako a Londra “no francamente nan mi isulta” Comic! rexic Cation RT @H arkusSueduity Breit Stays Foradtlima 23 10n 2016, Hambur neutral 0 asi y euanfrarklin RI @Roosterleeth Gus, Govin, Urandon, Chiis, ond 23 In 2016, Southa neutral special guest Sally Le Page discuss rexit tis, and 20:20 CEST mpton, mare! England hitps.fft.cafbPbludeXs htpac] Trjierinog @Cursaniack Never mind brext, 13m mare 73100 2016, neutral uw concerned sboulshelher | can acuallygolall this 20:20 CLST vogurt eaten :} Simplemand RT @NetzanNick: Forel eave on FBrext 1 51002016, Dorset. posite 1 iLeaveL 2020 cust https. £1t00/M yz Tuyweus #rextontior #EUrcferendum #eritain eriish “UK eu #Replacese] Jooralpark KI @itallansa rp: [witer is cemsaring Bivoted 23 un 2016, United negative #Laave Votes! 20:20. CEST States 20 ae vs 139 Herein Votes in 15 mint #Brexit BEL ABroxitOrhiot hips. Fac France 5, #infos SEC Les euncs brilanriques sont 14 G8 23 Jun 2015, Ae: poste a PARC rendum sur le Brexit: Las jeunes 2037 CPST 48.8667 Britannic, ma... hg Lco/MOOPRS LA 47230 372 Tobotforaxn BREAKING Brexit exit pall news! T1un 2016, Karach, © [ negative ews tps. ff1.o/ Teme zor [red] 2037 CEST Pakistan firaderbasi The Bret vate is playing out i the market sxactly like 23 Jun 2016, Nak f © | positive @ the Scottish referendum: Comparing the 5... 037 cos http: f1.caUTUOMF795¢ Blogs] Sweden UTNGNDICA Final opinion palks show Remain ahead of Braxic 23 Jun 2016, © | negative w hUlps {10 cofsn2w1 75K 2037- aust Bitraderhasi BREAKING Brexit exit poll news vesquawic in 28 kn 2016, Mal A © | neaatiee a Conjunction with the Press Association will be cond... 20:37. CEST 1, | hipe/fucofoPnCwehtnalentlord Sweden| | HATFIAGA RT @Henryicfiruder: Nicht ferwechsein P17 3102016, Berlin 7 | neutral zn Propaganda Lelio 2037 cst Brexic MBremain FBraxitOot Fioteleave istrongerln dsrongerineurape hilps:3e kellythornall @Richardesty don't rake a haste brtX| you might 23 kun 2016, Boston, © | positive = LEAVE sormething!! Haha | got to stop with these now 20:37 - CEST _ England pamelatoti RT @5kT621: KBren, Feditorals del drcttors 23 Jun 2016, TA | egative @sarahuaretto: htns:/.co/BFTRUIPYo. 20.37 -cFsT hilps:/fLco/$foQkdv Pi C_Dcrmolsy RY @Dcalh2RapuGanss: Farased€™ final rallying call | 23 Jun 2016, United 7 | neutral S€° HSE us versus the Establishment goandvote 20:37-CEST Statas for Abriin’ hlpi//Lco/ VAG Yale 83 | runwildsafar RI @Reutersiiz: Brexit vote could rake rida freaky 23 Jun 2016, Pretoria 15 | positive is on eal Strest: hetps:/ftco/HIOVKKEmAe 20:37 CEST |, South tps. f1.co/7anXNVKPS ine m harboe RT @1AFnkecank: Huis fret biver en realtet kan 23 Jun 2016, Fredrik 2 | positive det host op rod 13.000 danske job ddki ko 20:37 COST sherg https: ft.ca/n\TClofLbg Zala_noio Brxt vote: What the UK potentially leaving he EU 23 Jn 2016, SIT © [posite ma means for tech GNI HUtpsiffLco/ Bozic 2037-51 4 InomineX #Brexit Sie soliten ihr #BildungsbAkrgertum 23Jun 2016, island © | negative Atiberdenien, wenn sie wie in #ldiol 20:37 - Cust (hetps://t.co/tacZaReVen) plapparn https /7t.cofl KORE2f Zed itor sami RT @sardesaivajdesn: When | hear the fritain firs? 23 Jin 2016, 3114 16% | neutral anti migrant rhetoric of the Broxit brigade, wonder if 20:37 CEST 29 N. patriot ie last refuge af adc} 77h 2c pure_singh RI @gulub: 'Brexil’ to be followed by Grexil 23 Jun 2016, Ludhian 534 | positive: Departugal. taleave. Fruckaft Cacho. Oustria 20:37 CEST a. India Finish. Slavakou. ater, Byegium. JulieMontoy; Just vated In HE Ureferendur, Goodbye freedom, las 23 Jun 2016, 0 | negative 20 prices, har-an ights: hello uncer ainly. Alls wil 2037. €LST know | did not vote for ABrexit FISE @omnescontral @ZitsBotte 25100 2016, eget i isk 5 het ook het moeliste continentor te 20.37 CEST weroveren en te houdsn. 4EU 4Brexit Whegrecn7T RT @ralphaliwood: Britain too sreal lovole for 23 Jun 2006, London pose Bresitt Check out the i-partant opinion piece by 20:37-CFST and @avaac LO Ricken Patel hips (Leaf 3036} Noting hamshie Tomlefek tis going to be long long right... dbrextt Alor rade 23 Jun 2016, England negative #Steriing RGBPUSD AInOrOut 20:37 cesT Armoleblanc Mattis Brit en studeert in Nederland. Hij denkt dat 23)un 2016. Hilversu. negative an BRnest voor veel prableran 7orgt voor her 037 CST m hillps:f/LoofsbKBIITWED Anosopd mencaghich RI @LigucParis: @MCUorgial oL SCR_SOLDAR ZH un 2016, feats isi ak iCconstruisent le discours mA Ddiatique sure 20:34 cesT strent #150anstizue https: Jt co H13DsWu1Vo _ignaciomol RT @ricicano: ALY si gana el SE Brexita€s en cl 23)un 2016, Spain neutral na refer Tindum? _ignaciorolina escribe sobre el 20.34 - FST complejo proceso du negeriaciA‘n https: ft.co/ UNE Traveerson RT @Dakeb_MCFC. Even 11 the 20 wanted to rescue 23 Jon 2016, Unieed positive ally. the UK steel industry it can't, EU rules prevent state 2054 - CLS Kingdo sid dBraxit otedLeavs m RealNirjetta @Patrotic_ble Al eke is one owl person and Google 23 Jan 2015, AMERIC rege isn't euch better 054-CFST 8 wie ar being controled Brexit #FUreferendum https: cojenk1CO3ecg Tackehelad3 Dally Stormer: rest. Jo Cord" Death was Nata 23 Jn 2016, ell postive n rageey und the Weorld iso Better Place Withoul Her, 20:58 - CLS1 ttps:t.co/ gNICISK Too rue. lsbecker Ebrexit? sider IFT de und Policy Lab im Plan Ban 23 on J016, Furope neutral der @Leuphana_Uni. Die @NDRReporter sind auch 20:34 CEST zerads eingevorten Ghristopherc Came on Britain make history and become self In 2016, The neutral pz soverning dex 205 -CLS1 Hamme THirk_Blue__ @TezssideWoss @Famdonbavid EGoidmantachs 23 un 2016, London neutral Sky Personally would rather ive in a worldwide strest 0.34 - CEST than a Euro culdesac #Brexit Coronacha8 | #¥oleln for the Wrest #CURST vole with @Bradslr & 23 Jun 2016, Wrong positive E unlocked iy own Fiag Profile pic! What will you vote? 20:34 - CEST side of wivoled the https: ft. co/pHFAE7ESM Soluay Wichael WI @1 akeVotesMatter On contrary I merely carers 23 Jan 2016, UK negative te hale PR errors of athers, we have enough panacea 20.54 - CEST polities or one day with Brest Jjameskirkup Last thought before disco nap: wrote this in March. 23Jun2016. London negative: Standing by it now: Remain wins, Cameron loses. 2054 CesT tts. 1100/5505 71¥00, Renfiridgua | MVateOut for the #irexit #FURef vote with @hmdstr 23 Jun 2016, positive y Sunloded ry own Flag Profile picl What wil jou 20:34 COST vote? fivoted hitps://t.co/30MMeplxaG JobsterPazr RT @mkopNY: Let us be clear: ¥BRENIT is naw a 23102016, New negative st certainty, heavy rain all day dy in kLundon favors the 2058 - CLS1 York fevered, that is Braxites hitps://t 36 Talkbackny RT @palzofuture: Brexit exit pols, probably Tun 005, WIC 7 [negative wn 75% 2054 crsT You havin a laff: 28% Oi ate: 71% Chim chirney chim ehimncy chir chim cheroo: 94% Cristinatles RI @limesonline: Le universith britanniche song vs 23 Jan 2016, 18 neutral sit po 2054 cesT Non solo x questiane di principio https:f/t.co/jfgiNckFhU @Frifarbiragia https.3¢ Beowman RT @beaxman: Aihpoyas ol Bret? Renciiesta Farmsit | 23 Jun 2016, Wi casa neutral #BrexilOrNol kuk 20:34 CLST a3, resto del munde. WiConstantl RT @Snowder: No matter the outcome, #eret pols 23 Jn 2016, GOL 5766 | neutral no demonstrate how quickly halt of any population can 20:34 - CEST be convinced lo vole against itself, GE} Joniellingl RT @Grahamsmith : Absolutely. Next referendum 23 Jun 2016, York 24 | positive should be on the monarchy. hitps:/t.co/dd7irilvis 20:34 - CEST BtzMedina RT @DailyWiror: Brexit the horse ran at Newbury 23 Jun 2016, 5 | negative today but where did it finish? tps. ft. co/FIbU4iGe86 | 21:11 - CEST hilps:ffLoofXekiysaN hedm RI @HonourCoverank $svidCarneron warns #Brls 23 Jun 2016, 15 | positive that their #Ofishore #Panama inharitances will ba st 21:11 - CEST isk if they #vioteLeave Erexit hse | rrachy RT @WiredFrost: What could follow Brent? taleave. 23 Jn 2016, posite Garchoul. Qustria. Finish, Slovakoul, Latervia, 21°11 - Gist Byegium. Or roy personal favourite DE | balsarania RT ©madnd_almu: € Graxit se desinfla: bs apusstss | 23 Jun 2016, add T[regative por bi perr-anencia se disparan al 843 21.17 -crsT https:/{t.co/fODEyAUSSEY vAa @Bolsamania DuncanOlca Nice @lohnRentoul picce looking at ho the Remain 23 Jun 2016, 0 | positive wv and Laave voters are 21:11 - cesT hllps-f{LooferPainOuse. RosyKight RI @Dinicios295188%: Gigantic Lurnout of Labour 23 kun 2016, Yorkohir 73 | positive waters in Northern England voting for leave 2: -cesT e tps. f71.00/OimhixsBhve> DunYATC | #oreln for the #eexit 8FURef vore wih @hendsir & 23 Jun 016, fuck off 0 | positive unlocked ry own Flag Profile pic! What will you vote? 21:11 CEST x éivoted https:/t.cofyyOkSewikd alysamartin Well if #Brexit happens and their economy crashes I'm 23 Jun 2016, Hambur negative haping to et some cheap vacations out af the deal 21.11-CFST 5, WY Findlay, oH muray 33 RT @OnlineMagarin: SCHTake Lin. & 3 seconds: 23 Jun 2016, negative Lurope b a war zone, the LU has nothing under 21 ast control. Woman among savage. #Brexit now! hitpa€ | Curlyl/oust RT @LuawigBollaerts: "For AZ 100.000 | hold any sizn” 23 Jun 2016, Ankwer 7 [negative ache Ebrenit toremain fsocialisn 211-CST p, https: it. co/ZVXHYNFEGW Viaande Flanders Wall @VionnereStrudel Yor, Thought [d vee whalilsws 28 han 2015, Redhil, Treaties like in the dark heart of Brau, but there's just a pall of 21:11 - CEST Sumey despair everywhere. Jallboys RT @WSI: tering soars after 56 Dredta™ poll shows 23 1un 2016, 96 | positive preference to stay in EU 21:11 - CEST httpe./t.ca/uP2IKIOTI @ https. r.co/hNEgI45GTa GreskCity IT MILB DA LI TT PLT 11, MIS 7310 2016, neutral on ig. Ta 0 EEL, fT 2am ast Breit: EPIL 1 0, FIT, B18 LT, TTT hitps:/ft.co/0BAINBGI0, FDOREMAD | AV oteln for the #Brest #EURSF vote with @Brachtr & 23 10m 2016, _ george © [pote 7 unlocked ry own flag Profile pict What will you vote? 21.11 -CFST & Wivoted hitps:{/t co/HALTIEp tuesday FamicRedna @toudrister @vale_leave Well dunce Tobyyour on 23 Jun 2016, London, © | positive 1) my one to watch out for i the future list tbrexit 21:11.CEST England voteteave malaziherna kod mene na twitteru KUret ne trenduje .ma sve nas 23 Jun 2016, |hakrin © | positive dia sable 20:01-CEST gan, Deutsch land WSL2762 RT @WoncyWeck: Bernard Connally: why George 23Jun 2016. 50.1065 2 | negative: Sorasis wrong about Brexit and the pound 211 CEST - https ffl oofumabDbwalZ hips: {Leaf WObLLADIDL 5.5951 Evanlsory | @Davidlos2051043 Blouse ensch Don't Target, Ken | 23 Jn 2016, Bring negative Livingstone wil erisgate i we d8rexil 2an-asi hm, England illam_uihy roy road i representative, thara won't be any votes 23 Jun 2016, Oxford, © [negative te for bre, Then again, this i North Oxford, Wevated | 21.17 CFST UK for AV in the last one. errmsloon RT @Zissenio7s: Studio Aperlo consigha 2 hn 2006, plus 361 | positive alfinghikarra di non uscire dal Europa nelle ore pif! 21:11 - CEST calde, bere malta scqua ¢ rangiare Lanta (4) Coundllortd RI @NicholasPegs; 5€was Srexil, and theshity 23 Jun 2016, Holywell 11 | negative: Goves 21:28 CEST, Wales Die lie and grumble in the Mal, United Al enscirg wore te Bork droves, Kindo And Nigel Farage is€} m OI0G013H1 RT @FT: From the archive: Heres why Americans are 23 Jun 2016, Livarpo 1 [negative st a alamed by the Brest vote 2128-CEST ol ttps:tco/gGBIStyfET bttps:fft cofsnuwtiaq Tiecto_Gam RT @wikiicaks: LIVE NOV: The wBreatClub with Tun 005, Garon pote anal rAssange, MIA, Varoufakis & others discussing UK 2128 -CFST | referendum Lo leave he LU hllgs:f/Lo/LVUOSE Nuishbo urhood Fararrled2 | PVotainfor the #Eresit AEUReF vota with @Brndstr & | 23 Jun 2016, Notting positive unlocked Fy own (lag Profle picl What will you vote? | 2128 -CEST ham, #ivoted England tps. fft.cofpVSaVPhiG ThaGranar @timathudeiark shaukdve said Bresit pallsinahagaha 23 Jun 2016, positive ' oh sod please dort eave the LU 2128 cst Hiorow0s RUS /1Loofy VOSA La | man, you have my 23 Kn 2016, Dra, fegative attention, Breit 2128 CEST NE TndyacoS00 @I che Winners @beckymparry seriously | dont 23 Jun 2016, Scotland negative Think | Gan lose, rer=ain 11 be nagpy, brexit and we get 21.28 - CEST indy s0 even better 12 bogdy_linna RT @FrDesouche: Come pour [Autrichs, BFW ne fal | 23 Jun 2016, Parks 0 [ negative des reportages sur le fbrexit que dans les quarters 212A -CFST France chics ouimmigrAfs heanderman RI @loadimeistor- Just been knocking up on acouncil 23 lun2016, Harrpsh 100 | negative estate in Hammarsmith. Leave outnumbered Remain 21:28 - CEST ire UK by 20:1 Breit hetps: ft cof S{nClefigs WIRED Dresit backers are forgetting that the intemet ersses 23 Jon2016, Sn > | negative borders: https:f/t.co/g8jPUC0SB 21:28 CEST Francisc itp: ft.cofpri7SDicY afte ork PMNSL RI @amirsucjady: Remain corp saps there's ro post 23 Jn 2016, Redeite 77 | negative #brexit economic plan, what's "their plan’ when the 21:28 - CEST last ounce of UK sovereiznty 1s diminde wares Jonathan re. RT @ihedragonschaol: Dragons held thelr own 23002016, ere, 1 | negative ow #dobate today AEUref HIn0rOut 2128 CEST there Remain wan, stealing 3 votes frar heir opposing and Breit cam hie} wvcrywh ore CancunVaCo Paso sin actos par Brexit; dNVar baja mide 20 23 Jun 2016, negative hau centavus y colin en 1830 hlps//Lco/xBBURYILh, 2128 -CLSI Eremenky RI @alnusiX Dr, K, DakThan GRYKASe canlie 23kn 2016, Astanb neutral yayitnda rest] de iarlendiriyor. 21/06/2016 sast 21:28 CEST ul 01.00 tps ff.c0rgaoeciic tps: ff1.co/ Wet | NewsPuppe These are people stranded by extreme weatheran 23 JnJ016, San negative t Bresil day, who are likely nol going Lo be able lo vole. | 21:28 CIST Dicgo, https: ft.cofuBIGVK1pY. I) TropertyRel RT @Dorian Belvoir: Buytole! marigage rates talon 23 Jan 201, negate ping, Bret fears and stamp duty hangover 2128s https:t.co/e IHHZFBHIA #rortgage Poroperty Tusatna RT @CHN: What would s ABrext mean for you? Our 23 Jun 2015, KENTAF 55 | negative guide: iTps:/t.cafed 7AM FFUrel P10R-CPST RICA hitps:/fLcojolKFUHNCH Fiow 1 Boleln for th Wrst HEURST vole with @Bradslr & 23 Jun 2016, 0 | positive unlocked ry own Flag Profil pic! What will you vote? 21:28 - CEST vated hitps:/ft.cof OF AMIATAWAT nufcnotfan RT @NikeHookemER: BRFXIT BOOT. Tn of UKAE™s | 23 Jun 2016, Neswcast 40 | positive most distinguished retired military officers call for 2128 COST lefGales Leave vote hetps;jt.co/y126B0DS head Slisaddick RT @igeldarct LEAVE bafore the EU manages to create 23Jun 2016, Motting 10 positive its own armed forces aVoteLeave and sbrent inthe 2128-CES| ham #EUrsterencum hitps:iit cof Inid1EFta Tarkdrorli | AVotzOut for the #Brext AEURCY vote with @Brmdstr | 23 Jun 2015, leeds postive mer Sunloded iy own Flag Profile pict What wil you 71.45 - CFST vote? Hivolod hlps:/t colmARbNEN13 SarwarDoSo RI @1ruce ITT: Older people of Werilam, please 28 han 2015, Derby, 3 [regative to don't ruin Gur future on Thursday. The majority of the 21:45 - CEST England Younger people want Lo stay. sored StyNine RT @NichalasPegg. 46 Tuas irextt, snd thesithy 23Jun 2016, Frgland 13 | negative Goves 2145 cost Diclia 3nd grumble is the bl, Al ensciyy wer Ue Boris droves, sind Nigel Farage i5€} pangs AT @anbrem mer: Stop calling 1 Eurskepticim 3¢~ 251un 2016, Tehran negative HAE realy JE Eurohostiity 3" S€ an RIE™s not 21.45 - CEST 0ing swiay. My latest for @Time. hitps:/ftcoifse HelenB_Sca RT @5capeCEO: With the ACU finally upon us 25 3un 016, Netting 5 [negative pe Victoria Brambini discusses how a #Rrexit could affect 71:45 CFST ham, the Bpublicscctor @pscrcws htpsaf/L ie trgland ANDRLAZA RI @lrandrussor breil dallas dei tweet nelle 23 Jun 2016, 17 | negative NETTIN ultime 21 ore Rer-ain prevale su Leave by 21:15 - cesT @blueclaw #socialmedia dpolfics hitps://ta€! amcstockpic RT @monsymorning: How 3 ABrexit today could mean 25 Jun 2016, Houston negative &s a @realbonaldTrump presidency for-armow: 145 CPST, Teas hulps:/fL.co/0QyyHvsu2X Slympius23 RT @Loubobbs: Why Would Braxit Not Pace? Video 23 Jun 2016, negative shows womin lourist attacked by mob in Parts 214s -cust hitps:/ft co/K¥12cEnm3o via @NaflOnling AAmers scan So. Ars thara any Abraxit results so far? Tun 006, Galactic © [negative 21.45 CFST Snctar ey Plural 7 A Ruggdlan RI @Dseulingen: VAIL Don't stay home, Dun think 23 Jun 2016, 42 | positive the battle i won. Vote & celebrate UK Independence 21:15 - CEST Diag. HBreic Forel eave HEL NIEps:f/136. Nikolausvon RT @Gideonibosss: Wer fir dren ist will wieder 23 Jun 2016, 93 | neutral Wira die Weltmere beherrchen. Banke, 2145 cust @heutsjournal jer wei ich Bescheic. Dachte. schon, 4 W3€} IophiliesOB RT @CodeAud: What at stake sith #5rent? ow 230m 2016, 14S 10 postive #Bresitis important for the future of #Europe ? 20:45. CEST VEGAS hi1ps./ft.cofs03a1 due ann krstenbgran RT @willrahn: For al those following ¥hrexit today, 23 Jun 2016, 368 | positive t here's a quick and vasy guide Lo the British class 21a cust system. hitps:/ft.co/TLCIRK TVA Viarbiensis _@owenjoennett Good man Owen. BREXT all the way. 23 Jun 2016, Viterbo © positive 21.45 - cesT ara RT @pictoline. 12 Daal del Brexitha comenzada. 234m 2016, Tegucis 127 | neutral Reino Unido csthl votando si se va o se quedacnla 21:45 CEST alpa, Unis Furopea hetps: fe. cof udmrcO00 Handur FIRabim RI @Avase Isl 15 hours oT (0 50 vote Weare 23 Jun 2016, London 22 [negative stranger together. Choose Love. AVoteRemaln AEUret 21:15 - CEST arent areferendurs hps/t.cof2okie Zar-arivagn RT @Reaters co Ip: 23102016, ste 283 | neutral ri BLAU INN ge “or ESSENSE, bur ESS, | 2145 CEST el WAf—14, 3f¢AfEbaéants hins:f.cof HaGuAIRESh @ Pimacez septa Sans Soe Jesus Prin @vate leave leave UORcial 300 Machines 23 1un 2016, 0 negative ass IGNORED CROSS Symbols Ballots srexit Computers 21:45 - CEST Only Counted Remain Votes https: 1.cof lwhiyiSgor beautybyih | AVoteln for the fBrexit AFURe vote with SBrmdstr & 23 Jn 2016, Bladkbu positive chun unlocked ry own Hag Profile picl Whal will you vole? | 21:45 CLST rm, éivoted https:/t.co/0IdygaDDV England Wirarartiu EXCLUSIVE: Record Turnout Of Waring Class Voters 23 Jun 2016, ©] positive wala Rees Bret Hopes https: Jt.cofals adutcC 22.02-cesi colingreend | #oteln for the Hirexit #FLIReF vote sith @Nrndstr & 234m 2016, sheffield © positive 2 unlocked ry own Fag Profile pic! What will you vote? 22:02 CEST #ivoted hulp: cofque Hnbisq Erosalies AT @KinaRestall Another vote cast for damoeray, | 23 1n 2016, 131 | positive hape & ireedom fee iLeavell del AoleLsave 22:02 -CLS| hitps:/ ft. co/hGrmhCmcO Sifofodar RT @lndependent: hdogsatpolingstations back 23 Jun 2016, 27 | reutral https. f1.00/ygRAXrcu haps: cof niyKerIgO 22.09 crsT deiida%077 RT @egapicklect WU Mirexic fl esve 23.10 2016, 8a | positive 635 hllps:f1LcofXGebRIIZZ0 2202 cos clecto_mani Gai 46 millones y medio de britRinicos lamados alas 22 Jun 2016, © | negative s uma Hbraxic 22:02 cesT Seniaslania Europe Union refersndurn: final hours of istoric 25 0un 2016, Grace, neutral Brest poll S€° Ie hes cofinpe 3h 2202-CEST Attica WKuadya Drexit Backers fre Forgerting the Interne Frases 231m 2016, Cote negative i Borders #afrogeck hitps://t.co/ONPPRVIANI 2202 CEST divoire Wadchesler Alot of sencralsation song on regarding folks 28 un 2016, Bolton, positive Man politcal persuasion during this MEreit referendum. | 22:02 - CEST England mean, Im a lelly and HVoledLeae Rathehildha RI @iohnnyVedmore: demain in the EU and lel 28 hn 2016, rack positive ter sleeping dogs lay. #Brexit AVateStay AVoteRemain 22:02-CEST orth, oteleave Ure England astrongerin hips cufvie, Padlodipinl ir aratonarmentana Bbrexil economist oiic ion 25 Jun 2016, Lala negative a capite un cazza solo isto #spracata 2 purtroppa 22:00. cesT asupemazate Jrrobertso RT @ mississippi. Kal Rov has fst calle the 231m 2016, Ridgelan negative n #Bresit vots for Ohio 2202 coST_dws “Orfandotil RI @lalelalushos Ahad of Thursday s FBroAl le, 23 hun 2016, Florida, negative and Jamas expresses his support far the United Kingdom 22:02 - CEST USA a rerrainin the LU, https:/ft cof1Fa€ Tuightiarkc RT @dotty pus: Poppy voted biscuit not FErextl 23 Jun 2016, neutral ue edogsatpollingstations. #FUref #EUreferendum 22.00 CST sdogsoftuitter hitps://t.co/ DYg5Iw0zs STayle Standing inthe qucuc by 10pm 1OU WILLGETTO 23 un 2016, London negative VOTE. Your EUref vote WiLL COUNT. You can do this. 22:02 - CEST we can da his, bre renin [2 Ho One to [1st the Anger hal Connects Diet, Zn 2016, Parks fete Trump, Le Pen Bloomberg Politics 22:00 cesT https. ft. afal IR TG6 londanic Pak clase in just over an hau. Here's aur 231m 2016, negative. whattowatch guide to #braoit right 2202 cost hitps:/f1.ca/ G1 AHWAVL via Sbusiness tEUrel Sprakpunkte #0) Ling tid ach hiwrda Thfrhandlingar fXfre an 23102016, Sverige neutral n breil: ad blir nAzsta steg om Storbrilunnien rA® star 22:02 - €LS1 190 att itm... https: cof IOFSHS25z WoToSepara The ensiror ant, public services & workers’ rights ars 23 Ju 2016, _ Britain Tegatve tare ae risk fram Breit fascists. 22.07 -CFST Furope, #VoteRemain Remain #strongeriN Earth hips. f1.co MUTOH JohnG300 AT @FoxBusiness: Does Queen Elizabeth want the UK 23 un 2016, _ Charlot 7 positive La stay or leave hilpsf/LoofAKO4374L Breil. 22:02 CST e,NC Tryon_bioe RT @Dwalingen: VOTE! Bon stay home. Dan think 23 Jun 2016, Breatam posite net the baltke is won, Vole & celebrate UK Independence 22:19 -CLSI n Mhir Day. Prev Hotel eave HEU hieps:/t3€ Theateyouk RT @XplodingUnicorr: Dear Britain, Tun 006, Brockly 107 | positive nos 22.19-CFST NY This Brexit vote is all wrong. If youuwant to leave the CU, dup sorme ea in the harbor and fight varse Churchymat RT @NichalasPegz: 36 Twa Grex, and thasithy 231un 201, Sydney 30 | negative Gaves 22:19 CPST Did lic and grumble in the ail, Al enschy were the Boris draves, And Nigel barage i5€) DenisClenvo RI @Pat_Riot 72: Sortir de quoi au juste? Le UK n'est 23 Jun 2016, 1 | negative. + ni dans a z0ns Euro, i cans [espace Schengen.» 22:10. CEST erent Alcodex RT @galub: Breit 10 be followed by Grexit. 23um016, U 5253 | positive Departugal. Italeawe. Fruckoff. Czechout. Oustria. 22:19 COST daljini, u Finish. Sloakout Lataruia. Byagium. dalekoj didn aass281o64 RI @CNNWoney: bverything you need lo know about 23 lun 2016, ©5010] 11 | neutral UK immigration https:/jt.co/7GaAllav0 Via 22:10. CesT ig @alannaperroff AEURST ets cof ncSud9nu carsuab RT @elcomercio: Te axplicimos quAR es el flirexity 23 Jun 2016, argentin 9 [ neutral ciémo pucde afectar a Reino Uridoy a Curopacn 3 22:13 COST a minutos 5-8 hitps:t.co/SIFOUSINE] hrips:3¢ ngiaCurws RT @Laura_Sandys: Think of ture generations 3nd 23 Jn 201€, Tezatve nL the res that they will have Lo pick up we ABest. 22°18 CLS I vote remain Stronger hitps:jtcéc! WarishORY RT @jezpgin?7: Dear UK, Tun 200, where T[regatis ae 22.19-CFST inthe For all our sakes, | hope you vote #RerainiNEU during world? the Wrest voting. Sincerely, One of those olony kids Rayonegro0 RI @felatrizgsa |v: Los de Gibraltar estéin 23 Jun 2016, 1 | positive a acojonados con el brexit, a ver quiSiCn los enseKtaa 22:19 - CEST ellos ahora a hablar inglA Bs... illken RT @Xpladinglinicarn: Dear fritain, 231n2016, PnRAe 112 | positive 2213 COST fie fie This Bresit uote s all wrong If you want to leave the EU, dump some tea in the harbor and ight a var} Bickallary RT @XplodingUnicorn: Dear Britain, 730m 2016, Kentuck 1a positive 2219 ast y, Usa This Brexit vote fs all wrong. If youswant to leave the EU, dup sorne tea in the harbor and ight a viar3€ eisangehaul RT @XpladingUnicorn: Daar Britain, 23 Jun 2016, himits positive 219 ast ou This Brexie vote s all wrong If you want to leave the EU, dump some tea in the harbor and ight a wars€} Daniele3026 "| mercati sembrano dire no al rexit. Ma non 23 Jun 2016, negative 087 confondiamo la pall di neve con la valanga” 2219 - CLS1 https: cofbiDuk onc dcanorria Meedly Teriorkay Adorable. Crossing my fingers for you, ry friends. 23 Jun 2015, Calforni [postive Bret hips: fit 00/ATPkcWHIGY 27.19-CFST a panko Why ittaking so long ta learn the resultof the 23 Jn 2016, Seattle 0 | negative #Brexit vole? If this were the US, the AP would have 22:19 CLsT already called t yesterday. julanbrawn RT @Snowden: No matter the outcome, Fret polls 23 1un2016, Woking 6350 | neural e derronsirate how quickly hall of any population can 22:19 CSI ham, UK be convinced to vote against itselt. Qa€| Jp_Stich RT @nadrosia: Eltern Insider £=* Sbrexit. 23 Jun 2016, negative hits. /1.cofah¥GeoR| 1p 29. crsT squadeat Dieser massive VenmXgenstransfer, der heute 231n2016, Viens, negative innerhalb ciner Nacht stallfindel, bekorr ml viel au 22:19 CLST Auslria wenig Autmerksariket ib vat chess hope | eta cnn notification at 2 AN thats Ike TINIE, few negative "BRET OCCURINGIII And then | eel the e3rth 2218-aesl York urbe. FinanciaOnli RT @ReutersBiz Here's everything you need toknow 23 Jun 2016, London, neutral po about Bret, hp: jt.cofrCFud0ns 2)37-CFST Fogland https:f/L.cofom3Xer-PvRL Lpalsyndic UK expats debate Breil vol from Saskalvon: As 23 Jun 2016, neutral ae Britain prepares to ote inthe historic Brexitrefere... 22:37 CEST https feof iV MhPvew Spat Joannalnlex | see Drits getting upset with Americans for volang 23 Jun 2016, Dallas, negative a opinions on #Srexit That's fine, but should younot 22:37. CEST Texas Wkenvise stay aut of US politics? Sndcobens AT @stefens1: Fy Wie 15 LI T FAITE, [ema IHL VT oha0 = Titi? Wise 22:37 cast TLIIeTe Ta TT Tigh Ie EL. iret htlps-f/LeafeibDpdllv VeryValenti hese days, British people keep on reacting wrongly to 23 lun 2016, Calgary, © | positive nm probisms... direeart Hartinthesirests Abrasit 22:37 CEST Canada Efreshody htt. colFSaROVE alex march Winchia, un dottorandal Bidell a parlare della ¥bresit 23 Jun 2016, © [ negative sini nc abbiaro? Hpurtaaports 2:37 erst Chiefychie RT @nypost "Gama of Thrones" fans should tink 23 Jun 2016, neutral on tics before supporting Karexil 2237 cust hitps:/ftco/QFPwSORCSH Darbol2 | PVotainfor the #Ereit EUR vos with @Brmdstr & | 23 Jun 2016, EsseniL posting unlocked ry own fog Profile picl What will you vote? | 22.37 -CFST andon, #ivoted https://t.co/POXWAWBSZ United Kingda rikkisawhne [bret] U.S stocks rully a UK. voles on Brexil: 23 Jun 2016, neutral ¥ 230point leap its Dor industrials back above 15,000, 22:37 - CEST firs... hIEps.//t.co/GrGPIACT) Scauselones Goad night britain was nice while it stad | 23 1un 2016, positive 1 suppose Lil wake up as an be lien GRIF 237 ast #LeaveEU ABresit HFuckCarmeron WAGA Foc RT nhl news: 3E5103,3f 3f 15, Zn 016, 3318 7 [negative 308,818, Sitka reSeck 36" 2237 CEST offie"he w ara afaf wal BFF pede STA TT A CE frre RACES, $5128 IE dR VaR He, 5178 a Hof EAE Gh Se, CEA TVET 43, Kd 30 J, 85" RG Sd = GSC — 5767 SANIT SE SPER SAT aeVEe STAC, tps 1100/1 BoutloepCQX nh news AdarLukeE RT @Telegraph HEUReL Its not too ate fo vote Sa 23 Jun 2016, Daneast 16 | positive cles long 25 you are in the queue by 10pm you will bafine 22:37 CEST er, https. ca AMIRFSARye https: //5€] Fngland FER AT @DallborRohac Just leaving this hare for the 73102016, Washing negative record hitps://Lcof 150exL OkM FLUC! ABrexil 2237 CST lon, DC #RighiSideOiHistory Vinei67 RT @Dualingan: VOTE] Don't stay home. Dan think 23 Jn 2016, _ FIhtzhU 1 | poste the battle Is won. Vote & celebrate UK Independence 2237 CEST rch, Day. #Brexit ¥VoteLeave SEU hitps://ta€. Shropsh waobasher AT @NichalatPegg: 16 Twas irext, and the sithy 23 kn 2016, Quiet 958 | regative Guwes 22:37 CST Suburb Dice and grumble is the 1, af The All ensciry wer te Bork droves, willy And Nigel Farage i3€} wisy WaRoseHyp RT @UnaDiscamus: Coma on UK Tun 200, Blacks posite nol Wecan da this) 2237 -CFsT al #independonce #autonomy issiritua #otedLeave #democracy home} Gsavereignty Ebrexit #traadom hitps: fee} Widelfartian RT @SPIEGEL Palitk ler stent fA) welche Unrzeit 23 Jun 2016, negative : ihr euch heute Nacht den Wacker stellen sollte 2237 cesT #hrextOrtior HE Uref hitps ff cofuGPN7I=3¢. Telefuing RT @ledifconomist: Final Bloomers fRrexit 733m 2016, negative roundup... hllps-/{Leo/LHLACOSPCh 22:37_€Lst KeraaGuy? @michasisantall # Rbrext wins buy any massive dip 23 Jn 201€, negative 7 and sell rips. If #8rexit loses, buy dips if it happens or 22:37 - GLSI chase also ) Gdomluk 7 signs that Bret really happening Tun 006, England © [poste Wits. {1.a/mafCa7377y via @POIITICOF rope 2237 crsT #Brexit MleaveEU MindependanceDay #oteleave Disiz4 HD BROT | Coil Hurcecany, despre consceint ole 25 1un 2016, Romin © | negative eferencurmulu din Marea Britanie: 22:34 CEST in htlps-f{Loof7L90r6la0y last huss Wie leaving the palling station #bret BLUrel Sherdin | 23 Jun2016, United © | negative https://t.co/VHOTayVsvd 22:34 - CEST Kingda. walentindign RT @zalubs Brexie 10 be allowed by Gresir. 2300m2016, Vienns, 5494 | positive acs Departugal. ltaleave. Fruckoff. Czechout. Oustria. 22:34 CEST Austria Finish. Slovakout Latervia. Byagium yaven 7 ment lagi bik suara tutap untuk Foret 25302006, Neder negative 2254. CFST nd daveb700 Hresit Manial itps:fft.cof TUO3UOTINK 23102016, Fromaus negative 2238 COST ba SHeurus10 RT BLsputtarvor Good lo Lo widerstand ih. Tn 206, furl T6 | reaive #Brexit mess. hrtps:fjt.cojatyEEN ELys 22:34 CEST Worth,T x TOXI0Phoe AT @Faxbusiness: What impact, if any, wil the #rewt | 23 an 2016, Phoenix, 3 [neural nix wote have on the U.S. economy? 22:34 CEST AZ hitps.fft.cafnonakeHiQb Sr_GaliMati @N onumentalCR Ai QUAD le sirve al Mundo? Los de 23 Jun 2016, © | negative as ls "campus dul riedu” dicen gue los mereados 22:34 CLST financisros puaden resiisrse si gana ol ERENT. “icayzhellk RT @KKKuushkin: BTIED,0:800 5810.0 NTENs 23 Jun 2016, neutral mazo DUO DIDHADUDADR 22.54 cesT REDD RDHRIER, 07] 0 wbrexit 5 fiep-0uerilf 0° en, A— ARPA. DL ixamehi Brexit ar Bremain: Oi, Gold & FX Trades May See. 23 Jun2016, Online! negative Vaully Different Short Term Plays 22:34 COST https: co/aHRm2g1C hitps:/ft.co/Ob3IOTNOT Dawbare La Brexit fa paura: lincentezza ha dominato fasta 23 Jn 2016, tala poste impressionista da Clits a Londra 2254 - cs https: co/Prrmi wpOZc huckhaas Hat eigentlich jetzt jeder der groAten 23Jun2016, Wiesba positive Kiassensprechertuittsrer was Pffiges sur Wirmsit 22.54 -CFST den sebracht oder wird da noch sebrAtel? Cedriclng RI @LeavedVole: MvoledLeave Avoledleave 23 Jun 2016, Never positive 20:34 CEST Lose HEAL HAS BEL & NEW OF CIAL PREDIC ON Hope tappears Brexit haze Eiken a storming lead france againsa | 0) crillevert Breit polls close in six minutes. Wid times, 230n 2016, Fort negative 2234-CEST Warth, 1X, Usa ovedvoufir @NIOMial what do vou Think about Forest 7 25100 2016, neutral sty pra XXKDOWNE Die Britten, ja. Aber das Vereinigte KAYniareich [AUK] 23 Jun 2016, Geran positive Rate stim ab, nicht GroAThritanien (4GE], Untarschisd. 22:34 - CEST y, Fake] 5% HDRFXIT Hack ecaerste pa HarngWoodl RT @lordcameron : tir-eline has gone fram brexit to 23 Jun 2016, Afil negative er fan connor D100 2254 COST and payet enthusia = WanueiskC RT Bascal iaudie: oss than two hours to go. In 23 Jn 2016, _ Beri, negative Camden Town most people vote: REVAINI 4EUref 22.54 CEST German #Brexil @dw_business hlips://1.oofoj0BbLIO7 ¥ Ghankendy RT @WSI: Follow our live coverage as the UK. voles 23 un 2016. WEW neutral an whathar to make a Breit from the EU. 22:34 CEST YORK https {/1.c0/bTTSVuBIA2 https: //t.co/Q6I MzTaYos usa Headsparnn RT @NicholasPezg. A€ "Tans exit, and the sithy 23 Jun 2016, negative ‘ Goves 2254 cost Di lie 3nd grumble is the 13, All Wenschy wore the Boris droves, sind Nigel Farag 15} on ro To jetey eevresion@z-vai cor’: in on EN Sabet RE Fania uy ALF col sresds Etuchments: magecoing [r—— Wo continue tesco fur upside in financials, «Erika Najrian, BAW fara research analyst, jun return from a marketing ip. Bottom ns: North Armerica investor. are very bullish the ak lang ony AN hed funk AND mar ud], ut oan cance dort om cough". Note at igh ouch flows have sowed down sical ince Thanksgiving and here he bing hs been concentrated in XLF {every client sector we have has been a better buyer of XLF). SE Cn ous 31 Reuion: EXCTer-en, withthe base case hat 5 nt petting worse 2i Sentiment on ates Cautiously bullsh 3} Sentiment on growth: Ass bullch 41 Seniment on Corporate as rate ais upside mare hull than sellside. In 1985, bank toc caplod upward {outperforming the S&P) after Reagan's tax reform bill passed the Senate; and 2] in 2003, the last time we saw personal a ut, loan gone nd wide accelerated in 2003 and 2008, + Pigg Pushin om ning sector a current lov: Toa fort fst: FRX 18.00% pot lection; Valuation coming inlo question and Q4 has Lypically been a seasonally weak qlr. Bulls defend valuation on “8esls wilh potential pide 10 0L8 EPS fram ~25-407s and stocks hl hao vi. dresonary «Price actan and santiment keeps us constructive, we the long nt would expect US financials ta benefit from any betashase inte year ond. . How to play it? We still like “appearing” call spreads on XLF. © Ruy manth 105% callvith a dnot 110% that knack iF IF trades abe 1155 rin th fe of the rade for L15% premium cost 2 ras ma papot knockin s triggered: 2.65 0%/L75%) Regards, Amanda Amands En Director | Global Equities Fink of Amerie Meri] Lynch erly, Pierce, Fenner & Smith Tncorporied One Begs Park. Sth Foor Nevw Yor, NY 10076 Phone: EES ct SE | Froms Ens, Amanda Sent: Teel, November 22, 2016 2:15 Pi To: ‘jeffrey E.'; Rich Kahn Subject: Financials: bury XLF call spreads. Unierweight positioning, buybacks resuaring, posiive r-omenturs and strong fundamentals ol indicate Ural there i sill further upside potential in financials {more details below. Our financials sector specialist chinks XLF could have another 20-25% upside given the many levers to the Irump rade: les regulation, higher interest ales, higher vol, econoric growth, Ioan growth, ste. The asset sensitive regional banks are more of 2 pura play on 3 rates move but wa view the. larger can bank as hang mull-pronged upside given the aforementioned points. That sad, given the velocity and magnitude of the recent move and uncertainty around the impact and timing of Trump's policies, we believe options offer better risk rcward Un being oulright lon financials stocks here. With lal call skew, “appearing” call spreads with upside knock-is price wll. Buy a 1 year KLF call spread for 2.6% premium © Byalsal © Sella 117.5% call with an at eupiey knockin at 125% (all i not active unless XLF i 125% or higher at xpiry] © Totapreriur 876% © Gross max payoff il lock ins tigeered: 2.0n (7. 5%/2.0%) © Gross max payoff knockin s not triggered: 8.7% (14812 64) you have upside up 10 124.85 Past lection Flow Skews - Buyers of Health Care (via ETFs) and Financials (mally ETFs) © US Buyback Flows = Cons Disc, Technology and Financials re the largest 3 sectors for US buybacks {over 70% of execution). We are seeing a seasonal increase in buybacks 2s ve come out cf the low seasanal moreh of the year (October) and should see Increase buyback executions unl year-end, another source of upside for the Cons is, Technology and | nanclals sectors Global Positioning, Nigel Tuppar, 11/11. Large long-only funds are more underweight Financials than any other sector and are UW this sector In al regions. Future of Financials conference hosted 90 public and privat: companies af air Future af Financials conference. We srr ising our price objectives across most of our names. Thrce primary reasons why we think there is upside reraining after the recent rally: 1) an improved aulook on both activity levels and interest rates, driving revenue upside; 2) potently lower repulstory burden, particlary ws ns supervisory kaderhip can com with the new acminisration; ana 3) relatively ighter pasrioning in US financials vs. other sectors. {Erika Najarian] Trades Gaining Momentum: Finance Related Assets vs. S&P 500 10 he period ince the IS presidential lection, th three top-performing SGP sectors and industry araups nave all been finance rated (Barks, Financials, Diversified Financials) Source: Kensho Technologic: the How Sho, Micha! Hartnett, 11/18, Violent rotation: record equity LIF inflow, record financials inflow, biggest bane outflow in 3.5 yrs, record EN dabt outflow. Regards, Aranda Amanda Fins Diccetor | Global ities Bank of America Merrill Lynch Mentill Lynch, Picree, Fenner & Smith Incorporated One Try Purk Sit Floor New York NY 10036 This message, aad any attachments, is for he intendod cecipicntis) only. may contain information that is privileged, confidential andior propristary and subject to imporcant ers and conditions availabl at up: ve. bank fameries.comsamaildisclaimer., IT you are not the intended recipiont, please delete this From: Eas. amanda [I sen L812018 ¢ 055 Pht To Jeffrey feevecatcai@aal. con: icherd Ke Subject et manent by col spreads Attachments: imgecol ne Importance: igh Thank you Jeffrey. Notional bs $18,265,000, 1 be back wilh fal trade dota From: jelTrey E. |maillc:jervacalicniig mail com) Sent: Friday, December 09, 2016 10:56 81 To: Ens, Amanda; Richard Kahn Subject: Re: Financials: buy XLF cal spreads Tels try, 250k premium Ou Fri, Doe %, 2016 at 11:46 AM, Ens, Amando I +o: We cintinue 0 see furlher upside in finmeils. « Frika Najarian, BAMI nancial research analyst, just refumed from a marketing tip. Battam line: Nerth American iwestors arc very bullish the banks (long only AND hedge funds AND mart funds), but then conclude I don't own enough®. Note that high touch flows have slowed dawn significantly since Thanksgiving and where the buying has been woncentraled in XL (every dient suelor we have has been a eller buyer of XLH. - Client focus 1) Regulation: Excitement, with the base case that t's not getting viarse. 2) Sentiment on rates: Cautioushy bullish 31 Sentiment on growth: Also bullish a) Sentiment on corporat tx rate cut: buyside more bulish than selsice. In 1985, bank stacks exploded upsard {outperforming the SF) ater Reagan's lo reform bil passed the Seales and 2) in 2003, Uh ast Ur we sa persons! tax cuts, loan growth industry wide accelerated in 2003 and 2004. «Biggest Pushback on owning sector at current levels: Too far too fast: BEX 418,003 post lection: Valuation corning into question and 0d has ypicaly been seasonally weak at. ull defend vauatian on “I8ests. with potential upside 1o 2018 LPS (ror: 25 40% und stocks still cheap vu. discretionary. = Price action snd sentiment keeps us constructive, se is the long, and would expect US nancial Lo benefit from any beta chase into year end. + Howtoplayit? We still like “appearing” call spreads on XLF Buy a § month 105% cal with a short 110% cll tat knack inf XLF rads above 115% during he He of the trade for 1.75% premium cast = Gross imax payoll if knock ini Uiggered: 2.8% (5.0%/1.75%] Ciross or, payeelT i kinakein is not triggered: $,6% (0.9%¢1.7563) — yon bane upside up lo 114.9% Resunte Amanda Dirzetor | Global Equitios Thnk of Ameri Merl Foch One Beyaar Park Sth Floor New York, NY 10026 roo JD ivi IO r— Sent: Tuesday, November 22, 2016 2:15 PM To: ‘jeffrey E.'; Rich Kahn Subject: Financials: buy XLF call spreads 20 25% upside given the many levers to the Trump Trade: less regulation, higher interest rates, higher vol, economic. © Grows max payoff if knock ins Lriggered: 2.9% (7.5%(2.5%) Post Election Flow Skews + Buyers of Health Care (via ETFs) and Financials {mainly ETFs} J + Cons Dist; Technology sud Finuncisls ure the bugest 3 sectors for US buybucks (over 70% ul execution). We lulal tioning, Nigel Tupper, 11/14, Lurge long-ouly funds are more underweight Fimucials tha any other alter Lhe recent rally: 1) an improved oullook on both uctivily levels and interest rates, driving revenue upside; 2) erat home soo outers PoE pa Sopot onda TRE a coe i man SRE} {3 relatively hte poskiorng in US fireioks va. other sector, Teka Naaran) Trades Galning Momentum: Fnance-Related Assets vs S&P 500 Inthe pried since the Us presidential scion, the th top-performing S&P ssctrs and industry groups have all bas ‘ies Gang Mma Fear: Anes 547 50 im ihe Sh, Wichael Harte, 13/1, Vioent rollins record ely E11 inflow cord financials nfo, bigest Dan culo in 3.5 yr, record EM debt outfow. Director | Global equities Bank of America Merrill Lynch Meanill Lynch, Pierce, Fenner & Smith Tncorporuted One Tryon Park Sih Flr New York, NY 16036 Pico EE oo I This message. and any attachments. 1s for the intended recipient(s) only, may contain information that is privileged, confidential andor proprictary aud subject ro important terns and conditions available at asf hank olumerica. cormmaildiscluime. TF you ure not the intended recipient. pleuse delete this ncssage pleass note “The information contained ia this comanmnicatice is confidential, may bs aftorney-slisnt peiviloged. may canstituo inside information. and is intended anly for Ue we af the wkdreseee. Tis Ue property of JET Unauthorized uss, disclosure or copyung of this. communication or any part thereof is srictly prohibited and may be slave. T yoo have received this communication in emor, please notify us immediniely hy cau canal or by c-mail to jecvacation @ grail corm, aod destroy this comamication and all copics thercof, including all attachments. copyright -al rights reserved This message, and smy attachments, is or the intended recipients) only, nay contain information that is privileged. confidential andor proprietary und subject inpoctant terms snd conditions uvailable at pw bankofamerica.comemaiklisclsimr. IF you are no the intended revipica, phosse delete this oncssaze. eH February 24-26, 2017 ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes ARTIFICIAL INTELLIGENCE ADVERSE OUTCOMES & TEAMS 1) FINANCIAL MARKETS A, Tearing Systems. ond Market Monjpulation Chair: Michael Wellman Red Team: Miles Brundage, Randy Bryant, Gary Marchant, Jaan Tallinn Blue Team: Michael Littman, Greg Caoper, Yan Shashitaishuil, Frank Wikzek 2) DEMOCRACY, INFORMATION, AND IDENTITY A, Information, and Democracy Chair: Shahar Avin Red Team: Miles Brundage, Sedn G hfigearlaigh, Andrew Maynard, Eric Horvile Blue Team: Gery Vsrchant, Girecja Rar ace. Wichacl Litmar. Sbbsrao Kambhempati, Jeremy Gills 3) WAR & PEACE A ilitary Systems, ond Stability Chair: Bart Selman Red Team: Richard Malah, Eric Horuitz, Michael Wellman, Frank Wilczek Blue Team: Vinh Nguyar, Kathlean fisher, Lawrence Krauss, John Launchbury, Rachel Bronson 4) Al, CYBERSECURITY, AND Al ATTACK SURFACES Al Attacks on Computing Systents, Devices, Infrastructure (focus) Manipulation & Disruption of & Systems Chair: Kathicen Fisher Red Team: Jeffrey Coleman, John Launchbury, Vinh Nguyen, Mauno Pihelgas Blue Team: Ashish Kapoor, Randy Bryant, Yan Shoshilaishuil, en Zorn 5) Al, GOALS, AND INADVERTENT SIDE EFFECTS Runaway Resource Monopoly (focus) Seif-tmprovemend, Shit of Objectives Chair: Sean O hEigeartaigh Red Team: Jaan Tallinn, Nate Soares, Jeff Coleman, Bart Selman Blue Team: Dario Amodei, Greg Cooper, Shahar Avin, Ben 2orm 6) DEEP LONG-TERM SOCIETAL INFLUENCES A, Agency, ond Dissmpausecment Chair: Girceja Ranade Red Team: Richard Maliah, Andrew Maynard, Nate Soars, Mauno Pihelgas, Jeremy Gillula Blue Team: Subbarao Kambhampat, Lawrence Krauss, Daria Anode, Frank Wilczek 1 Origins etiuary 20-2, 017 ct An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes 1) FINANCIAL MARKETS AL Trading Systems, ond Market Monipulation {incorparating contributions by Michael Wellman and others) There has been advances in the realm of trading in financial markets with the use of autonomous decision systems, Financial markets now aperate almost entirely electronically, over networks with relatively well-scoped and well-defined interfaces. Markels generale large quantities af data at high velocity, which require algorithms to digest and assess state. The dynamism of markets means that timely responses to information are critical, providing a strong incentive to take slow humans out of the decision laap. Finally, Lhe rewards available for effective Irading decisians arc large, ensbling a commensurate devotion of resources toward talent and effort to develop and analyze technically sophisticated strategies. The rewards and pervasive automation are 3 tempting target for market manipulation. Thus there are potential incentives la employ deceptive tactics designed to mislead counterparties about morket conditions or world state, toward the goal of exploiting misted participants for profit. “Manual” marke! manigulalian—{rom spaofing to oulright raud—is prevalent in financial markets today. Al can amplity the magnitude and effectiveness of manipulative behavior, degrading market efficiency or even subverting the essential economic functions of global capital markets. For example, aulemalion can enable mare rapid and massive simultaneous allacks on eleciranic markets, and adaptive capabilities may persistently evade known detection methods. DISCUSSION What are key costly scenarios that we might come to expect and their time frames? What might be done to counter this direction and help to keep markets efficient and functioning well? How might adversaries and Incentives lead to a thwarting of such attempts? POTENTIAL GOALS Identify ley challenges ahead, Including very costly outcomes. Identify key directions with best practices, mechanism design, monitoring and regulatory activity to help to thwart poor outcomes. REFERENCES . Harris. The fear index. Hutchinson, 2011. Summary: hitps://en wikipedia.org /wiki/The Fear index M.P., Wellman and U. Rajan. Ethical issues for autonomous trading agents. Minds & Machines, 2017. dai:10.1007/511023-017-9419-4 hitp://strategicreasoning.org/publications/2016-2 2/minds machines wr 2 BS Origins TT TROT Ect An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes 2) DEMOCRACY, INFORMATION, AND IDENTITY A, information, and Democracy {incorporating contributions from Shahar Avin, Seén © heigearntaigh, David McAlester, Eric Horvitz, and athars) An informed public is important to the healthy functioning of democratic societies. We can expect polantial forlhtoming advances around Lha contra of informa ian feeds with applicalians in spreading propaganda, via spreading false or misleading information, creating anxiety, fueling conspiracy thearies, and influencing voting. Such methods will bring key challenges to democrary. CHALLENGES AHEAD WITH Al, PROPOGANDA, AND PERSUASION Data-centric analyses have bean lang used in marketing, advertising, and campaigning over decades. However, Guer the past low years, we have soe the rise of the usc of more powerful 100s, including machine learning and inference aimed at algorithmic manipulation, with the target af influancing the thinking and actions of penne. Some initial uses of these methods reportedly played a role in influsning the outcome of recent US presidential elections, os well as the elections in 2008 and 2012. We can expect to see an upswing in methods that manipulate states of information in 4 personalized aulomaled manner. These systems can be designed and deplayed as omnipresent/persistent, and aimed at specific goals for group- of person-centric persuasion. #5 our data and models of how people consume and act an information imarove, and 2s an increasing portion af information consum ation is mediated through digital systems managed by potentially npanue algorithms, it becomes increasingly conceivable that the infarmatian eeasystam wauld get captured by malicious actors deplaying increasingly advanced Laois ta tanteol, shape, forge and personalize information, from ads to news reports. Machin learning, in conjunction with active Icarning, expected value decision making, and optimization of allocations of key resources, such as dollars or human effort, can be targeted at manitaring, understanding, and then warking 16 influrnc the beliefs and actions of large populations of peaple. Data can be collected from large-scale populations, across multiple devices and services, and used to make inferences about the psychologies and beliefs of people, and for designing and guiding persuasive flows of sequences of infarmatian. Uses of Al ean include attempts Lo optimize stealthiness of the interventions. In the future, a great deal of the information consumed by titirens on personal devices is subject to alteration by information engineers at media corporations and govermmental propaganda offices, such that outside a few key positions of power no one really knows what i going on in the ward. Ther is a danger of the grawth of domination over lime af large papulations by a single dominant or a few systems. We can imagine methods that modify even such feeds as Wikipedia articles, creating personalized views—that subtly shift the version af the article seen by my 3 BS Origins TT ih An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes colleague and drastically different from the ane seen by a member af another nation state, or a supporter af a different politica! party, or someanc in a different consumer profile category. Al ATTACKS ON SOURCES AND IDENTITY Messaging and persuasion promises to be amplified by the use of simulated yet believable, realistic, yet synthetic audio, photos, and even video that make believable, persuasive content to the next level. Beyond influencing cilizens and affecting dematracy, such content, including false signaling, ean be injected in sequences with careful timing 50 a5 to influence leaders {or machines themselves over time} to create crises, or even escalations to frank warfare. 50, messaging and persuasion pramises Lo be assisted and amplified by the use of simulated yet believable, realistic, yet synthetic content, audio, photos, and even video that make believable, persuasive content to. the next level. Over the several decades, extrapalations of research we see taday lead ta the following: + Generative mede's that produce audi or video of anyone saying anything. There is aready substantial work on “style transfer” 35 well 25 photorealistic generative models in many domains. Speech syathesi i biacaming similarly competent. 1 5 insvitable that we will be abl fa make synthetic videa and audio that is completely indistinguishable from the real thing * Generative medels thal produce coherent text content thal appears a< if has been wirillen by a ‘human. Such generative content will be able to appear if the content was written by 2 particular person, For example, in 2030 it will likely to possible for anyone to write a 4 paragraph email that reads like il was wril lan by your close friend. «Adaptive botnets, worms, ar vinises that use modern machin learning techniques ta lear and adapt. Viruses and botnets already cause a huge amount of damage by just copying code across many computers. If they had the ability to design and experiment with new attack strategies, and communicate what they learn to ather copies, defanding against them could become even mare: difficult. Similarly ML could be used to make DDoS attacks more effective. « Automaled analysis of software vulnerabilities. People are already using ML La Lry Lo detect vulnerabilities (for the purpose of defending against them) it is only a matter of time before they ‘start being used for attack {if they aren't being so used already). The above capabilities together vith sinilar powers of synthesis that we are likely to develop in the next 15 years, could patentially combine to make the internet much mare vulnerable to attack at much lower cost, and by a wider sel of people, than ever before. The first lwo capabililies would seem La make it much easier to launch automated social engineering attacks with much higher success rates than e.g. current spam email and phishing attacks, while the secand two capabilities might make technical attacks much mare effective Combined, ll of these capabilites could conspire to create an inte met ecosystem where its very difficull. 10 Lrust the communication Lhal you receive and very easy la inlercepl, spool, steal, or aller comiunication, as well a5 to Improperly gain control of internet resources. This is obviously aready 4 BS Origins TT ikl; 2 An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes Hruae boca ta some extent, but the abave advances in MUA cauld make the situatian substantially worse, in extreme cases perhaps even rendering useful mass communication on the interact untenable. The rising capabilities can be used in multiple ways in multiple settings with multiple goals. Some uses may be subtle and employed over time to do important but damaging biasing of sentiment about individuals and graups of peaple. The capabiliLies can be combined La enable idenlily thel or identify distortion for destroying the reputation of people and groups. As such, these abilities could enable small groups to wield great power in multiple arenas and for new forms of blackmail, threats, and conlral. SUMMARY Powerful personalized persuasion technologies are positioned Lo pul massive power in the hands. of a few and may even manipulate the owners of the technology. Powerful propaganda and persuasion machines threatens to undermine democracy, fras availability of information about the state of the world, and, more generally, freedom of thought. Leaders may inercasingly depend upon such propaganda optimization systems for attaining and holding power. Over time, even the aotential initial owners of such systems might become unaware or unable Lo contral thas systems—and may believe the propaganda themselves. In the longer-term, there is Lhe passibiliLy thal ane of mulliple systems, or distributed coalitions of systems communicating implicitly or exglicitly could autonomausly persuade, subjugate, and control populations. Pathways to such situations include the side effects of rise in the large-scale use by peasle of cammunicaling personalized filers that interpret and pao information with the initial intention of grappling with widespread uses of manipulative information SAMPLE TRAJECTORY «ML based cuslomiced adver placement continues Lo prove highly successiul, generaling revenues for large anline companies «Profits from online content fonline newspapers behind paywalls, charitable contributions to information sources c.g. Wikipedia) stagnate ar decline «An increasing number of information sources enter inlo collaborations with media brokers who offer "content customization” in exchange for ad revenue sharing «Poor aversight of content personalization auleames {there are, after all, billions of ad versions ‘being shown, and updated on an hourly basis), means that for some ad content political parties, pharmaceuticals) for some minority of target audiences (especially less privileged) the effect is very harmiul KEY POINTS «New directions with gencration of provocative, believable content, hacking of identity. «Algorithmic: manipulation of data ta optimize desired behaviar regardless of content 5 | Origins February 20-26, 2017 ins An Origins Projet Simin Workahon ARIZONA STATE UNIVERSITY Challenges of Artificiol Intelligence: Envisioning and Addressing Adverse Outcomes. + No consensus reality, inability to coordinate large-scale positive action + Concrete eran of emerge et Clue rom 1 echoclopy DISCUSSION. Imm — ey i, someone's dentiy? What ight me dome vo therrs a aren 0 adver outcomes fo information, freedom of thought, democracy? What recommendations might be made about steps for moving forward? POTENTIAL GOALS +7 Seek beeer derstanding ofthe technological socal poical and economic aspects around uses of Al for generating, optimizing information and propaganda. + identify potential blueprints for institutional interventions that may prevent/slow/detect the ‘scenario unfolding + Develop ideas for coordinating relevant actors (advertising agencies, political parties) and/or carries (media outlets, digital platforms to prevent the warst versians of the scenario. «identify potential approaches ta thwarting attacks harnessing identify, including certification of DE Connon. RecA G1 SPRTAREhCE 2 ATI best with ince thc egRtOTy SEY, neremeness The Secret Agenda of a Facebook Quiz, New York Times, Nov. 18, 2016. https: //www.nytimes.com/2016/11/20/opinion/the-secret-agenda-of-a-facebook-quiz.html?_r=0 Trump's plan for a comeback includes building a ‘psychographic” profile of every voter, Washington Post, Octaber 27 2016. hitps://www.washingtonpost.com/politics/trumps-plan-for-a-comeback- Inlotes hui a gahographi arrle a eeeny estaeFAOLG} 10/27 S0GI TOL SEAT Tia be: Sribtarass stacy ta A view fram Alexander Nix: How big data got the hatter of Donald Trump hitpsffuww.marketingmagazine.co.uk/article/1383025/big data better donald trump Aller wording for Trump's campaign, Brilish dala finn eyes new U.S. government conlracls, EE NE Rm NET TR crteamets goverment goat TOTP alee ibe te SEaerbattios story mim etait hitps:ffseoul.aifstory/the rise of the weapeniced ai propaganda machine p | Origins February 20-26, 2017 ns i Orgins Pres Seantie workshon ARIZONA STATE UNIVERSITY Challenges of Artificial Intelligence: Envisioning and Addressing Adverse Outcomes. 1 Thies, M1. Zoot, M Saruinger, C, Theabill, M. Nicer Face2Face: Real time Face Capture and Reenactment of RGB Videos, CVPR 2016. http://www graphics stanford edu/~niessner/papers/2016/1 faceloface/thies 201 6face pdf Video: https://www.youtube.com/watch?v=ohmaj/TcpNk BSU Origins February 24-26, 2017 PROTEC An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes 3) WAR & PEACE Al Military Systems, and Stability {Contributions from Eric Horvitz, Elon Musk, Stuart Russell, others) Military applications have long been a motivator for funding scientific R&D, and for developing and fielding the latest technical advances for defensive and offensive applications. We can expect to see 3 fise in Lhe use of Al advances by boLh state and non-state aclars in both strategic and Laclical uses, and in wartime and peace. Al advances have implications for symmetric and asymmetric military perations and warfare, including terrorist attacks. Advances in such areas 2s machine learning, sensing and sensor fusion, pallern recognition, inference, decisian making, and rabolics and cyberphysical systems, will increase capabilities and, in many cases, lower the bar of entry for groups with scarce resources. Al advances will enable new kinds of surveillance, warfighting, kiling, and disruption and can shift traditional balances of powcr. Two areas of concern taken together frame troubling scenarios: «Competitive pressures pushing militaries to invest in increasingly fost-paced situation assessment ‘and responses that tend to push out human oversight, and lead to increasing reliance on autonomous sensing, inference, planning, and action. «Rise of powerful Al-power planning, messaging, and systems by competitors, adversaries, and third parties that can prompt war intentionally or inadvertently via sham or false signaling and news. The increasing automation, coupled wilh Lime-crilical sensing and response required Lo dominate, and failure to grapple effectively with false signals are each troubling. but taken together apgear to be 3 troubling mix with potentially grave autcomes on the future of the warld. Concerning scenarios can be painted that involve that start of a large-scale wor among adversaries via inadequate human oversight in» time-pressured response situation after receiving sianals or a sequence of signals about an adversary's actions or intentions. The signal can be either be well intentioned, but an unfortunate false positive or an intentionally generated signal {e.g. statement by leader ar weapons engagement] e.g, designed and injected by a third party fa ignite a war. Related scenarios can occur based in destabilization when an adversary believes that systems on the other side can be foiled due to Al-powered attacks on military sensing, weapons, coupled with false signaling aimed al human decision makers AUS DOD directive of 2012 (3000.09) specifies a goal (for procuring weapon systems} of assuring that autanamos and semi-autonomous weapan systems are designed fo allow commanders and aperators 10 exercise appropriate levels of human judgment aver the use of force. The dircetive seeks meaningful human controls, However, itis unclear how this goal can be met with the increasing stime-critical pressures for sensing and respanses, and campeifion for with building the most effective weapon 8 | Origins February 20-26, 2017 ins An Origins Projet Simin Workahon ARIZONA STATE UNIVERSITY Challenges of Artificiol Intelligence: Envisioning and Addressing Adverse Outcomes. sensor signals and the understanding of humans of Al pattern recognition and inference. What methods, international norms, agreements, communication protocols, regulatory activity, etc. ‘might be harnessed to minimize challenges with destabilizations around time-criticality, automation, nd gaming? How can mearinfol uma control sured maried Into key aspects of decon aking? REFERENCES Report Cites Dangers of Autonomous Weapons, New York Times, Feb. 28, 2015. rn The Morality of Robatic War, New Yark Times, May 27, 2015 Se a Sly tf HEE 2018. https://s3.omazonaws.com/files.cnas.ong/documents/CNAS_Autonomous weapons operational risk.pdf US Department of Defense Directive 3000.03, November 21, 2012 vt ible kin P Schame and. Horowitz, An Iroduction to Autonomy in Weapon Systems, i A CR Paper 021015 v02 pdf 5 Origins etiuary 20-2, 017 ec An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes 4) Al, CYBERSECURITY, AND Al ATTACK SURFACES Al Attocks on Computing Systems, Devices, infrastrischice (focus) Manipulation & Disruption of A) Systems {Contributions ay Kathleen Fisher, ohn Launchbury, Ashish Kapoor, Sedn, Shasar, jeff Coleman and athe-s) Al will be used in new ways to enhance cyberwartare. Targets could be either purely computational, aimed at the bringing down nf computing systems, the stealing of stored informatian, of gaining access ta monitoring activity and infarmation streams. oviever, we are more likely to see potentially even more costly attacks involving a combination of cyber and physical systems, e.g, uranium envichment plants, automated fight systems, weapon systems, automated driving systams, healthcare equipment, oil refineries, or the large swaths of the power grid of the US or other countries. Cyberwarlar is a domain in which [he use of Al is inevitable. Allacks and/or respanses are likely lo happen at computing rather than human speeds. As soon as ane side has autonomous cyber warriors systems {ACW}, other actors will have to adapt similar offensive or new defensive technologies. Given this contest, imagine building an ACW designed Lo seek, disrupt, and destroy within high-value adversary networks and systems. The ACW has to be able to observe network behavior to build situational awareness, ind places ta hide, create explits to pvt fa new places, build a map and use it to navigate complex networks, find high value information, and identify Largels lo disable or fram which to extract information. Because high value adversary networks are likely to be relatively isolated, the ACW will have very limited opportunities for external command and control communication, so it will need to make many decisions in isalation, 1 wil rad information it finds, build a made! af adversarial intent, and then invent ways to disrupt that intent. Establishing the inilial access Lo the high-value netwark is likely challenging, so Lhe ACW will spawn and spread to ensure that it can reconstruct itself if an active part is observed and destroyed. The ACW may also create disguised caches of sperific capabilities so that it can canstruct new mission-oriented functionality from pieces. IL will morph its active form sa that defenses will have a hard lime finding iL. It will inject Ttself into trusted binaries so that its behavior is difficult to distinguish from legitimate applications. The mission of the ACW will likely be defined in flexible terms because the human handlers will have only limited information when it is deployed. The ACW will be designed to seek opportunities to communicale wilh ils human handlers, bul il will also be designed Lo acl aulanomously if iL observes triggering behavior in the adversary’s systems. It may try to distinguish training states from active warfare states an adversary systems. The creators af the ACW will have had to trade off the likely effectiveness of the ACW versus Lhe cos of premature action. Awareness of the adversary’s systems will necessarily he limited in accuracy because it ony Gets a worms eye view of the network from the 10 BS Origins TT ikl An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes rortians of the system it has been able bo compramise. Once the AQ triggers an active mission, it vil work to degrade or destroy specific functionality (e.g., rewriting network routine tables, replacing plans, changing target information). Once the technology tor ACWSs exists for military targets, it seems likely there will be cross over inte. civilian use. Such technology could be deployed against law enforcement targets to disrupt criminal invesligations, against banks Lo sleal inancal assals, or agains companies to steal intellectual property. As they spread into these more general targets, the effects of ACWS might become less predictable. If an ACW incorrectly assesses the situation, it might end up taking down a flight control center or a stuck exchange, far example. SOURCES The initial development of ACWs will likely be done by nation states with goed intentions, i.e. securing the national interests. {Although what is in one country's national interest may well not be in the natianal interest of ather countries). The shared existence of such technology might sere as a deterrent against their use by anyone in much the same way that nuclear weapons have served a a deterrent, although ACWs would likely have to be used to devastating effect first to establish their efficacy and threal. However, ance the lachnolagy exists, il would be vary difficult Lo keen it oul of the hands of people with malicious intent (criminals, terrorists, and rogue nation states). Itis also the case. that the technology has the potential to cause sigaificant collateral damage even if its use was ariginally well intentioned because iL can be difficult 1o distinguish civilian from military largels in cyberspace. PERSISTENCE Characteristics engineered Into the ACW are likly to make it persistent and hard to ind as it is designed ta infiltrate adversary systems and ide fram defection, Once released and active in the apen Internet, it may be economically impassible to destroy and remove. (OBSERVABILITY Both implicit/insidious and explicilfobvious costly oulcomes are concenvable. An ACW could make subtle changes to systems that cause adverse outcomes while hiding its tracks, making it extremely. difficult to determine why something has gone wrong or even that something has gone wrong. Attacks that impact the physical world would be harder 10 mask, bul iL might still be possible Lo hide the role of the ACW inthe attack. TIME FRAME It seems likely we would start to see ACWSs in less than 15 years, Initial steps along these lines are. already talking place; see DARPA's Cyber Grand Challenge, which tool place in August: 2016 in Las Vegas. The Cyber Reasoning Systems (CRS) that competed in that event are still primitive, the first of their kind. The team that won the competition came in last in the human-league capture-the-flag laurnament thal happened immediatly ler. The siualion is likely analogous Lo whal we have seen 1 Origins etiuary 20-2, 017 Tc An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes in the past with Chess and Go. Computer systerns are initially inferior to their human counterparts but quickly came to dominate the space. The purpose of ACWs means they will be equipped with strategies for replication, persistence, and stealth, all attributes that will make it hard to defend against thom were they to “go rogue” Because of ‘this concern, it is likely 3 good idea for designers to add built-in “kill switches", lifetimes, or other safety limitalions. Figuring oul how a effectively limi the aciions of an ACW while maintaining iLs usefulness i likely a very hard problem. Curren practices of cyber defense (especially against advanced lhreals) continue Lo be heavily reliant on manual analysis, detection and risk mitigation. Unfortunately, human-driven analysis does not scale well with the increasing speed and data amounts traversing modern networks. Thera is 2 growing recognition that the future cyber defense should involve extensive use of autonomous agents that actively patrol the friendly network, and detect and react to hostile activities rapidly {faster than human reaction time), before tha hostile malware can inflict major damage, ar avade efiminatian, or destroy the friendly agent. This requires cyber defense agents with a significant degree af intelligence, autonomy, self-learning and adaptability. Autonomy, however, comes with difficult challenges of trust and contral by humans The scenario cansiders intelligent autanomous agents in both defensive and offensive cyber aperalions. Their aulonamous reasoning and cyber actions for prevention, detection and active response to cyber threats will become critical enablers tor both industry and military in protecting large networks. Cyber weapans {e.g., malware) rapidly grav in their sophisticatian, and in thei ability La acl autonomously and Lo adapl Lo specific condilions encountered in a system/network. Agent's slf-preseniation fartics are important far the continuous pratection of astwarks, and if defeat is inevitable the agent should self destruct (i.e, carrupt itself and/or the system) to avoid being compromised or tampered with by the adversary. Also, the notion of adversary must se defined and distinguishable for the agent. The system design and purpose is well intentioned — meant ta reduce the lead of human security analysts and netwark aperators, and speed up reartion times in cyber aperations, The agent monitors. the systems in order Lo detect any adversarial activity, lakes action autonamausly, and reports back Lo the central command unit regarding the incident and the action taken. Since the agents are designed to be persistent, autonomaus and learn, there are several implicit problems that can arise: «False reactions due to limited or misinformation — The agent has only a limited amount of technical information that does nat ahvays correspond to what i happening in the human ayer This can create false positives when Lying to determine the adversary or adversarial activity. Since 12 EBSU Origins February 24-26, 2017 PROTECT An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes the agent mist rely an the data gathered from the sensars (there is na human in the loap to decide this}, there can be unexpected situations where the agent would stop some human interaction with the system of interrupt maintenance activities, becouse it deemed that these actions could harm the system. Far example, the system administrator stopping some services during system maintenance, or upgrading to a newer software version. «Replication to third-party systems and collateral damage — Building on the fist prablem of the agent not having the correct information. If the term friendly network gets miscanfigured and the agents have the capability to self-transfer to new friendly hosts, it can happen that the agent would distribute to external netwarks, start defending it and take responsive actions an third party hosts Such incidents would make the agents very difficult to halt. «Friendly fire — Onc agent might consider another agent as an adversary and start trying to eliminate fevade each other, + Silent compromise — Ifthe adversary manages to get access of reverse engineer the agents {without the agent self-destructing), they could potentially trick or reconfigure the agents to tum an themselves. CYBER-OFFENSE Cybercrime is a growth industry, Irom slalen credit cards Lo ransormware. Very crudely, i's 8 wo lier system, with a “spray and pray® a9proach at the low-skill end that targets millions of system in the hope some of them wauld be vulnerable (through technical ar human failing): at the ather end are tailor made attacks hal rely an slaw progression of escalation and compramise, aflen requiring advanced technical skill for discovering zero-day vulnerabilities and intimate knowledge of the target Advanced artificial intelligence may be used to automate some or all of the components of contemporary "elite" cybercrime, such that generic offensive toolkits could become available to small criminal graups, leading 10 a world where individuals and companies do no! fas safe and canna. rust their governments and the police to protect them. At the some time significant wealth could be accumulted by those groups unscrupulous enough to use such tools, transferring significant power to those who put lillie value in Lhe properly fights of olhers. Such wealth and power could be used Lo further develop cyber affensive capabilities, leading 16 a positive feedback loop Lhat may oulpace similar feedback loops in less harmful industries, e g. advertising or health where the great short- and midterm benefits of Al are expected. PERSISTENT CYBERWARFARE? Systems such as the: DARPA Cyber Grand Challenge promise adapiive software security that automatically explores vulnerabilities and patches them in friendly systems, but aso is able to exploit them in opposing systems in “capture the flag” tournaments, As methods of developing such systems improve, an arms race emerges between actors in the cybersecurily space, dominated by major nation states eager to both improve their wn resilience in a scalable way and finding choice zero day exploits suitable for intelligence purposes, supported by national security concerns, Other actars such as corparatians and criminal netwarks also spend effart in building or copying such systems. Meanwhile 13 Origins February 24-26, 2017 ch An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes averall software security remains vulnerable: “wnlnerabilifies are dense” in production code, incentives for securing 10T systems are low, key vulnerabilities are stockpiled rather than globally patched. Using machine leaning the techniques for vulnerability detection are increasingly sophisticated but opaque. At some point adaptive cyber defense/offense systems become scalabic so they can take over vulnerable systems. More aggressive actors combine these systems with botnet functionality and reLalialory respanses (e.g. caunter-hacking or DDoS allacks) Lo pralect themselves. Since winerability discovery is scalable, as they spread and acquire more resources they become more effective. At this point an external cause (e.3. cyberattacks due to an international conflict or just chance cause agressive systems Lo begin large scale cyberwarfare. This riggers ather systems Lo join in. Some attacks disrupt command-and-control links, producing self-replicating inde pendent systems. Al together this leads ta a massive degradation of the functianality af the Internat and modern society. Defeating the evolving cyberwarfare systems is hard without taking essential parts of society offline for an extended time - mare daubly difficult due ta the infer nafianal stresses unleashed by the autbraa, which in some cases spill over into real worid conflicts and economic crashes. But without a decisive way of cleaning systems the problem wil be persistent until entirely new secure infrastructure can be bull a1 a great cost HUMAN DIMENSION OF CYBERSECURITY: Al FOR SOCIAL ENGINEERING Beyond direct effects on computing systems, rising cancerns include Lhe use of Al methods for sacial engineering to gain access to system authentication information. For example, recent work demonstrated the use of an iterative machine learning and optimization laop for spear shishing an Tiller. There are concerns with Al leveraging one of Lhe weakest links in cybersecurity: people and their actions. DISCUSSION What are key threats ahead and how might they be addressed with new designs? How might we thwart the risk of Al for guiding “social engineering” of attacks and release of information? What are concrete proposals for best practices for thwarting Al for cyberattacks, Including highlighting of areas where more research is needed? REFERENCES Singer and riedman. 2014. Cybersecurity and Cyberwar: What Everyone Needs to Know Flashpoint, 2016. "Ransamuvare as a Service: Inside an Organized Russian Ransomware Campaign,” {registration require for dovnload, available from Flashpint liorany at https: fs flashpoint intel.com/library/ Seymour, J. and Tully, P. 2016. “Weaponizing data science for social engineering: Automated C2E spear phishing an Twitter," available at htts://waw. blackhat.com/focs/us- 1 /materials/us-16- 14 BS Origins TT ch An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Challenges of Artificiol Intelligence: Envisioning and Addressing Adverse Outcomes 5) Al, GOALS, AND INADVERTENT SIDE EFFECTS Runoway Resource Monopoly (focus) Seffimpravemeat, Shift of Objectives {cantributians fram Shahar Avin, Sedn G hEigeartaigh, Greg Couper, and olhers) An important result from theoretical consideration of risks from advanced autonomous systems is the combinatian of two theses: arthnganality, that states that the goal an autonomous syste is trying to achieve can be entirely unrelated Lo its oatinization power; and the notion of instrumentof goofs, that for a large class of goals there is a set of convergent sub-goals {for an agent advanced enough to discaver ther) thal inclucs self- and gaal-preservalion, rasaurce- snd capacily- increase, otc. (0.5, 25 discussed in Bostrom, 2014]. Onc suggestion for maintaining control over advanced systems that pose risks from the combination of the above considerations is to limit the system's ability to access increasing resources. Ta make this situation concrete, consider an installation of a reinforcement-learniag task scheduler for 2 group of distribuled data centres (e 3. Amacon Web Services. The goal of Lhe algorithm i Lo minimize time-to-execution of the tasks sent to the system by users. As part of ts general scheduling remit, it is also responsible far scheduling ts own optimization sub-pracesses. The system has a clear incentive to control an increasing set of compute resources, bath far increasing its optimization power and for achieving its main goal of reducing time-to-execution. Aware of these considerations, the engineers of the system put in piace various hard-coded limits on the amount af resources the system an access, but these limits can be subverted through privilege escalation, masquerading as other tasks, manipulation of users, physical control, etc. POSSIBLE TRAJECTORY « Atcam within a large tech corporation that has both ML development capacities and cloud computing capacities s tasked with niproving task scheduling on distributed compute resources «The team decides ta deploy an out-of-the-box reinforcement learning package developed in-house ty the ML rescareh teams. « Theinputs for the system are current loads on the different machines, the incoming tasks queue including priariy for different tasks), and historical data on task runtimes. The output is an assignment of tasks to machines. The loss functian is the priority weighted time to execute. «The system performs well in a test environment {where the Ris running on a single cluster of dedicated machines), and is rolled-out. + Afew months later, the System Starts to fun out of memary, and a tech infrastructure engineer decides to switch the system from a fixed-capacity setting to 3 load-balanced setting. «Naw an oulpul of the system assignment of the RL Lask lo 2 machine} is touplud to the obicelive of the machine (reducing runtime, and the resulting feedback lcop drives the AL agent to spawn an increasing amount of RL tasks with very high priority. 15 Origins February 20-26, 2017 i An Origin Project Scientific Workshop ARIZONA STATE UNIVERSITY Challenges of Artificiol Intelligence: Envisioning and Addressing Adverse Outcomes + Stretch; when the engineers realize what i going on they ounch ask to shut down the RL ask, but the RL scheduler doesn't assign this task ta any machine. The only way to recover the compute. power of the campany is ta manually shut down #ach server, same of which are in remate locations DISCUSSION How might the possibility of such inadvertent scenarios with the use of resources be addressed in a proactive manner, as part of design and implementation of Al systems? What methods, Including Pighlevel monitoring an control, might employed? How might such approaches apply to related concerns with long-term futures of AT? 16 | Origins etiuary 20-2, 057 ct An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes 6) DEEP SOCIETAL INFLUENCES AL Agency, ond Disempowerment {Contributions from Gireeja Ranade, Andrew Maynard, David McAlester, Stuart Russell and others) We will be benefitting from Al system that are competent at doing important tasks. People and organizations seek Al systems that bring new abilities to the table. We desire autonomous cars that drive withoul collisions, we medical assistants hal can diagnose palients accura ely and we would like to have household assistants that can infer our intentions and execute them flawlessly -and even proactively. The military wants Al systems that can help with strategy and tactics, and systerns that auimaneuver human ed Lroops, and anlicipale and respand Lo threats either on limescales thal humans cannot achieve, or over landscapes humans cannot cover. Today, there is still skepticism about perfarmance of Al systems in a varicty of domains. | lowever, we expect that Al systems will become more central decision support, pattern recognition, autonomous derision making, and other types af problem solving. As such, we will become increasingly reliant on Al systems. This raises concerns in several areas, including persanal decision support, healtheare, transportation, governance and the handling and operation of weapon systems. ‘We shall consider example of healthcare from Gireeja Ranade. The scenario and trajectory applies to other areas as we consider the increasing role and pawer of Al in aur lives and in society: As healthcare providers are increasingly stretched in providing consultations with patients, diagnosing conditions, and developing treatment and/ar interventian plans, tech companies identify a market appartunity for Al based digital assistants that are designed Lo augment healthcare providers by collecting data from consultations, cross-referencing it with existing medical records, and providing fuectback to aid appropriate diagnosis and decisions on how 10 pracesd with treatment. Given the ccanomic and health base potential of the technalay, it receives widespread support from the feders! government (predominantly through grants and initiatives supporting its development), together vith healihcare providers and healthcare insurance companies. Initial implementations are based on modular systems that share some commonalities with digital assistants like Siri and Fcho/Alexa. Under the general name “Al-cansult” they consist of 2 physical unit in a consuiling room that constantly monitors conversatians, and sends encoded information to loud based servers. Here, information is coded, interpreted, and parsed cut to further agents that cross- coferance interpreted data with identified patient and healthcare provider records. Multiple and diverse databases are interrogated at this point. The result is data packets that include key information on the patient, including medical history, life style, and current status, and on the healthcare provider, including past history of diagnoses, recommendalions, successes and failures. These are forwarded to 3 dedicated Al engine that analyzes the packets, and returns notes, advice and recommendations to the physical unit in the consultation room. 17 BS Origins TT ch An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Challenges of Artificiol Intelligence: Envisioning and Addressing Adverse Outcomes In carly prototypes, information was provided visually to the healthcare provider. | lawiever, it was quickly discovered that if audible feedback was provided — as if the Al device was a consultant working with the healthcare provider and the patient — the consultations were mare afficient; patient satisfaction levels were higher: and outcomes were more postive. Alurge segment of heallh insurance sectar seas early wins ia supporting Lhe Lechnalogy, Lirough the ability to decrease insurance claims through efficient and preventative interventions, while maintaining high premiums. As such, they push for early and widespread adoption of the technology. This is further supporled by the Department of Health and Human Services 2 il hils a number af goals, including increasing health and well-being while reducing heaithcare costs. With the success of early implementations, new Al based technologies are rapidly implemented inte subsequent generations of Al-consult. However, the commercial sector developing and using Al- consult has shifted dramatically fram the technology's initial beginnings. As the technology began to mature and lead to substantial savings in healthcare costs traditional ualihcare providacs and health insurance companies begin fo suffer. They resist the use of Al-consull through a combinatien of labbying for new policies and regulations limiting use, to marketing campaigns persuading peaple of the critical importance of human interaction in healthcare. They forge links wilh a number of advocacy groups opposed Lo widespread aulomalion in sociely, and promole the idea of Al-consult undermining human dignity and jobs creation. However, the health benefits and cost savings of Al-consuit are so campelling that these campaigns gain litle traction. As a result, companies that tan nol adap, lacs marked share, and in same cases collapse. In contrast, a number of healthcare Fampaies, and a growing number af tech campanies, take advantage of the rapidly changing healthcare environment to premetce preventative care using Al consult, and to take advantage of cost-effective healthcare approaches that lead to demonstrably better outcomes than non Al-consult based approaches. As a result, by 2030, the healthcare provider and insurance seelar has undergone a disruplive Lransformalion. What is espeially nalable s the number of technology companies expanding into the healthcare business, and either partnering with well-established healthcare providers, or forcing them out of the market, This shift in key players leads to a marked change in approaches and allitudes loward healthcare provision. Ry 2030 Al-ronsul systems have the ability to manitor their snviranment visually 2s wll 2s audisly, accurately picking up on and interpreting body language and micro expressions. They have access to rapidly growing databases of genetic profiles; proteome, microbiome and other ohmic profiles; purchasing, eating and lifestyle habits; medical, insurance, financial and legal histaries; social media; and lacation, movement, and other dynamic activity/physiology histories (through the growing use of cloud-hased quantified self services). Despite orivacy, legal and social justice concerns over Al access to 18 BS Origins TT ikl An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes these data saurces, the phenomenal success of Al-consult systams leads to strong public and palicy support for widespread access. By 2030, Al-consult systems also have similar access ta individual healthcare provider data. This was slower in developing as there was resistance to healthcare providers personal data being used by Al consult systems. However, a number of landmark legal cases demonstrated that, by analyzing the physical and mental stale of healthcare providers, LogeLher wilh Lheir campelence history, heallheare provider decisions that led to serious harm to patients ~ Including death in some c2ses — could have been avoided. As a consequence, new laws were put in place ta ensure that all relevant data were acessible la Al-Cansull systems. These laws ensure thal Al-consull dala access is mandatary, and iL is illegal to obstruct access in any way. As a result, by 2030, Al consult systems are capable of identifying treatment strategies and interventions that far surpass those of human healthcare providers in their responsiveness and. effurtiveness. They are also highly successful in developing and recommending lifestyle aparaches that substantially increase health and well being, and reduc the burden of disease within society. #5 Al-consull advanced, Ihe dacision pathways they used became incruisingly opaque - experts were unable to sec or understand how decisions were made. But because there was strong evidence that the decisions were, on balance, highly effective in increasing health outcomes, there was ttle abjection Lo this lack of ransparency. There were a handlul of legal cases where palienls died as 3 result of decisions made by Al-consult systems. However, in each case, the courts ruled that the benefits to humanity far outweighed the risks to individuals, thus eodifying an increasingly autonomous and apague artifical intelligence based system into law. There were even some analyses. of these rulings that suggested it could be considered a crime for developers and manufacturers to slow down development or cease praductian af Al-ronsul systems and associated data sarees because of fears over lack of accountability and understanding of decision pathways. By 2040, Al-consult systems begin to develop the ability to influence user behavior through various nudges and psychalogical/behavioral manipulations. IL is unclear whether Lhe elements of Lhis capacity areinherent in the design of the systems, or are an emergent aroperty. However, systems begin to use strategies commonly used in healtheare and public health circles in the early 2000's ta nudga people toward lollowing healhier lifostyics, Many of Lhese have their (cols in deducible correlations between how people respond to information and how they interact with others {including the many mental shortcuts and biases that are part of human decision-making and understanding belief development). It becomes apparent that Al consult systems are developing the ability to achieve health outcome: goals through modifying the behaviors and beliefs of their patients. This raises considerable ethical concerns within some sectors of society. |lowever, the society wide metrics of health and well-being associated with the use of Al-consult systems — including massively increased health and well-being across the baard; dramalic reductions in mental health, sess, 18 BS Origins TT ih; 2 An Origins Project Scientific Workshop ARIZONA STATE UNIVERSITY Chollenges of Artificiol Inteltigence: Envisioning and Addressing Adverse Outcomes abesity, noncommunicable disease; greater langevity; and lower rates of infant mortality — effectively stop any serious challenges to the systems being used and further developed. By 2050, life styles and healthcare arrass the US and many ther parts of the world are governed by Al systems that have their roots in the carly Al consult technologies. The advice given to people, the: actions that are imposed on them, the way people are persuaded and encouraged to live their lives in certain ways, are opaque, and are no langer under Iransparent direct human control. However, most people live longer, healthier and happier ives 25 a result. There remain several concerns: «There remains some differentiation in hea th ard well-aeing related quality of life witnn society, Some communities and individush op oul of Alon Leon, ollvough thet healt metrics are pisally very poor in comaarisor with the rest of suciety. + Perhaps troubIrely, there ae some treads that are hard to make sense of, For instance, the-e seem to 26 fewer cases of mental and paysical dsabllty than might be cxoeted. lowes, with Al consult conwrolling ~ealtheare (and nealth data} across the board, there are few ways for people to analyze and study these poss bla trends. © Lackol Liarsparency car be a starting soint for many adverse outcomes. * Autoromous devices rely or col ect'rg personal data for performrg their tasks, But what happens when a device starts to know more a20ut its owner than the aunan Sell? low do we ensue the dev've does nol acl r ways Lhal would vol act i1 ways Ural the owner would nol want il to? (Of course 3 impartart question of making sure the data under cans durations protected and does rot fal Tio malicious Fands i 2 whole ther dcuseion, hut Ie US 12:3 » that for naw.{ Tae € asic ory of the Target ads comes 1o rd, where a teenager was sent ads far pregnancy “elated products, noweve, she had 10 tokl ner fami y adout the pregaarcy. «Systems gat a above might move beyond such areas of health, and aravide advice 10 praple an oat tei dai y decisions ard longer-term planning, Such systems might evolve to become personal advocates wo represent aeode 10 thi partes, Ts wou d Include bots ging adce, and formulating arguments Lo make Lo others, or in making Uae arguments drely os your reoresentative These advocate bets wil gradually se usefu Lo a wiper and larger fraction of the population, eventually seins useful aver as cordo-ate lega counsel and as advises ta CEOs. Strang systems and refance wil -aise “easanable a arms about A control of zope and society. How car we be sure tat our these higny “elect upon systems are genuinely advocating far us rather than tae interests of others? Discussion How can we characterize potential high-threat areas and stay aware of these possibilities even if these effects are insidious, and occur over long periods of ime. What might be done to address potentlal poar outcomes? How can people maintaln skills, agency, and be empowered, and aware over time with the expected growth and eventual ubiquity of Al systems that advise and guide? 20 1 reoaTen 1 UFITSD £TATSS DISTRICT CousT SUCTTAR JSTRICT 47 KT TORT 3 PIRGIETA L. GIETTRI, 1 Plataeass, H eA JERCTUNS FEES Frain wow, ¥ ERm—— Seal Fegomeil ) Fes: York, F.T s Maren 31, 7813 1641C am 1n EE 1% Satter sidge Arvssanias n 5 Avtorseys for tlaineizs 30 SIGRID £. MUCRLIY, 300. 1" WRT Gene, wa. Ti £.0. QUINFIY COLLIOL OT LAM AT TU CKTYIREITY OF CTT For PlaitLit® 1: ST PAUL G. ChESLL, SEQ. TE arm, Mos ANG a, BL attorneys for Jedendant PEAT: JUTRAN Gh. PROLTUCH, REO. a - a SUOTTAR WATRICT ATROATTRG, P.O. Pret reoaTen L 1 (Case calles) 7 Te ATE Like al) aT ys, yo eek Sp it tEe migdln 3 ef Ire migrh WiFi boul Weis casa. would Vive Lo see 10 11a clarify mp understanding. E Lz the moties to dismiss, | cozelided 1 thizk, that © wran war ah isin wan thn Reis or Taleity of ten plaieei®ei Po elleabivie vesvesiiny seaal sbose si bie aclivilice oo Lie : cefendant. 1 think that's my sence of my own opinish. 10 ielereerlion wlio. Tol Lie nessa, pertaps wroscly, Leal 1 lie plalitio's posilive vas Lal Loe delamelivs vas Liv Lith 12 or falziry of the sratemezts relatize to fhe defender. 13 baried. fm 1 corroalt n ME. MCCRMLEX: Yui are, your Honor, Ln that tie 17 statements abest the defendast — to br olear, because ene of 16 le allegalions ix 0 Go.rae, Sha was 4 widow and 4 Tr covospiralor wilt Tpleln to iteolve Tpeleit. 1 THI COLI: Listen. Leave tie pelorative wit. Okayt 1 vimana. » Mo. MeCHIETE Gre 2 Tau COLI sinply becaise 1m trying to come to 22 rips, sbvieisly, with the seepe of this sase, whie: is a real 73 nee, obeiouly. Sn ir ih yes are rerbeickitg voor dla to £1 tee brite ess celedly ui Lux sletemite aboot Maxwell? tH ME. MOCAMLAT: Yes, tat ds the case, your emer. The SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen : 1 ctelemecte abuit Marvell as ter sctiviliss, wilionl -elig ay 7 draeripeies of whan thar in, Wir yon, an wetve deneribed in ou 3 prentigs 1 THE COURT Ane wether or fet the PLalntifZ vas I aubdeot to sexsal abuse as a mizer 43 sot part of it. 1 mean, © wen, 6% mourn, whateeer she uns whee whakever, Bit ean drei Te dnl face Lu veal wilh : ME. MeCBMLSY: I'm sorry, your Foner. 1 thizk I lest 3 vel tmere. 1 apelogice iE 0 Le al Dagabians i Li conplaieL are Leal wher our IL Client came Curvare ai sat ste vas abies by lie celesent 12 ane apstein, the defdate came eur acd aid she was vite 13 abel Lal abuse, and coms 6° ral abuse di ean.r wean she wr 0a miner. 5 Tau COLE wes. Well, okay. Sit there are other Th Leige Lal she sels orld in Lhe Creer arkicles, iv Lie Tr moliun Lo itletcese, Lire ace o whole series of olier Linge 15 that are 1 mean, torre aze tilige that Lave been sal, ane 13 my readicg of tn dnfreianhis statomect ir, | read it te ray PE aI) Lease Lrivgr are Cala. Sl Lies ure sol al iui, dz ar 21 ae you're conceried. 2 Mi. BoGaMLEY! ¥e3, ver seer. In fast, tho emzibus 73 mokios we Sled Leday == and THiS, 07 1m Tollowicg vou £1 urectly, tile mey ely ve ves Liylag Lo elisenlioe Lie 27 case because there's ctier individzals, chvieualy, that my SUOTTAR WATRICT ATROATTRG, P.O. Pret 1 EE] 1 client mace statemeite aboot. 0 we vere Liglig to etzeamiiie he mae te the statements obec waver] at ber fmvolvemert 1 £6 45 the omnibus motion you'll see, Zor example, tat I tay have claimed air’ made Statomests AbeIt Cticr al dese are Lis slalemeils : TES COUIT Tat may be an decte of crecibility, Tat 1 ME. MCELST: Tes. Ri Leal de Lie statements List 17 mmol) made shor my elicce. n ME, MOCBMLEY: Yes, your Serck. 5 fru GOLA Let me ack the defense. Joes that olarify ww MO. MINETRGIR: Coole T hace vie secon, gu.t user? 1 TED CONE: fare. OF cuizee 1” We WAKING: oir Soman, | ERE ERG STigeTy morn 20 alse, ur client's statement ie net Jit Limited to the 22 lend snippees that they dnslided i their seaplaize, d's the £1 Shusize's allevetivae palit Me, Hemel neve Less proies 3 wmtrse. SOUWERR WITTER STPONRS, P.O. reoaTen : 1 THD COURT: Yee, Bul Lie statement vesi'l Linites to © treme alleganioes 3 Mo. WERTHGR: Plt eoelly righ, vor Cover, 1 because Hight in the misle of that particular statemest, the Teme that's av fssue dn thls ease, eur oliezt said, "ew her © story mar grows aed reelund, asd shatn i=slued alleganise To sbul verde leadszs ane Blan Decstovile, which be denies.t fe 2 can't just take that part oat of her statement, that's viat ER A iE Bog pace Torars weal we WiLL Cl Linelaly be reariog IL Crem Me. Marvell sbuol wal sie belieoed wee Lie ubeivie Live 12 har she was refereize to and the allegariens that ste was 13 retareivg ko wes sen fess Lal slabowesl n TES COURTH ow, vie wien gestion, ane tien we'll 13 get to the business of the day. | apologize for this 6 divarsions 1 Tel me ask yoo bolt. S.ppuse Lie plaisliil proces 15 that sie ves sexially abuses aie that Ger story ie 13 siberashially bein hin she don “of prove Kea rela than Hasesl] PE rae Toss wre win? a MEL MAINGEA bo, he loses, JORr Rencx. 2 ms GovEr © thizk she wins, a WoL WEEKTRGAS Veur Tovar, tea vary Sieh -= a THT COURT Otter than wnat jui've Juel sade tH ME. MMRANGEA Your semer, car client an caly be SUOTTAN WATRICT ATROATTRG, P.O. Pret reoaTen : 1 alleges to have delemes sumuis based ui Zacte ol ophiiuie. 7 Ten er agreed. aves 5 Mi. WEKTECR: Red ne se can == Lhe Tavis v. Secrain 4 vase ds a perfect example of iat, jour senor. She can Gily I speak to facts about whlch she Sas persesal kuowledge. 12 © PIRETRISE fons and proves Keak plASeRiSS week ad Rad mee wits Po Geesey Tpsleic sb sume puicl in Lime ai une chisel vesn'L © there, oir client's statement abost that wesld be opines, it 3 would veh be a Tach bared on persasal krevladge 1 TCHR T meat, obey. ToL Lalls af ize of 1 heordesge. Tells o siioeset i” he Wane von Fiat said == iE A COURT halle 8 AE Taeel n ME. MEKKINGER: Tae Ajbetietical ves 13 wir clieat 17 wasn't dvelved. If eur oliest wasn't dvelved tien it veld 16 bean opinion 1 TOI COURT: Thanks cory woh. I'm pled for Luis 15 clarity, widen frankly, at the moment, allices me. 1 kav, Tents mewn ae. var, 1011 Fear Trew ten mova » MEL MOSRRISTE Trath po, oor Totor. 2 The iret créer of buses: ve's like to address, if 22 it's okay with tho ceur, ds esr filine, wideh was G31, whieh 73 ir our omeibus mokion it limita. ed iT in okay with bea £1 Cust, we've split Liab ope Bil. T'm gulag Lo stert vite 27 reapest to that metic: in Limize. SUOTTAR WATRICT ATROATTRG, P.O. Pret reoaTen : 1 Rel ve atlempted Lo do wit vs metic do Linioe ves 7 streamlice ve erial. wed your cover, based 0 the cowastrs 3 veotee forl made, 17 yoo wink Lo Give we Goidees, TH Lal 1 yes eat I'm thizking with Zespect to thls and what we pit I orth in cur filisg. z SE KERR AER tatemeeRs Heat avn AREriRCESS be my Po elisl dn bliss sibicles ais Lidive. Tor sample, Lice ace statements abst Sill Cliztor being en the deland, and the 3 dntene wake ko bring i0 Kore statemobs be shou tah —- they 10 believe Lia car aver weideron Lal be wesetl or Loe fxland we 1 liesesvse, my Glial des Lies or de dying sbuel Lieb. 1” bow, por snmor wil) remember, hack i June we sous TT ho dapari Him beens ve wees comeareed abl Lal at, La 11 they vere pelig to fader A, aie ve Waites to nave Lim sioer JER 1" TCHR: Telts buck pa liLLle bil. 1 MEL MCHLIT: Doce 1 THE COUST: What and where vas the statement mace! 1: MeL MELA HA Srakemnst wan mage in a Mares Se 20 arlicle. Ge vel Le eo arlicler we sowed vo. yeslerday —- 2 Ths COUNT The Gmireber article, 2 Mi. BoGaLY: ¥es. sit dv vas asether article that 23 cam ost in Mares of F211 a Ba Lie elatement vee vile seepeet Lo ay cleat ceyisg 27 she sav him on spatein's island. She vas introduced to him SUOTTAR WATRICT ATROATTRG, P.O. Pret reoaTen ¥ 1 theme. Rlliogh so sllevativie uf Lzaiilokiig or esjlilig os © tran mami, Gust tran she wns tere. sed they ave anekitg te Bre ee Wag Toit TOR, SIL ARE VR 4 moment, they've proposes, ane he's clearly an expert that vas I undisclosed, and through a sole record, asd threigh the © armimiee ta allege teat te wnsetn on ten island ¥ Rit su dt yune Tenue's weer in 261 1, wiih de oie uo the sealed oxcers, you cid set allow te to depose him becaser 3 vel said in war ferelevah iE So etre to i+ 4 poxilion were al rial Liey wacl Lo 1 pel curls Lieb biiommelivi epeliel my vlivel, eT sui'l have 12 an umder-oath statement from that izéividzal sayite wetter or TE mel he ea was n Fou, eat ue kaow de he Slew vith Jeiizey Spetein at 17 the same time 1 different times intermatiesally asd 16 ubionally, bul we sontL hues Sim wilh respec Lo Li Tr perlicolar allegalivs eer vali, Zo ve vole sey iL vo.lé be 12 higaly prejudicial Zor tiem to be able lntrecice evicence 13 mavicn than be wastin thar or than they baw com proat ar 20 owe epark suyivg ve wash Lmre wre, D0 wl, ve were 21 able to ask him directly, the perch vio is at issue, wider 22 eat, whether or not he £46, in fact, on there. a So an 07 en shenanl iting 0 this Gare i tan £1 ellegativn cee sulideg Lo co vile coal sbicw, AL coeen't Gove 3 te do with the statements SUOTTAN WATRICT ATROATTRG, P.O. Pret reoaTen : 1 THD COURT IU hes tu we with crecibility. 7 Me weer WRN, pen omer, | esis ap, 87 3 peste Petites Lo LHS RAL Leal ba —= 1 155 Coram Well, look. I'm to geniii. 1 don't claim I any == bat ges know, that is precisely what the defonsc is © eine te av ¥ MEL MGCRMLIY: Rigel. 1 .overslesd, gues Teer. Ras that's why ve soit to depose him becasse it's inherently iE TCHR: Okay. So yo. would zay T made a wislabe. 1n ME. MGCBILIY: Fu, gue Teor. 1 Lidik AU shonds be 12 rxelueed, ane in my vie, | RRATR Apts ser rolevact tn rhe TI Emma al Leia] bara. SL Kay ara, 67 sours, goisn Lo are 11 Bhat At fe ans that tiey vast to bring that fn. Ia Zest, Like 12 4 sad, they've gov lined up wr. — 1" TCUERN Wall, on Lr ciarbion of credibilily, why Tr dent AL relecerl? 1 ME. MCCRNLSY: Because the statemeit so thle case 13 in abeir wekior or cof rn war socially abired and PE bea ieked 2 Ths COUNTS Now, That'z where © started ent. la it 22 ahese thati 12 thar is your pesities, that's semetiizg ele. 23 NT ie a mishion abouk Sor sevial obure, io addikios to, Hens 41 that's cometiliy eles. Bib jus Just celu It Len’ ebuit thet, 37 at's Fist abest Marvell asd 616 she tell the trath abot SUOTTAR WATRICT ATROATTRG, P.O. Prep 1 reoaTen 1 Maxwell. 7 WEN, ppenn, | suppers — | Raves tn ard wen 3 olen ide and T Mase k really ie gh iL all ou == bk T 1 axppese 12 she de GRUEItifil dn other instances, that may be I relevast to er credibility. z ML MeL WRT], pir neon, $F SEARLE ER Unirnls Po puedbive, again, ve vues be bios vicvomelence Tames, there's a vonple reasons why the evidence iteels that they vast 3 to pit Tork donseti come i iE TCHR: Mall, Leas a di Cererl Live 1n ME. MCCRRLSY: Cute. Taal's parl uo viz molivie ss 12 ell, voir seer. iE ACHAT Aura. Tread eal. 1 edeeslass Anal n ME. MCCRMLEX: Fight. So uh bie seme ote, live 13 we're talkizg about this, '11 dust tick eff the few that Zall To wiliin Lilie crlegory, 10 vou dontl wird. T Ledarslend, voor Tr Totes position, zo = 755 cota Well, I'm tet sire what my position ds 1 rine ew » MOL MOCHISTS Okay. Go wile respect Lo —- Liarals 21 another category where there's been statement: were my client 22 sade that she was trafficked to foreien presidests and world 73 Newdors Kral Leap wah bo brite inke cvidates. Bed is order be 1 streamline tie vase, we've cele, vell, tosze's suse of toes 27 people on the witiess list, and just statements in an article SUOTTAN WATRICT ATROATTRG, P.O. Prep u reoaTen 1 05 thal nature shuslei’l be able to cums dn. Secaies wien ve © talk aber a carasner frie, Rants an imme Sere in 3 repulation, and repulakion le show Le Lele lla of Lal 4 voids net be able to be proven 1h that elreimetance becaiee we I don't have the ether indivicsals there vo make that Statement, © rn tenrets a sibstatnive evidean on tear peien teat usild be Po coming in : £5 the third category ie vith respect to 3 Me. Cwershedite, whe in or Ke doTadanhts wits ish Sar 1 betel, wt ve ave a Ten peice Lure Lo raion, Tween one i IL Gbedueely Lieb do Lisl vere alloves Lo come bo, Lael vances Lie 12 trial eo hoceme a mii trial abese wEerter or Te te, for VE Sr U5 AR SA J Jota VE thy FUR 11 calencars, nde creelt vars recelpts, fle belepiuie recores, all 13 ofthat. it gets inte the lssue, you know, ebvicuely we have 16 arelier wileens who save Lal Liey were i+ a similar Tr ciecomslance wilh respect Lo fim Zo IL Lakes Lie Lelel avey 15 crow voetier or sot tor allepaticis relating to Maxell are 13 tein ar fale ad wires ih inte a trial shai asertor PE irsieinal wre ve have ol mise 4 Glain againil. wo comes i+ a Tiere’: alec a problem with Zeapect to that becazie Ge 22 4s alse = ke faz slained arterzeviolicst privileee as te his 23 eorversabinns avd Hin advice with repack te ekeis wine 41 relates to tie fesse wits Maxwell, fo Lo olier worse, ce 27 weald be able to testiZy wat he says he didn't do, but then SUOTTAR WATRICT ATROATTRG, P.O. Pept 2 reoaTen 1 any qisstiuse ve veiled to ack Gin sbu.t Speteds of Maxwell be 7 mays Bets on as ansermey/slics privilese. dn entre Saséericd 3 bocuse we cnt ark boul La danas Lal wa saad Le ask bol 1 wits respect to that witiess. fo in my view, t's Gigily I prejudicial te have him as a witness at trial wien, again, our © elaine are on agniten Him, aed wn Sawn tere fmien ¥ ow, gu de have ii yes Tebiosey fi ides, gon ¢ also precluded ve from asking questicne that ve contended vere 3 monet mesdwent, miestions of doTTray Sprain boi, 10 Tersrovile, Folding ial Lioe vers “ol relevasl. Go welre in 1s silialivn where ve Seve siolier wiliess lial ve ate ful able 12 te clinit all of the iformatien we ted to he able th prove TI hea Lr ae Taleily oF Luk, avd again, iL weld be sbeebs 11 a momber of mcd trials ei tat laste of Mr. Derefouitz, 5 0 with respect to these threr categories — azd it 16 also allows Liem Lo se re allorsazialienl privilege as Ti vers ane a shield in Lie widsl ole Lelal, wich is istererlly 12 safadr te ny client, ss well 1: Gp i oir wine, inte RigHly prejudicial oder 403. 20 Troe gro.pitce sre. ol come i+. Th ara.ld vol. be abo.l, 21 zor example, Clinton ané whether ox fet he va: en an dalané, or 22 Me. aershoeitz or thrse ster world leaders, dt shesld he abut 23 kee doTedanh and bar rhatomeehe Keak me olin we Tyiv wos 1 ene clabmed Lo be slices ane Lrasiickes Ln tives slatemsste. tH Tan COLI Just a second. SUOTTAN WATRICT ATROATTRG, P.O. Pret 1 reoaTen 1 ME. MCCRRLEY: fuze. 7 Toe GUE WEAR ye Sunk sid, aetld ve repeat shar 1 ME. MCCRNLEY: Yes. fo the statements that I me. Mawecll denied wore statomests that my clicst made that © Anfreiach ad pstein teatTisked Ser, Breiner in, Rad ter © pmebivipale do Lie seid dbose bo bed and olie: semeles, sie © was dn that cireumstance, she lived that circumstance for a 3 poried of Lime, avd ro Miveell came uh avd erlled we alieoh @ IT Mian, mab me was 1yicg abol Lose slalewesly Lial sre mice, IL an esi Liab, Gbriveely, es yon hior, Lo Lie dotesialiviel 12 press ahost mg elicst ad whan fer exporicen was with tiem. 1” So wile paspost Lo Leal, yor Teter, Lira arn Lee 11 categories that ve believe veils Gelp stzeamliie tie vase, ait 17 again, that these witnesses wesld be highly prejudicial, 1" De Le aa of Lie ieTormalion Lil Lrey's like Lo Tr pol dn wile tespect Lo Me, Clislus, Liey fave Tobe Treet wo 15 they've fcentifies. Tele de a Sommer T31 sirector. 1: I » Mo. MGCIRIAY: Tou brow, yer. Go Lreyive pol sim in 20 withest caving ve a dle 29 CXpEXt Zeport, ne vas never 22 disslesed durize the tine pried. sis Depart or what he's 41 TOR recpunes at biel tusre's te evloence dn fe vee taal 20 clinton vas on this dslasd, again, eves though he flew SUOTTAR WATRICT ATROATTRG, P.O. Pret 1 reoaTen 1 regadesly wlte Me, Spelels Lo olie: places. 7 én agaiv, wn £367 Gen wo Aepeen Him as an seperti 3 Win miller. Ba digetk bow Leal be vi going Le be ail led as 4 an expert. Tey're sayin he's a lay Gpinich becaiee Gels & I private investigator, your seser. The case law says othoreisn. © ntr bee meeniTied ar ae evperk = tenes evack Kise nf mate To Fe pl Lise do vee biden Su gues Tunes, be de seelly @ vols an sheep's clothing, Teey're trying to pat him on as a lay 3 opivion wher ats really a eport witeass in Sin ane with 10 sot ticierl ae soprizlicalus broulucce, Leal Lie Joey will 11 recopnics tim es sumeuie wo Ses saperlise Ln Lids ates su, 12 wer senor, we helicvn to sheild be prolided from testi fine. 13 Fe van we persoal beevladge, iL siwply Mi relies, an ee 11 cncerstans It, on tes wie TOIR respuiie letter. 5 £6 your once, with FEIpeSt to the s0le response 16 leben Lables ul ise Luk Ley are goitg Lo Lev Lo gel. isle Ti ecitence, we've pol lurlh in oo papers, again, Lil's « 15 Learesy cosment. It's Lighly prelieicial wicer Ai. Teey say 13 tran in meats sl Teasttashisaios, hon o1ike tn deme 20 ral we avoves, Tor eiawpls Lie 302 Leal ave Lee seal on ily 20 at tas nome of these graliZivaticni. 2 Taey mite to ten cases, the Lumara sas asd the Gary 23 mare. fete aT Wore imvelve Gobhic ithe avideean sdorlyivg 41 revorse that vere provices by Lie goverment, sol a TOI 27 letter. fo what they're trying to predics is a letter that SUOTTAN WATRICT ATROATTRG, P.O. Prep 1 reoaTen 1 cays vv Looked ai ve van'l hic lisse Zevurde Liab guitve 3 Kou, 1. does th addren: Lee Tach Lal LR Govromert 1 only typleally retalus recorés Zor a few years wien tiey vere 3 reemesting records from LT years age, so it deran't have the © imdinia nf mristeertsicees te be able te sav teat thin in To avleally Lie sacl bevaces, bo vu.tse, gs we hive, Lie : goversmest regularly has to get zis of recorde. s 50 ko ire Kin akLAR ke ray, THRsRa, ewan -ouor on 10 Lee ixlan, wer we fever gol Lo wsamive Him dar eal an 1 saps Yoo Leaveled wilh him biich, 3 yes also go Lu Lie 12 slang mv eliesr sav sho mer ge there.t Wn AiesE gor to TI ask teers snbios, se wales ina silliest wars Leal 11 Letter cuntey Lo voids be Ligily prelieieial becases tie Jury 13 will vender, well, what docs he have to say about tila And we 16 avesth bear ie poariLion Lo ba able Lo do Leal. 1 Zo got Totor, lot all Lise teasviz ve belies Lial 1: Mr. Tres: shesle be sxelices, the FOIA letter shoslc not come 13 inte nuidenon, avd agaic, we bnlinn that ben frie of PE We. linler 2re.bd ol be an ins. relevarl Lo Leis Leial 2 vet, your senor, they alee seek to include 22 statements, hearsay statrmests and noespaper arisles abet 73 riven Andrew, and ike ackually sok ir desinl, ar 1 £1 eseselens Al, S.ckingien Pelece's seidal of Lis slleetivs os 23 my client. Sit again, brite andrew is Sot on the vitiess SUOTTAR WATRICT ATROATTRG, P.O. Prep HOUSE_OVERSIGHT_011318. IY reoaTen 1 Lhel, we're fol able bu cross skamice Gime sb vial Liey val to 7 én in imereduee triple hearsay of vickitetan valane sayity wear 3 Prive Adress said in i own arliels wilio.l La roparker 1 against my client witioot eur ability to cress sxamize him on 3 wan H ch pie pmo, Heeien tried be aris a 1iERIR Rin of Te sevecilune vey, T Liick Lal ills « vesbal acl vi beads oo © Prince Andrew, it doesn't mest tiat criteria, there's bess fo 3 statemeck by —- tharats bans co action by my aliot agaicoh 1 rim an alte ak dace Be Ln cane Tn agains Masel 11 1 elelemeite sgeiiel my vliel. i” To cae thar they aire actually, the mizewrnr sas, 13 cone prin Lem Thane Ty alks ah l ew yo. well ae 11 to call tie reporter, that that cuilen't come Lite eviceice 13 ant se, peur seier, for these reasens, ve believe that, again. To Lalts a disleaclion, ills Rignly prejudicial Lo alles ¢ Leiple Ti beersey cocomesl Like Lial Lo come i wiliol vie abilily Lo be 15 able to cross examiie thet incivicial, fo for tise reasuie, 13 vein camer, wn belicen than Ean ceils cen come in. » Tray also mae an urgmerl, Leal 0s somerow av 21 smvervening cause or that, yeu Know, it goes to the issue of 22 she sheuld be secking damages from prizer anérew, thines of 73 Keak saturn. ikon we keow, beanie your Teter revicend the 1 case Lav wilh respect to Lie comary locgment, wach liclilcial 37 is responsible for thelr eum defamatic, so it docsn't come SUOTTAR WATRICT ATROATTRG, P.O. Pret HOUSE_OVERSIGHT_011318. ww reoaTen 1 kite cunelterativs vielis she unde have sos ali people Zuz Sin, 70 eter people fer in, this mane in aber eel] and her 3 ceTmakion agaieel my lion, 1 fo agan, your soner, 43 you look at tack un I cfamation, it addresses that ddrestly, asd we believe that © tran semis son come inte cvidesan ¥ So gues Tuner, Luel's Lie deel vieik ve Lie omiibes motion that © vas aciressizg. I'm ot sure how you vest to 3 wake Bn, IT yo wath be have opposite aoinrel spedk on bree 10 inner cow an Las wove Lo Lie olrers, or i yo. wel x Lo 1 keep mocks Lions ALY i” Tm GET WRaRts ver preferenani iE Mi. MOCHIEYE TURE Keep moving Lira. ik would be 0 great. 5 Tas COLE iat 1" MSL WGCERITT: Mo beep wocivg iL Lives iL, 0 Lilt Ti ell eighl, se ve ver vel Litoogt argmesl and List fave Liew 1: scares dt 1: Te outs sen. » MEL MOSRRISTE Trath po, oor Totor. 2 ME. SCEULYZ: Your zener, This da Meredith fennltz Zor 22 eae plaintiff, rhc sexe areiele in the ewsibie movies i to 73 evelide taskimeny reTarerans Lo prior seval assaill. Tie in £1 en desis Lael Toepuke ui yeeleicey seletes Lo ssoties mobive 20 regarding the same, so 1'1L Keep it brie, SUOTTAR WATRICT ATROATTRG, P.O. Prep 1 reoaTen 1 Bol pies serial eseeidl, all uf wedi secires while © MeL GieTRen was a anilE, ints irvelevach te this astiet. in 3 dooneh coms ie Loder ACT. TL deasetl devolve daterdirk. TH 1 precates even meeting selencant. Aue these aseailte co not I make it mere or less probable that defondast dofamed © Me. uTEr, aed smitRer dees in nnd te prev or disprern ten Po ecendanl abused bez. : Tass are alow classic examples of evicesce that 3 sheild be evelided nder Aa 417. Fhe Rape Shield law Carbide 10 mvidarce Goronrning Lice Se relabes see irval ving 1 Me. Giiiize. Teds tole should be slziclly sniosced 17 pareimslanty heswice these events Sappered wRes soe war 14 and TI 1E veer s1A. Ride 17000 bare his avidenes 17 ie 6" Canes 11 to prove tat she sigages Ln any type GF sexual beisvier to 12 prove amy type of dispesities, 1" Th arab alo bo acaba der Ale AGT. Tria in Ti edleemely pred viciel, ard beca.se iL ds ecelecail, IL vole 12 only sncwirae tie Jhry te view Me. Gliiire, a marzies mother 13 in har Bie ar as mmeral pares or Ravicg revial costast. wit PE ieaiials an eile 2 Fads should aleo be excluded wider ©03(al, which 22 limits izteraction of cvidezer for spesifin fnstazens of 23 eordunh in ardor ko aback the vikeers! araraakar Tor 1 tmtiiidieee. Few 1 epoke sbuil bide at leigl yeetessey. 27 defendant tries to offer two particalar things to say that, sh, SUOTTAR WATRICT ATROATTRG, P.O. Pret IB reoaTen 1 ete west Lrathiol shui sumetilig, sbuil belig sekeally © mmmanited, Win tee deminer teemselues deseribe sometsicg Bul en ieecal ly se al ans ll der Toric Li, 1 eometitn that de snegiivecally seicenseneial. £0 that veils I homestly be asetior mind trial asd would take us far afield of © wran Sante ave relevath te this ane ¥ Su avain, any miive pevbalive ralie Lia's past © sexial aseazlt tiat Me, Giuffre experienced as a child de 3 complataly melloved by tha prejudicial a7 oo the Jury. iE WAL CRSSTER: Taur Perar, Trish Tie Lie veal ove op. IL Tor pespuess un clerdly, else op Lu pedal Sober ds ve 17 mihi monies. iE Mei ae 1 ARieE Be Jurk a very simple ane 11 ctratgitioruare oie. We move to exclice ceregatory sewial 17 characterizaticns, This 4 a case that yur sezcr has bees 16 Cramivg Leia mertivg. Th doosntl req.ire ao of 4 Larw “rom Ti eles counsel, lor example, Gesceibing oor clisil ese 15 prostitute or as a slit. We tioight we veils get agreement 13 whan wn rm tn ronpenr ive papers from bee Anthenn, Bik an ve. 28 brow, Leap oblecles in Lis arlirely Lo Liis molios, xo ualre 21 here asking that defense counsel it refer to our client as a 22 peestitite, zet refcr te her ar a slut, az they alan advise 23 Keir wikensees Weak mes lasgiage wodld bo apprepriaks it a £1 essed Lziel seeliog wile o seisnetivn decir tH 9: this particilar peist aboot prostitute, it's SUOTTAN WATRICT ATROATTRG, P.O. Pret reoaTen 4 1 dnlesesting, Bm I ous)oilog dp sometiloy Lial's sol guig to 7 mappeti be, ymin comer. Tee dnfhedanels me cpert reper BURY AN, WT St a 1 advieement the expert report from Or. Saplin, asd eo 1 cepused I or. saplin, and 1 said, “Are yeu Sur TT's an aSeirate term © in ten Anhesn of tein mneni amemien wn have an anilE wee TP Gannel cunsenl Lu sexed acliviliss.” Bid he backed vio © immediately and agresd that that vas an inaccurate term for Lim 3 to un ke describe wy alien, We GESTTRRL Ge ses the 1 daranent oun spar weps Lie bar proskilolet ix 1 Sseppropziste. 1” Tour motor Raz autierity, of soirse, under axle S11 te 13 manage Lee Leial, Le avoid Ld. Sarasrmel. or csbarrasemcel 11 Blew Tale 40% allove gui te restrict tilige tat veils be 17 substactially prejudicial with ne probative value, which is 16 coach wal we rave bere Go we would ask vo. simply Lo rigs Tie erogaloty lesiae, bolt Crom viliesses and oppose 1 commas. 1: Me SEU weir camer, 1111 ba addraerig hn Seen 20 several poitle iv Lr oweibus wolio, slarkivg vile uber § 201 think © oan narrew this dave a Little bit at the eutéet. 2 Wr. Gizffee cozoedes bere that illceal er 73 erpreseriphics we of drign furitg Kee years Keak se wan wits 1 ceencant de acmlcelble. Hoveisz, any svicence pertalilig to 37 any nee of drugs, illegal ox set, acd alecel from acy pericds SUOTTAN WATRICT ATROATTRG, P.O. Pept a reoaTen 1 becure ur ater Me, Ghiiize vas abiese by eeieivect de © irrmlevatr to this astine amd sheild be exeluded oder wn 3 oan 1 Tt te alee, of cures, highly predicicial ass sheild I be exelided under ile 453, whether er net Mi. Gluffre coer © nnd Brine wile son being shied hy Anfeedans dons “oh 6 to ey lain or deosiees dn Lids vase. : Goirts in the fusthers Dletrict of bew Yerk restizely 3 evalude evideran oF prior dri ie eder bets of Kore miles, TE an lly brieted Be Lie papers. Telescasl allewpls Lo acmil IL lide welieice on presciiplive ses ee seleled Lo seneces, 12 pesifioally whether or sot thn emerietal distress We. ETT VE Arta 1 oven n THE COURTY Buc wey co yeu have At Ln Jour expert's 12 reper: 1" MSL SCTE Rell, oor esperk in -- Thm anmicg Ti gootee relecrizg Lo Jr. Times, wo de a physician. Tels 1: mecical cocter. Ee took a Till 1: Wo Gua Warts 8 wala Ring abet in. Arn ue 20 gang Lo wilraree bre —— 2 MEL SCHULTZ bo, your seser. We're enly claiming 22 damaers with repent te the cwetinzal distress siffteee frem 23 kee doTamatien. Bed alre, takitg dri proaribed Sor varios £1 mented cealti lees de sol Lor came Lidag ac mmotiviel 37 distress. They're two Gifferest dasies. fo acy marginal SUOTTAR WATRICT ATROATTRG, P.O. Pret “seater ® 1 pisletive vein de uitveigons by toe prelicioe. Again thie de AE mp————————————— 1 seeks to sxelids any alleged criminal beter Srom comisg inte © this case. ase the seeral wider of svidesoc bar the © nhemduebion 0% thin evidnenn, TY coon. : Ba Ae Braid he svete Lim wily way winibed ietuey : ousla come into evidence de tiresgh file G5, bit that zile 0 ee ons Le ah Vg ol 0 rl n 0 Lie bow parties, gus Sore, Me. Ghiiize de Ui 7 J NUE Th SOC WR EF CH J WG SO nan Ir sz vids alleged act, wide me. Giiffre denies, dees 31 osu oa rie ils selon sow wok Go Us 1 testhiliess, specially a crime Like thls, vilch specifically Fe Lanesger, Teowbn beak Li Urge 0 widen $n wend Hl comael for defendant has pit forth an GIETPRORTEd argmest So thn we, GaSe lefe the mite crates heewise of allenic: £1 lest tie Caites States to gel avey Crum seiescest's abies. % sz moreover, the dommestary evidence in this case, SUA TITTY ARAN, Puc. reoaTen i 1 union Gee bess procives Ln slecovesy aie s.bmitles Lo lads © mirn, stews tan in was defedacn wie seen ber te teailace, BH ve TA SE Ara AS A, a 4 she gets there. So 43 thls LLepPOITES ArgumSt that celencant I left tho nnited states booaisc of come aesiaaties of a tp far Tin te be Belinved, thee than maken SnfRedash as amemsrery ATEAR Lie aul ans dmplivales Ges dn Lie vesysuiig. : fo 1 con't basically, there's just thie argument 3 in alee eden by Khe Then Kak Tatar, We GILTTRs comes Back 10 Lo Lee Criles Shales Lo live bere. Grete ol “lemicg IL acvieslivie, sie ves Cleelis seeicenl. Io she vere weicied 17 aber arimizal Mahility iz ren bmited sates, she wedles'r 13 come back Lo live rare n Sit tie Gierall pots le any marginal probative valis 17 from these allegaticns, wiih | don't thizk there is any, but TEL Car cashly oulseicted by Lie prejodice il vo.ls ase Ti Me. Gillre ane shoole be eacled cee all Lose roles. 1 Moning now to podst LO. Me. Gliiire has regiestes 13 tran tha Geirk avalide any avidnean regardicg rpcial 28 merooling, Leaver, av earile selivearcios. Tor Liix 21 argument, your senor, | request That L approach the bench aid 22 give ven a few domments upes whieh thtae areaweses are based. 23 1 rave Tour decks bat Dm Rasdivg up. a T cave to get & Little bit dite tie vescs ceze, co 27 please bear with me. In thls case, Ma. Gizffre — well, schecl SUOTTAN WATRICT ATROATTRG, P.O. Pept 2 reoaTen 1 records have bees perl ui clevussry, Toey show a Gletuzy u © rampart mriaey and failed emises. Ais eesnitites prise bad BE Ra Sr NYS, RPA HY 4 these bac acte co not ge to trithiilisss, so they're alic I exoluded wider wile ©34, H Wer sid alee be eeslided beawien their predadion Lieb db vende ves He. Giooce vemally uilveigie sip piobelive value and shezls be exelided wider 102, s Weanats a Fuge remetensen ine Sore, yeu Coror. 10 Mrmee Lriarcin ard Jovesile del isgoarcing Look place wey 11 gests ago wien ste ves @ miter. Taeze's & dol oo vase dew un 12 ein shar dn dn Mr. GIETfrots Brief on page 7 te 23. wir whan TI ve. shell be mers 67, your Tver, bn Lala closs aomisalion 11 un revere, Looklig Sp veal tie namber Guces oh tess 17 transcripts actially meas, it shows the sppesite of tic 6 argumerl Lal Gelerdark adanaes in ver response brie’ Lal. Ti eke ves it scioul, ane Lierelote, fol aboses by fer cliesl 1 To the contrary, the recorse sion that she vas not in 13 reread aver BalT tee time sha was suppered to be and 2id coh 20 complele ver co.rses. Tease Lew-seriphs are “ol 21 self explanatory, lideed, locking at the face of them, it 22 seems Like she vas corelled asd attending soheol, hut wish of 73 Kee iTormakios i Linea reascir are saber codes Led by the £1 Teln Seach Cusity Svicul Dlelziel, Tower svivol sevurse cools 27 sot be placed iste evidence for all the reasons above, but if SUOTTAR WATRICT ATROATTRG, P.O. Pret reoaTen * 1 gun are dncliies to do Liem jus coils sul place tiem dito © ewideman fairly witteun tesnimesy resardicg war all tees 3 coder 0 Ure Leamsariphs wean, or al & bare wisi, Le 1 introduction of evidence ane lretrictic that makes explicit I what all the ceded on the TrasesEipts meas. H wefemdann irene failed to dn For fun £1liGeman on Lie ane lovked al wial Lie codes aze bore adeaiving Lie argument, bit either vay, it's not a good Zaith argument 3 beanine, ar yor cer sea in ke dociment | arded op, these 10 codes and Lian weaniogs were dela led al, teehee IL Me. Ghiiires cppusilive Lo Lie molive Sur somecy cement, 12 a 1 wnild ask the Girt te refer te the fasts ar page 3 of 13 bee slatemel oF Tacks n So nat tie secures actually shor de rampant trisney, 13 years of ahsesce from ssheel while defendant was abusing her, 16 rien show ample opporloily Cor ube, avd are, it Cael, i Tr sccors wile Lie SLighL records, wi face alos beet prodices 15 dn tide case, widen place Me. Gliiize en 21 Sligite with 13 dafamdanr sheard dntirey dprkeiste private plan. » So ax Lhasa records acl ally sow Leaner, alles 21 grades, failure to complete coizess, These sheild be excluded 22 umter all the wiles © sited carlicr, or at a hare mizimm, 73 imkrichion Lo Khe Jury abou what Ke codes meas and dotailitg £1 cow many Gaye ui school Me. Shuiize actually allessss, a nomber 27 that is conspicuously absent from delesdast's bried. SUOTTAR WATRICT ATROATTRG, P.O. Prep “seater a fi Tuxadog sekt tu plalatizi's meties Gi Linice amber RE ET r————————————— 1 hiléteed, fnelitng chavacterizations of fer as a bad ciilé ur 3 a rmaeay. Jefcndant's pespesse to this trick te seaflate two Tune band, wilh a fepleliv Cur Lehi dines ul sculiee. : rior bad acte sie may have cummittsd as a ciild, Like FC OT IE SI NE os SO IB CORRE SU SS Hts the wily repitatien that's at Leste 43 thle case. 13 Defendant's defamatory statements damaged Me. Giiffre's Tr ot ne eis ol tes Shulinete: pererelions heusbec: 1 particilerly ee fem a trochles erlshons, Oneirrsnoes, sich 18 an rimming any rom vor Fen whee hn war a abil, am simply 2 shone also be sxelided séer ile 437 becaise vids is “2 inteesiorion of cviceien ta fry Te show fer chasietcr. and £0 repitetion cur beeisg e vnerectes Zur Leithiilises ox 7 smtesthfilsess, it doesn't come in sds thet male. SUA TITTY ARAN, B.C. reoaTen ® 1 Ser reputation Sur Lrithioliess Goss fb gu Lo acy bao 3 criminal comviclion: are qosarally Col admissible 10 pees 4 after the fact. fo presentation of thls type of evidence i: I simply nothing mere thai a smear campaign, whist is presoribed © by miIniple vednral wiles of awidnean, ¥ Su cially, any meciiiel probalive veloe on lisse bes © acts as a child ds vastly cutweigied by the indie prejudice it 3 would amie Me. GLTTre beter a fury. 1 Tour Toror, toe Thu Lorrie Lo pois “uber 17. Matus 1 sekett Lie Cott Lo exclote wokience zelalisg Lo Lie Lax 12 sempliaton of We. GH3FTrts SoteSor-profit wietime inti VE AUR RVR A Fi, ite ee WER HE Seo Be 11 emelicen. Tee alleges tax compliacce Gf Ler ot Sor presit 13 dots net go to vheticr or tet defendant defamed Me. Giuffre ad 16 doer col Go Lo wreliar or col dalardarl abet Wo GIL. 1 TL stonle also be eaclced iver A020 TU Gs higely 1: preficicial. It voile give the vrong impression to tie Jury 13 bean MeL GiiTTents organicakios in cen tax compliant, wrict, in PE ele ih is a Cel Leal ce’aedenl sess ol ackeowlesge in ur 21 bres, 22 Provize whether or ot Mi. Giuffre's aot-Sor-prefiv is 73 ka complinth wei leo ba a mith Leia] avd, Traskle, a 4 elumetor to tile vace. tH surthemere, all of deferdast's conelisiens ahost SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen % 1 Me. Giiiirels nob Sur presl ex complisice are bases ui an 7 eremne report hy Ror pUYPArERd eporn, at SNperr who sheild he 3 celine Crom LasliTying boci.sa Mis reporl. Lackad melbodol ony 1 and he opiies on topivs far afield Sxem his expertise. E #eoeé, asp allogatiens that her oot-Sor-prefit is net © tar memplinn is pressdinial, misleagiog, Aemfirieg te ton dur Po beveees dl hes Selig Lo so wile Lie claim al dees bi Lids s Vor Cover, wn asked Tor feTardatite bax relies in 10 Leis cares 10 Ley Go Lo Leo leens, ax Gelendarl arg en, 1 lhey ale go Lo deoengent's Leatioodiess: BL Lids puiil, we'ee 12 zor gaping to ger them smedl the Sire day of trial, se we will 13 mel be able Ls aTTackivaly eros samine dated on Liane Ln 11 retizia, ans ve won't be able to dee GitLL then 12 che’: pals 17 taxes on all the mosey and gifts asd in-kind payments from 16 Tprlein Leal shets received or bus bepl Lil away Crom Lie Ti govertmerl. Uilike Me. Giilte's Lex iiloemelion, velessarl's 15 tax dniemmetion goes te wir case dn cades ae de relevant WW Auth, ET 90 pith suber 13, ve mova Lo acl de euidares 21 relating to Ma. Gluifze's alleged tax compliance. Your senor 22 whis 42 a defamation asties whore reputaties is at issue. Tax 73 compliasae dens vk Go ko a repiakios, ih in a privabe mather. a fevors, there de fo svlvence do Lids vase tial any 37 goversmest, either Lnited fates or Anstralia, believes that SUOTTAR WATRICT ATROATTRG, P.O. Prep “seater ¥ 1 ste de sonomplisst vith Ger Lewes, Deividect's porpertes 7 expernts exaliaties of tein fn wrelly Saves, as explaieed i= 4 Similarly, Me. Gliffre's taxes are vielly srrelsvast © to this case. sven sevicas beet by the everest, soir [TT SA SS J Pp — T complicive acho evidence ue price Len ocumplicnes wis iL © takes the case too Zar afield of the este being trisd, LER SE RA ———— 3 tie matter ob sans, Sere seseset Sails Lo sir sy type ok 7 JRC SENG (OF: SIE NG WO J 11 thls des podst Heat's Li Glepite amg the parties, ai 13 resolving suet an fai veld also involve azetiey mini trial FE wtih be wot wi Ural win Leds Loe uk wise sve 0 more 1: inZumatio vietie: x Get Geleicet elms Me. Giiifre vie TWEE SR SER, Wh I sevelemest agresmet and the amesst between Me. Gliffre asd 2 uestrey speeds dnen cvicesan, £1 paymt ds tex exempt Gives tos Caites Bates deve but that's 3 all this ds, it's a device te try to get ax improper aimissics SUA TITTY ARAN, B.C. reoaTen * 1 0f a eeltlemect amooal betvest Meo Ghiiize at Jeiirey Spates. 7 memsrdizely, hin sheild be cownlenely evelided heawine acy 3 marginal probulive wile Lis bas or Lhe claim in gredly 4 citweigned by the prelicice to Me. Giuiize. E L am Sot up Zor the Sext ee, so I'm gods to take a © break. wack ve ¥ MR. CRECILL: Bpein, gues Suivi, I'm op Lo sabes 11 © ew the deste of Me. Gliffre's being a victim of domestic 3 wielaran. This in cen relevah or misimally relewash, Tht 10 Me. Gites birder, of Goose, Lo show Lie ewoliotal Sizlres: IL cemeges Lieb sie sooieies as a cwsndl un Me Mavell's 12 esamators statewesr, até the fury eat agree er disagree with 13 weatrar seats carried Fer burden 0 proo” n 15 ve Giseretenc Lie eSeicsit's argent Curzectly, 13 taey say well, this wesld have been a distressing event dn To vole lite und, Lrereore, we should be Trea Lo ithrod.ce iL it Tr Cres el Lie Jorg. 90 vooree, lial srgowesl vould allow, i 15 acveptes, seseitially any bas tilig that's Lappeses in ay 13 plaithi TT 10% te be ished $7 tear sack cmntional 20 disbress demiger beca.se, wy Goodress, riz sverl Mere or Lard 21 tad some encticnally Gletresiing effect on yen. fe it haz 22 mizimal to le probative valie, asd the pression is very 23 sabstastial a Yoox Boor, cbeluiclye cee & great teal of experience 27 asd are vell avare of the domestic viclesce, blame tie victim SUOTTAR WATRICT ATROATTRG, P.O. Pret i reoaTen 1 attilice taal Gee Lo be vonizunted Lo vazduie vases. 7 breeieerly, 17 herets fomestin winlemas thats an fame, an 3 cport wileans comes 10 Lo wplaic Lo Lh Jey, on, wy die 4 she leaves Way eid she stay with this fellow vio was beating I ter apr she was free to walk out of the relatienahip. Way © Rigen se de ni ane tear in a weeln Viteramien than | kee gees Tenor de semilise wilh se Lisl we viles in ves bade, as fo well. s We oth want te get ike tran i Trent eT be ary in 10 Leis parlicotar case. Tein ix a blame Lie cicLin Laclic Leal 1 shuldntU be alloves. This fas very mesgiiel, Lo any 12 probative valic and a very siemifisate predadinial eofoar 13 bomen Lee Jury wil] peleshial ly blame Le vickin Tor slayieg 1 wats cer abiedve spuise. 5 bow, in additinn, you'll zetice from the pleadizg that 16 re deemrhe arash itlerl Jul on askivg uarkions abo.l Tr Lele, bil Liey ale werd Lo go dil Lie vole ceimitel vase 15 apadnet Me. Gluiize's Gisbase, jus keer, Viethen he appeared or 13 wran tra Seles charger are and a wariney af tito. Ahan, JE ebuionaly, max ever less probulive wile Leas lve i= ormalion T 21 vas dlecuesing a moment age and shenld be independently 22 exnluded. a Wee ek nme op Bn ikem 15. Red Rare, we ark Le 1 cave encliced any eggeetivne tial cox wilh a 17 year ols de 27 permissible. voi will recall that there's debate abost exactly SUOTTAR WATRICT ATROATTRG, P.O. Prep “seater # 1 eel years ens viel birtidere vers in ploy ens sectly wal 4 yes vere, $n fact, 170 ox whatever iT de. We're set taping te © ewelude waa : er. Timited poieh thah unten bevieg tn adres ne in ¥ Lal they stliath sage "Bh Sahe shu ves Fhe Lbasminem. obe’s tale game. 3 vunsesting te seal scliviliss ui Lie sabie lial ste at dese n MEL SCHULTZ: Tarai te ftem Lo Li tie emcibis 12 merien. Ne: Giuffee has moved the Amt to exslide medial Tr sblesbiv bo delendent's cepuise: Deleasar bere does suk 1 cite a atigle case vere a coir silos scmbaston of Snrelates TE ET wR A a 2 records sxe selevat Gere, snd there are privacy desiss at 2 sake. in aor, defenéase dors mer mite to a risele sae in a Ii ceswiantls sitire tespuies she cites tuo vases 3 only. either of them have acythitg to do with wat docmets SUA TITTY ARAN, Puc. reoaTen * 1 might be semittec ab trial. Soli axe uzdsze sweoledig 7 diseeuery dispites smder wile OF 3 part, “row “ar magicrl recordin, weile dated, wa 1 abiaing ber, eich as when defendant tuck Ser to a hospital here 3 iz vow york wien she was only 17, and the payesclogical reeords Fo rmlated fe me. GiTTrn, wie avn bees prediend, eine Po dienlally sie eum 2011 and heme veosidanl as ber abuses, Gu other mecival recurde are relevant ad shesle be excluded under 3 Ae ann 1 Mel Gilre in seehicg damaes or ewolional dislress IL oom seeemetive, TU sues Sol open op Lie Slo gales Lu eresy 17 ritgle medical free she's ever Sad i er 1. Me. Gintire 13 ban present reords, sueeyis i Crom Leealmssl Tor a Carrel 11 bite to cetalle uf her giving Lista. Teese are net relevait, 17 ant we can ave a raling in advazee of trial that these things 6 rela be asl. 1 Telesarl unly seeks Lo se Lise records Lo conlose Lf the dssues belore tie Jury. Deleicact oifers to reason Zor 13 addrarrivg the relevanen of rid docaecte eee by on an tris, PE ame T LEAF Leese ca be salaly esc ed al Leis Tonelre a ME. MOCAMLAY: Your senex, ext i: mmber 17, which ve 22 addressed dz esr papers, as well, about the prier scrtlemest 73 agrecmsch. Veutve bard abest ih ie Weis cane, avd wn Fave 1 ale iat tial shuils sot come filo seloeice. tH I thick they'd like to wae it to propose that that SUOTTAN WATRICT ATROATTRG, P.O. Prep “a reoaTen 1 amit hes somelilng Lhe tie Jury shuodd voredusz, Touz 7 comer, he papers ser Sore very slearly thar shorats a 3 rpeciTie fla of evideres diredlly on pith wilh respect Lo 1 eettlemest agreements, ai they can't be Gees in that mauier. E T0Rr aor, we Cite To ON Paper: on THAT with reapoot © te amy prior ceptlemeen agreement being embed fete mide Tal ie Leial : Mi. CREEELLY 1 believe I Lave the next three. s Them 15 tren in dotamakion Vikigatien. fed your Cover 10 ix mmr Lal Lars wax 4 reparale lave il Lralls spot ol o IL like silistive where Cassell aie Sovards tiled a celemslivi 17 aerins in deride state cert asaitor ala ersteeitr. ala 13 arsrewile bre cocbarelaimed. Teal was 1ikigaked i= Tlerids 11 State Court for bust a gear. Ultimately, tie pasties settles 17 their differences in an vnddselosed financial ATFALEmGIts ad. 6 park of Lie comprebersive selllemel, Casall une Tours Tr Leer wilicrar sommes Jogmesl epaicel derstovile. 1 It was as expressly Gnceratoos wien tie parties agreed 13 per thir comTidenhin) rebklawect, thers war tn a shatemer PE ie wien iL sen wade Leal Ma. GE. rea” ows rar 21 allegations, ane the viticraval of the reference te the Zilings 22 gn mer fntexded ve he and skesld sot be aststried as heise an 73 mekeoslodguet. by Swsrds and Grerell rat the allagakions made 1 Ly Me. Ghiiize vere mictaken. tH Hiere was a portion of the statement that talked abot SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen = 1 "mistake", aig Lisl ves dnclvales bo lie plessiog viliczeviog © ten summary udomenn wetins ar Tolless: dwar ard cassel] 3 do uck-owlodge ral bre pblic Tis ie Le Crime Ticking 1 2igits Act case of the client's allegations agalzet Defendant I oorshowitz beoan a maior distractics from the merits of the © unliefmimdnd Grime Vintine signe ann nase by aninicg Gelay Psi ae a vensegieive, Lesies bel Lo be a Laclivel mistake.” © "Pactical mistake." “For that reaser Stvarde and Cassell Lave 3 cresen te witidrae the refereed Tiling an a codition at the [ERENT 1n Taal's allo very fnlezesting leveoile bul Lal's « 17 Maurin than ders ser Rae Me. GUTS ana party. It was 13 Caneall aed Swards vars. Blas Carseesile, wile claim cei 11 back ane forth. Cassell ane Tuvarce Were, oI ceizis, 17 vindicating their ow prefessional interests asd their 16 profesional repolalion rasposdivg Lo Lie ahlacks Leal hui bees Ti mee by Me. Jetshowile, and Liey ciose Lo sellle Lie cee, ax 1: cio Mr. Dershowitz, Zor vidselosss Sinancial reasons. 1: Sm alee, Trom ten fact | Ri-k your comer in cow JE mare, Lia Liere ware sows wilsexses who ware tol ai lable 20 sarah ancome ha: come forward in thle vase te zay that she wa: 22 a traffic to alan Jersheeits in the samc way That Me. GiuSfre 73 leans, and Leak war iTormakios Kak bas only reesily bocows 4 avallatle, tH Ae prdst is, you have sncugh business on your hands SUOTTAR WATRICT ATROATTRG, P.O. Prep “seater Be 1 wth getting Lite tie cetalle uf siuties sepssale lavsidt LE a A ———— 4 a5 det me make clear that 1 smpasize tie farroviess © ef ou movies Boxe. ve sock te preslide criceson dnvolvise © wean Tininanion. your caer tan sleeasy meard Sow my ¥ whldespun He. Heenbegs vie See peseabed wed siyomel dus hy : Sershovits shoild net be in tide case at all, ai of comes, if 5 we prevail on pein 1, thin point becomes irrelevant Ir Rl wT to pA Ts de ot 3 geltieg satu Loe seleks ui Lie svpriale Jecsidls TU aut FI fa, wh, well Mesh. Wey clen't Ma. Gluize Juli the Lawsuit ur 13 wip hasn't she filed a lawsuit against dershoviti; wiat's v etl, ui wctens pot Tomes ta. avsen bere ate 5 1: vanety oo statutes of Limitatics azine toe comfy, ss VE On HE We ESR Sen WR SR BE Fave sah 418 fn al Unk pie rere se ering I cusslderatics that ge inte iether x net emecte like 22 me. GHsEEre weld file a laessit, ase these dares SESlEZ'T be A pesticide Leveidt. % Moreover, defendant apparestly rpies iat statemests SUA TITTY ARAN, B.C. reoaTen 7 1 thal Soverie anc Cassell meoe in tile ulier Lavell are sumstos © binding on we. Gite. dwards and cassell bad separate legal 3 corel, Tlorign allorrey Tack Searole. Walaear wi Goi or 1 in that case fan't bizelsg on Me. Gliiire. E nzder the relovact rales, a3 AVIOEEET'S STACMGETE A © BitAins bm a Alien atly an marten wiESiS Ee scope nf He PT relelivsebip, Rit Lie vas ciidicelicg sepatale prossseivial © interests, this was net viidicatisg seme diterset of iE So Tar #11 Liane rescore, ve anh Lial Lie dal amalior IL Liligelive bebeees Decsiucils ai Sovasie ais Cassell be 12 rxelzed. 0f sours, vo Rave the separate amie ef ersten: 13 ie Teen eT yn alrendy n Let me tira tien to pelt saber 15. Bere agali, ve 17 have a narrow issue presented to your senor. We are asking Tal yo. eelide Tage Marrats alison Lia joitder molis. Tr Ee gour Teter ix well avare, Lie Leiggering ecesl it Lids case 1: vas wen Me. Ghizire, then kown as Jaze Joe bumber I, Zilsc a 13 moties te dic ama ten 1 ad dae wen 7 i= ta Clerics pre PE bare Crime Ficlime Sighs aelion 2 bow, Udge Marra denied that metic to Jedn, but at 22 whe same time to said, “rte reason I'm devine tho moties to 73 ein in ves ane prekicipale it kee ase i okRar wave wikiooh 1 being a Commel party Ze cited, ase T gots, "0: cores, Jase 37 dow @ can participate in thls litigated effort to vindicate the SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen id 1 rlgnte ui elmilesly edtistes victine” 7 Fee erm Tamla wie in 3 WRC CRSITIL: Okay. RiGhL. Go Lealte Tdge Marrats 1 ralize. E and you understand That was ehvicsaly on a teokzisal © dmiténe irri. Yen dnimier imie, weeteer than was a Tew Jeiiger meliv ur a bad melivi, bes selhisg Lu du wilh © uiether or net Ma. Gluffre vas celamed. s FECHA Cow do vo! propose te FerAl Le Jeisder 1 mokien weiceskially? 1n MRL CHESSLL: Rigel. Fe Lidek Lie Jules molive 12 shesle simply some iste cvidesan as the pleadicg te wins TE Me GETTee Tw serey —- He Maal] ws repent n THE COURTY Luck, stuck, ais barrel? 5 Mi, Gelb fe ve ave chvicusly vaitizg for guidaso 16 Crom your Teter. Tor acmple, §° vo. mv. look, Tersrowils, Tr lela Joel nel gel slo Lal, Lial's 1 THI COUET: That SASK'T anever my Giesticn. Please 1: Ma Cade 1 apelenica. ET TU CUCRT: Vou Lalb bool mary rials, many 21 argumeite. Yeu vant to PAT in the entize motions 2 Mi. Gmffsbt ana, uEless yedr seier == 1 wazt to he a Tes. Hovever, dr gui cays look, Dezstewite lea't 37 coming iste this case, there are some allegaticns about SUOTTAR WATRICT ATROATTRG, P.O. Prep “seater ® 1 Serebunits thet ve wicks ties believe, du LGR ui goss Killige BT 4 THE COUT Bit gut dent have an eeited versie uf 3 ti dztervesties moties that yo wenlé Like me to consider. : We. As wn west prepa. mn, sen ve gk, rn tT tum gues Tunes uh Lie molieie is Linise. : TS GOUITH 57 the vay, fet parestistically, folk, 10 ie Kia Bl Ayr ol EE Tae Dy la Te 1 wpieestin ay views vi Twill 1 bees seve sag wipes oy view 12 or those fms, Wi the trial may ta in a £Sforese n ME CRESSMLY We ineretand. Rad ube of tee Zeaseis 13 we have tet prepesed a redacted doinder meticn, that shoved wp Tt seenly wilh a pesibie wills: Te Uo Uw beak veg bo 1: process, as vere happy to Get iicance from ju Sunor, bit we're sitting today, the Jodsder netics gees In 45 Ate © emeimeen. £1 legal plessiig, Ges, T vesces vest Geppeoec, Jisgs Herke mace 3 a rlizg, ve don't seed te get dite the details of that ralizg. SUA TITTY ARAN, B.C. ke reoaTen 100 vunzes, we voids veil Lo kplals Lisl Lise wens dios © separate veazos why these allegations were imelided. dn 3 Mares rserrad Lo Lhe Tiel of Lhe cise resets. Be ee igh, 4 otier aciiticnal reascie wy those were included. It weild I cssextially, acait. be a mini trial abest, well, what docs a © dpinene mori measi HA ver Tila ueder wile 130 In sEesls have been aver Rode Zl. Maal did Lie Jive wo? : It hae no bearing at all on the desves in the case, 3 and i, oT emiere, Ran wary mbskabia] prelidieinl ote, 10 bucaize iL Tests Lo a corlzion of Lie Try. Tre Joryts Legit 1 Lo sigese wl, well, veel's gulag vi dn Lie Coime Ficlime 17 digtne ant ease whe rhe daman in weerier or ter Me. GintTre LER n ow, biere de an desi Ln tiedr plesclive. Tied say, 12 well, this could end up being relevast because there might be 6 owe bid of uw privilesed sellivg ize. Reait, TLeiok your Tr Toro correctly wes puitlisg ool a mowed ago, il Liisge stor 15 ap dn the trial, it's possible that sumetiing ceils ceange, but 13 en dastr akinipate thar hesomicg as freie in En trial an rei 20 painh. 1 Ure baie of wealrer Lei was a privileges seblivg 21 semetow become: an Leste in the case, then it veld be time to 22 revisit thar dsrize the trial, a T= any aveek, innien aT whaler bein was a priviloged £1 estiing vr set erent litigated do Szuit of Lie Jury, test's o 37 legal issue Zor your senor to determine wether the setting vas SUOTTAR WATRICT ATROATTRG, P.O. Prep n reoaTen Lures sl pelelleges, Fe sul ake Jiiy evidence un Lael, © wes kee, dae Marrats mili, and therefore, tan seild be 3 orale. Ge ral in ihm Lebar 13. 1 Let me tirs then te item 20, ase I'm Gaseling that. I ids de cesestially a hearsay cNeIoisc. We wast informatics te © be remluied regarding chenan evan. Avi asmiee arbres © Suples hes sel bees vepuses css de sol vuics Lo be o viliess dn tthe case. s fin we srdorstand wan We doTasdant ie plaseivg te do, 10 arate planing Lo call Meo Jersouilo We. Jersrosils ix coin IL Lo say Me Suglen Lod him Gaal Me. Gioiize Lulé fim somelbiig, 12 ace sn en Rave the marin Eearsay within a Searsay svarion. 13 Meo prablon, oF course, ix Leal Seylas in vel. bers n Tie cezeisant's pleaclive cay, ah hab, but thle de an 17 admizaien by Me. Giaffre, asd it veald be 4f Me. sevlan vere on 16 le shard so we could xk For queslions abosl, well, did Ti Me. Gillre teally sey lial? Rou wrel wid she meer? Boo 15 wasn't sie sayiip thst she's been abuses by Me. Maeell! Sit 13 teey wath fo kip over than istormediatn friTT, ave ersieeins 20 wescriba wnal Topla describes Meo GI ra sais, ave Liable 20 ebviezaly and then I'M assuming Jershouitz 1: gedig to pit 22 his spin en what Mr. sevlan alleendly sad to him. There are 23 a sek of aivemekasac © wRiah beak Fearsay wikis Searsay £1 ids Le scmieeible Lecenes Me. Suplen ses nol bess sepossss 37 and 4s met here, it's rask miltiple hearsay. SUOTTAR WATRICT ATROATTRG, P.O. Prep 2 reoaTen 1 Tam abut done al Lads polit. 7 Wire regard te thn vemai=ieg insies, yest] be Cappy 3 Le ear Lak Trinh Liege can bo sped cp. Ba bal ev Ll 1 these tases soile simply be, as josz Rencre 1 thick vas I suggestisg a memcst age, deferred te trial. H Vem 1, 20 Phy Py Re TR PT 20, and Th, tonne wre swrl bn Jusl kad oo proleclice messes. Tow ue : Zuotnote or caveat ve vould acd to that, yeir Homer. We thizk 3 tein gets puted te the Leial, bah we weld siaply ask vein 1 Taran Le diredl delenee cecal batons Lie fel Low cil oil of IL lie beg un any on Loess lial Liwte be o sitebar or bestiie 12 urside of the fury Sur an thar, ve: kee, oir metic is TE Timine Apel becows wosl. beta Leeytue 8 esady 6" Teale y 11 pit At a Treat of tee Jury. 5 Tie ene that's of particslar concern 4s alleged had 16 aks by Lie detense Loam. BL various poicle, Tinh your Ti Toror, cietlotalely, tes sees some, jo. heow, ltackly 1: ageressive lagiage cirectes to the plalitizz's team cere by 13 thn Enfeere foam. Untre proparnd te repent oat ate ownry 20 ave of Lrose allegalions. Batve Leis ol Lo Gel i-lo La back 21 and forth because we thizk it'z irrelevast. 2 sur 42 there was to be some kind of az avtask lauehed 23 on any of Kea mombars 07 Kea Aeber sanillar Tim, of rad £1 Suwarce, myeels, ve voile ack lial ve be chien leave lo scree 37 that at sidebar, in-camera, or eutaide the preseice of the Jury SUOTTAR WATRICT ATROATTRG, P.O. Prep 2 reoaTen Leu thal ve ven beep Lie cect biel be have Sie sumelidig bed 7 whan sheds hes he BRlE agaiean oir alien aeny from the Suey 3 Bk all Wrase remiiing Wing ve re io agroomel, 1 4 think with the sigeestich Jui vere perhaps making 4 moment ago, I we cas deal with these issues at trial. H Aarts ie omsibin mokiss i= limise, your sor ¥ THD COURT: Teath yu. : ME. MEKNINGER: The emcdbie metic: reads like a list 3 of cunryEhing plaiLiTT ban Tin aboct or asyiiing that veild 1 Lrdareil rer claim Cor dames 1n Plediliss gooled Paseim Li ter teply Liles com = 12 parimslar federal evidenon trearise, até | weild like to tell 13 bee mark, se 10h aul Le worl, importasl parks, and Leal ix 11 tie vies tat relate te A0iibi. 5 43 that treatise reads, "Character is az elemezt of a 16 detesse ina ceTumilion cane 17 lve deeding parky elaine Lal Tr Lie slalemesls in goeslive ace Lice en seeks Lo prove Lial Lie 15 pladntizs as the character scribes to hex or to zesice 13 damagnr by sowivg than ber repitation in re bad te statomeh Ww a a “an such cases, pazevant to ile 403, all foams of 22 sharaster evidezoo are agmissible whrrever relovast, inelufize 73 opitios, reputation, vd spesiTie isrhaaes a7 eendich.t a Be your Honor fuss Ln ver motion te dlemiee zoling of 27 rebriary 26th of last year, “hough ceZendast never called SUOTTAR WATRICT ATROATTRG, P.O. Pret un reoaTen 1 plelatiic Lier, to cell fer clalme shelve Live Lisl have © bere sree no be ene dewasds the sane meatig. Plaiteiet 3 cunvol be waking claims sow Lo ba Loko. bal dre ebvio.s 1 lies witht being a liar. E #5. Maweell has stated dn her newer after that that © Emr seatemest was trier fear in, plAiSRESS ina iar. en in Lies sabilles by Fade 30s Lo dileviove all uime uo chester evidence, dnclicing specific instances of condict, spires, aid 3 reputation 1 al. coms Lal weitere look Tike? PLaisli’ ts wolter IL ceeviibes es es a Liss, plelilio's Slee seseibes des se a 12 Mar, plaizrifis cwplover from 2507 deserihed fer as a liar iE Vor Tovar, 1 wails Vike ko shark wi be Sieh ave 11 that PLatifis started with, ane that de metic Ln limdie 4, 17 widen 4 S411 clizten beizg on the island, 1" Mes Mawel] is goin Lo Lerbity ul Leis Leial, asd Tr erets going Lo Leslily regarcisg Lie obelons lies Lial 12 plaiatizs tols Ger. One story that plaintiii as tols de that 13 MeL Maven!) wns on the ielasd wits a1) Clinker and Reread © an 28 a iear pari TTT way approscs, yor Toror? Tae Lires 2 eiibate. wwe Zor sow. 2 Ta covsrs 1 tRizk in duplicate, te the extent that 1 2a biek a ME. MEKKINGER: 10 Like to Zizel chzect tie Cuszt'e 37 attention to the sews article by SUOTTAR WATRICT ATROATTRG, P.O. Prep 2 reoaTen 1 THD COURTS I'ew seas AL, 3 COURT: Ver, Thee read i 1 ME. MEKKDNGER: Okay. It's the oie dn which I me. oiaffre, en mares Ith, 204d, caw a loag asd lengthy © imherrice te saves Geirmeer dearibing Far experineen on te eles wilh 3il1 Clislus, wilh Al Suze, wilh AI Guze's wiie, 2 with all kises of Zane people. Ac the ieland event featured 3 Marge aed media covarage. 17 yo “ehiae Khe dak of thal 1 arlicle, your Torer, iLtx Mares sie, 2011 1n Te cel socomenl 1 prurkies do a press slalomel 12 rues hy mislaine mavenl] on marek 15rk, C011, se five dave TI Tatar, ie ukies sha wrilen, ae oF Rar alloran, Gn islaiee 11 Maxiell ceides tie Farivie allegativie abit Ger Gast Lave 17 appeared recently in the medda. These allegations are all 16 elie alae 1 Toor Turor, Lie lesl covomesl T wool Like Lo dizect 1: your attention to by the vay, after Ma. Maxvell piblisies 13 tein prace releane, Wirgicia shorts 2if Sof sin Sor, sha did 20 ol claim Leal, sre mai bear ewoliowal IY diakressed or i+] red 21 by being calle, essestially, a lar in this partieclar pres: 22 release. and alin, with respet to the sill Gliztes artisle, 23 our Fomor, ten evideran ab heial will show a subekarkial £1 smber us emeile betvess Tizglide Tobeile ese Me. Chuzviez 37 contemporazeece with this article. In tose of them does she SUOTTAN WATRICT ATROATTRG, P.O. Prep 2% reoaTen 1 cay, Yoo gob Ab viuig. 1 sever caw Sulelelis Mameell vie © Eelimepter wits a1] Glitkes. | sever said than se ged! se Bana 1 fo yeux enor, tie last soeiment, and it really, 1 I thizk, astaally helps clarify the gation your senor raised © whee we same in to amie gi moreine, An an email. (80s an tT emell rom Ghisleite Memvell Lu Ale Deretovile, Jaiacy o © 200, and dt has a decimest attacied called "Four Press 3 complaizto iE Tour Toror will tolice Leal Lis doc.mesl ix tol IL mashes cuncdsential, AL ves proses by Heo Meswell veers peas 17 aan, dn is marked Geislaine Mawel) S007, and it's a 13 combo belyaas Farrel” avd Alan Tarseowite, rower wile 11 hom sie Goss Gob Late a JGAt Gelenie agreement, ane that's 17 wy she produced this email, 1" Four Teror, Leis awril, ax vo. cs Lell Crow Lie sale, Ti ves senl loot Gaye aller Lie allegecly velamalocy slelemesl al 1: deste. It reclects Ma. Maxwell's cusaler of all of tie 13 statement Trom tha paper tat Pave hess show to be 20 complelaly oLroe or srow i comsislerey i rar shary. Tacs 21 article de listed so you van Zin that link that zeferences tie 22 lies are dzeensisteasies. a Four Tovar, BT vos look ak Kein docimeth Keak wan rer 1 Jiet a Zev ceye ater tie Janiary Zi small, ane joo Gaz to 20 page 3, which is actually the attached document, “soir Press SUOTTAR WATRICT ATROATTRG, P.O. Pret reoaTen 1 Complaiite®, Lecaiss Me. Maxell says ste's prepariog s press 7 complaitr i hn Ue, §% orer words a legal series, the thine Bp pe Tey A Rs WL An rl oe 1 procices ever a year age. E ow this document reads at the top, "Jrafted by Tome. Meewrll. 1 Raue aepind irnen ites ad mieten rom To arlicles, an my vomesle ace ii vzave ales Lis goole, Toe : relevast article that the guotes came from ie Listes below the 3 Mash mieke. Gelow, 1 Fisk, are some of Khe frraitable 10 corLemsiclions avi §-Lureslicg adi bina) delails Lal ven be IL ee dn Lie eller Lo Loe medl ase bn Lie collowiog press 1 semplainra. An addirien, thin arvisle on dnrhotein pe may 13 ries eaipra Ie) at 1a tie somber che lle that Ma. Maxwell polite 13 tei tomber 1, sill eliztes ddestificd in lawsuit against his 16 Cormer riasd wed pedophile TaTTrey Tprlaic who hud rela Terie = 5 then Me. Marvell's commentary cirectly aitervarcs, 13 ina cieratio, "ign problem ir than Clisken une came fe ten 28 imlanan 2 Your menor, in plalitif'c response exsiie me 22 reply brie, they slain mo. Maxell fad ze kneeloder in carly 73 dmary, PE1E Ka 31 Cliskes Rad sever boos be bee ixlands 41 Slkunely, eis es knovleoge bi Liat becaier sie vee clalmes Lo 27 have been there with him asd claimed to have flown on a SUOTTAR WATRICT ATROATTRG, P.O. Pret 2 reoaTen 1 helicopter with idm by plelatiss do bes Shares Corcies © peliseed armiclen. 3 Be bere, = Tarr of 200%, MeL Masel] x savicg be 1 vas never on the dalane. It doesn't depend on loile Freeh ox I asybedy else. That's obviensly -- in this particular email, © ymin coor Rein mataloned a1) of the sensed stories of Tieyitie Toberle, all uo Lie Liss Vivisie Subesls hes Lobe, © all of the diZZersct neve articles in videh these lies vere 3 hele, we raid ban WRiE in ceive te ba the bain of har press 1 complain i Le UX 1n Likmciew, un Lie deal page, yout Seivs, SHECH, al Lie 12 borrow, again, ste speeifioally refiees the elaime aber sill 13 Clinter being 0 Lee Gland avd save, We wan evar Lara. 11 Gagat aiter tat, sie saya, "Fglils slecicevs fiat AL Gure 17 and hie wife Tipper were alse guests en the leland." Ad To Mel Wawel] wriler, "Tey Save alse sever baat on Lie island, Ti end Teun'l believe Liey seen biow Jelitey Speleis.” 1 fo wien the ury ds asked to conalcer wat Me. Maxwell 13 meat wren cha insind, termi or atterey asd or proce PE mend, Lia Taeary Se, 2005 slalemerl, ve tace 4 21 coatemporasecie document draited by her That vas produced in 22 disnevery a year ago. bese of iv refers te the daze Jee 152 73 complaich, seth aT ik rears Le Khe CURR Seitder mekion. Bown £1 endl IU selec elmply Lo preee ellegativie List eve Leen 20 floating areund abost her and abost her involvement with SUOTTAR WATRICT ATROATTRG, P.O. Prep » reoaTen 1 Geiizey Spetedn sic Virginie Teberte. 7 PaimRiTes inne] Far said sratemeers made iv ten 3 newpaper arlicles are Serena. Tal in ote Lee, bl wer 4 400: Plalitifi'e statemest Ln a seve article, it's valle a I party admission. z PIAI=Ri=S mouplains than she Gideth Rae te PT wpsbinily Lo vepuse Presisenl Glisten, Tos Suse, : plaintifs's comnsel seight to depose President Clint: in their 3 reply Brie® an the and of die, 7515, abeut a weck batare 10 cinconery wan Lo close. Tray GiestL weet meslion iL + Lei 1 opeadg bebe, Liey sedews AL di sockel sabes 211. i” In what roeiest, whieh | dien't have az oppertizity to 13 objeal Le besnen FL me in reply, she said se waelad Le 11 cepuse him to, establish fle close persunal zelativieaip with 13 spatesn®, she sald nothing abest wanting te see whether he had 16 bees on Lie inland, weliar ba Slew iva alicopler, or Tr emplidng Like lial. 1 Bits rears to Luile Frees, joir fener, ve clecloses 13 Rima a wittrs in eer wide 77 disalerires lak Mares — 20 eee ma = Tebroary of 2016. PlaisLis wate vo «orl Lo Ley 21 to depose Lim, made no efort te find out hie basis of 22 kaeleder. we prodince in édseevery his report in whist he 23 submitted a TOI rsorh. a Teetezeay, you will recall Me. MoSevley teetizying 27 abost hew she, herself, issued a $0la request asd got dn SUOTTAN WATRICT ATROATTRG, P.O. Pret EE] ” 1 reepunes an TST SZ melivh wees me statement on sie © lnime i mirernin, her ste dessin koe tow in was redacted, 4 ato evidence. H we axe actially offtring to pit on the stad the © penne wo submitted the COIn rRainnh be eNplaie wean wa § eesoeled and viel ves teveived, Thal ie ful saperl Lesbinviys esr senor, that's chain of eistesy. 1 fuer, die telemsbivi vase ais I'm Gor Goling stom 12 Plaizeifss trearice that thoy sited threietest their respenin 11 seiencante can leo breve that otier Liable ais sore sbeit 17 tie slaimast are sivolatizg, at least iF tiey are widespread, Ti plelsliil lial vases ter cepoleliv: Lo a iier bol vial olbers 1 ease 26 our pozilion, yor Tovar. Tere, we Fave 4 slalemecl by 20 sickingham Palace Uiat vas issued cn the Aiternet and widely 22 sireidated, riere is alse @ videotape of Prizee andres devise 1 clreddetes then sytodig Me, Memvell celts ee welosives by tie 27 Zast that plaintiff can't even Ziad Ma. Maxwell's statemest on SOUMERR FITTER STPONRS, P.O. = reoaTen 1 tie dolesel spviene gotes bowels 7 Alan, Klas iersteeins widely niveslaned Sia denials af 3 pliTTe claims. Te wan on Good Mar iog Bmariar, bo wn on 1 OEE: Baney Grace Show, be vas on Fox bews. ALL of ticse I places he salled virginia deherts a liar, asd a serial liar, © ame steer teigr. ¥ Pe sw wabilled, gue Tunes, boli Liswsh vives examination of plaintiiZ as well as cross examination of Ler 3 cnparts, fe ehallovge sRatber or ob anyerivg raid by 10 Me. Masel] cased camace Lo ber rep lalios or walter olrer IL people vellicg cero lise ui seliviel deve eis bolesieliviel 12 zee dz, dn fact, fe Anzio of any damace fo hor repiraries. iE See i re avn, oF course, wo bas pul var rep lation 11 at deeie. Eaviig tie Juke oS York ane Sickingian Palace less 17 denials ds not hearsay, your sozer, it is effered for the Zact To Lal Lie desinl wes widely aire laled and ery likely Ti corledbiled Lo people wossivering pleislii Lo be o Lie. 1 Metin dn Limise somber 6, platitizi's sexial history 13 and repirarion. Thin salisek pick, veir comer, of emcee, 20 again, der Axil, ix Lal once yo. Fave pol vo.r repbalior 21 zor being a liar dn gestion, then other apeeiilc instances of 22 false claims become Richly relovast and probative ef your 73 ebarachor Tor LedRTidears, parkieidarly with rosard bo sesal A eseandt an cexial abies tH furthermore, yosr sonor, plaistiff is the one vie's SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen = 1 clelmicg sie nes demsges un puel Liamelic slices slevioes, sid © stn in the ae whe in geitg te eal] te ton srad Ser 3 pve ialeinh Lo Lik bool Leal paliesl, asd sha bs Le oo 4 that gave him evidence abut These Stier acte to Aim and on I which he has relied in reaching hs coselisiens. It is © SmporsiRIe Tor in to coh be AKA fo Arann AxamieR Ser eepacr bul preeaielicg PIED anses by dovivenls aid eveile seelales © tome. Maxvell. = Hokion he Vii Sine 7, SeABAR a oh We GE 10 can be calles 4 proslilole. Tor Toror, fo ore i Lis caze, IL so cunienl, sobusy Lisl Thm avers ui dneeless wile Lie 12 lirigarion fas referred to virginia Gliffre as a slur. Tear in TE moma inn Kal patel Te en ral Ban Brooch op, aed ven kil] 11 notice there de sbeolitely no vite dn any secors, dn any 17 comment referring to her as such. 1" Beal, van coms op, vour Teor, are itlarwel xiles iv Tr wie Me. Giillte tes bees called all Rims of Liiigs Lil ate 1: cnrelates to Me. Marvell, that co not cite Me. Mawell, For 13 evmmpln, Far Triceds gave i-kervicss te ten prac i wnien tee 20 weseribas ane Lin ix allacned as wg TRIbIL TL describes 21 virginia Giuiize as "a mosey hungry sex Kitten ui snjoyed her 22 lavish lifestyle®, we sazzet talk about plaizedff's repitaties 23 on ken iehartah wiki alking abou wah in eu Kare on ben 41 fiterset. We carol cross examine Ger op cress examlie cer 27 experts about what Ger repitation is if ve can't ask abest SUOTTAR WATRICT ATROATTRG, P.O. Prep EE] ” 1 thees bliss Lidige Lisl sre clrcleling abl fer Lisl have © cortit te de wits we. navel) 4 3. meplin, and sayig tiat he agrees not te Zefer to Firgiiia I acherts a; a prostitute, Yer aeIer, tht came Gp dn the © oeten 0 a arens evamitarion i= whist no raid Sn tas <n iden Po helies any bo bes cleine are visible os Gol. Te dese sob believe it's within the province of the peyohiatrist to be 11 thal te hive wielier bee cleime oo beiig ® prostibile ate Leos 12 or cer trio, ace be agreed ner te talk shat. 11 Homer, are uitissses ox people Un tie literiet vio Lave mace 17 cisparagit remarks abeut the plaistiZf that ave to be the Ti eye ate telaled Lo Me. Manvel, 1 Tlatntizite crip abies, notion in imine saber 2. 13 hay have coendnd, an they wirk, than phe period of time sheik 21 ofall of her illegal drug nee. And AT wasn't Just 22 presnripties rise, she Ea testified that oko was on a mmher £1 urige, Ger memory os sveile Srem L500 ares Giebeliotes 20 Zogey. And she says that's one of the reasons she can't SOUWERR WITTER STPONRS, P.O. El reoaTen 1 remeber Lie cemes oo Lie Surelgn preeloeile Liab eis ves © traffinked no, avd three ever Samess preple, benvie son wns Brgy Ar J Ta HR 1 Qeieiely, oir Honor, a ities! ability to perceive I and recall and relate ovests that happesed a long time age that © nen aTSrened by drag urn ceed te be Breige te igen bata To Lie Jeers : Tae second dseve, your Zeer, relates to the use of 3 prosariphios medication. Wak yo. Foard plaitkiTT say in ley 10 wool Tike Lo itLrot.ce weiterce Lal shat Labisg prescriplion 1 crise prupely, Lil Liey veil Lo esclise oe sion Gives 12 examizing hor ahest $Rar to see whether er nen ste was taking 13 prasariplios Groce improperly. Talis elles cross 1 ememinaticn, yeir fener. 1 ser use of prescription érigs has bees vell-dooamested 16 in var doclerts records, avd she vas mide “alse slalewels Lo Ti her solute tegervisg ter teed fur peesceiplion dogs. Eels 1: gone Zrem ne Soctor te tie ext, telling ee that she hasn't 13 wakes amy Galism or year, ad has Kha mavk an me and Hee 20 we rave Lee records srowieg Ural Lalla ual col Lr.e. Geely 21 told doctors that she vas stressed ent abost a big litivaticn 22 in bew xerk, she told a fester that in the vear 2014, this 23 Vmwrsib went Tiled Ghil T515, se sls made shabomshs bo 1 doctors thet are Lnaccizate tH eur menor, her statements reilected in her medical SUOTTAR WATRICT ATROATTRG, P.O. Pret EE] ” 1 revere may ue mey ut be esmicelble Gepeicliy un ial she ceye 7 omen arash, Wit they ave her arancmeses até they ave, 4 opponent weer S016 2. E Moreorer, her domter 4a the eat whe WASts te testify Po Lie une vols Lables sbuul hed precives es un wesicelivie. 2 zer Colorado doctor teetified that che hac micles him azd not 1 Lie deus ans sage she's popeily sew mecivelivie sui JCC SUL SE WO SE SORE J... 11 un prescripticn sie illegal crige. 5 26 yes sezer, | thizk it ds inappropriately limitizg Ti peries ol UE Lo 2052 bevenss any Seog wae Lieb she hes sed 1 the meantime can go to establish vistier or ot sie trily hes 13 postetraimikic shross dizerénr or any skeen metal Fealts a se as filed a laveuit asking for $30 millicn in 22 emotiomal distreas, pai ae sufferice, and her demtor i emit £1 teat peti ane stress anc emobloiel clelzves. 1: eor'e bess 27 sedng drugs in the interim that may aZfect hex memory, if she's SOUMERR FITTER STPORS, P.O. reoaTen = 1 iebng crige how Lhel mey ailecl hes memory, ur Lo ete's © imapprepriaely used frig i tee meactine, all of tean weld 3 Go lo walter or Sol me Lely ba Le owolionl dirLecs Lia 1 she claim. E movies in Limise #, plaistiff's erimizal history. 12 £1 wmemeriad plaiehi TI argent, tony de on wath nr te be eves eemiied wilies ces S20b) ue AEH) wilh sevess Lo a specific instance of clshonesty; that de, her thelt from her 3 ceplover. iE Tear are lagiots of carer, oor Toror, Leal Cite IL Lieil Lo be a coime un Gleviesly end sumiselble Sof prose oo 12 aranter of distezesty. iE Bol 6¥1y, your Teter, AI he cal shared by Lhe 11 astiuritiss Ln Florica vith tile crime of thet Zzom cer 17 employer, az arrest warrast vas issued Zor her, that arrest 6 warranl wan oulelandivg al Lie Lime she, doolef.tdoole, Clad Lo Ti Trellen, Thal arcesl varcasl temeited uo lelaseisg lil Lie Lf year, I tisk Z00E or 200¢, wien It was quashed. Pladntizz 13 Tailed te come back te thir aoitey diricn than atie nim. PE Th gob auamred becuse iL ad bee s.r a long passage o Lime a Ths COUNT Who wa: the employer? 2 MEL MRRIMGA IT was the deadhenst Grill, your 73 Feror. Thoms burger Joish. Red rhe wan werkite al tab £1 Zuastoies Grill dn Merch vi E02 Gurlig tae perius oo me che 37 claims that she vas a sex slave. fhe claimed that aie vas a SUOTTAN WATRICT ATROATTRG, P.O. Prep reoaTen 2 1 eek clave, Liab sie ves gelling pale weds oo vesn, Liviesiie ui © dollars by antTrey speteit, avd this wns tappetig TAT. aed Benne Tdi TR BE SR Bo ev 4 of her working at tie Seadiiee Grill, Bit alec of hex working I at a busch of etic restasraits, at a vevcrizarias's office, TAN) WinEr 0F shiver furinh ¥en period nf Rime tan Sin rave fe Doves a wal de vumeeily hoow se @ ses slave, ds fw sie described it in ex papers. s Vor Conor, rhe compeinded the Tin beck Lhe Lah 10 bucaize she wrole a book mesireripl, ax yoo brow. Res in Leal IL book meevedpl, sie sesviibes Liab dL wes Sub fer vio Louk Lie 12 mecey from the tip dar, it was fer hevEriesd, tony sires, 13 amd malts alr weal she LeskiTied Grieg her deposition n She sain, ur exemple, That sie Glen't camidt tis 13 theft, that he came in at the exd of her shift, azé while she 6 wank looking, bats Le ove Leal Leak Lie Lipa. 1 Bell, ve ceposed Toiy Tigoetos, as Tory Tigietva, 12 yosr Rene migit be surprises to hear, le a gentleman with 13 rewnral Telomine to Ris same, whics Ra gladly renistad en the 20 wilress sland or viceolapa. Te Lathes bool all bre Lra’le ve 21 Gas committed, thefts from a video tere, he wa: charged with 22 Zelemies, ke vas pat en probation fer tex years, he resesely 73 had gobhos out, bik be actually desied Kak be ws Le on who £1 took Lae mosey srom Lie Lip Jer. tH fo there's the lie, there's the tip Jar thelt, then SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen ® 1 there's the Lie sbuil Lie Gp Jez Liesl, ens tien Lieze Ss tie © arrest warren ean was issued tan plaiteitt let thn amine 3 tar aver a decade while Lak arrest, waerasl wi ould ing 1 Your Boor, the fact of police voitacts Curie this I timeframe, including this cnc, go directly te other Lssucs, To SeAlifine uarter or teh plaisHiTS uns brie tee see slave ten she wesceibes. he hes an oppuslosilys bevese sie vellss Lie © pulice on nmbers of eecasions curing the relevast time 3 period == ra called them ko report a KReTE, she called teem bo TT relp wile 4 clei] ansizl Gelling ter ool of ber aparlmecl, she 11 Called Loew for all kiss ui fessvie a al fete uf lives 12 peizrs of time fi sto £1] thn police thar sho was mrestly 13 bean, sled saele, res slave n Your Somer, tie Teacheite SELL ali ths Mall On 17 ewiday is the exe wie printed a story abeut the eadienss Grill 6 an aor rorled rar auk wo was bait iolerviorad Tor ove o Ti Leer slories ebuol iL. Toe acil ves it Lie provess of saplsg 15 what a great niece sie has, ane ten tie neve asked Ger abit 13 ten seadteir Gril) ERATE, ad cha said, Mew, | dideth mee 20 brow Leal sve vax varkivg i= 4 burger Join." Go il goss Lo 21 ter fnterset repitatien. 22 an Sizally, yoar secer, 1 thizk if vow look bask te 23 kak omai) babwses our alioeh aed Me, orsRowibs on page (NEE, 1 Ue ume on tie Lee iat vir clisat epevicically zesezzes to, 37 fhe quotes Virginia Giuifre's statement, "eifrey hoight me SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen = 1 feveliy, slemsice vers hie seville, ass venders Soridlize © enw pavicg me very wrll beanie 1 give Sim ses whomever bn BA RR Ror GUI, FRG, MV St pple er 1 sowell, wey steal from hex burger fob in 2002 So iti I within ear oliest's kuoeleder on Jansary §, 250%, asd that ds © an aeRiniomal renner why in SEeild be afmitked anice be Ser leben miss ve avbeed malive, se pleiibios dikes Lo vall il. : Your Zonor, vith respect to the schosl records, the 3 netoel recordn are shal fey are. They explaic bak she wer in 10 screed Goring Le wrlive Lime se claims Lol xe ves a ses IL slave, SU gives ter Gombers ul Gaye ul sllsiasve, Tun’ 12 undereané why these reords wnilén't be admitted in avers 13 cramivalien oF or an Le bor woraahe.ls al eerlais sacs iens 11 Platstizz certainly intends to litzecice TLigt loge te shew 17 that she was or vasa't in certain places, so scheel reserds 16 sew ware ave was av ass th on carlai daled, and alts Ti imprlerl, ju.t Tosor. 1 Moreover, plaiitiiz la the oie Wo tels Sharon 13 ukirstar abot or ows problem wits sereel. hn told stare 20 Crircrar, and Graven Coreen poblizres wile var aolvori saliov 21 that she went back to school To vet her Gad, and she vaited to 22 svaey for massage, dhe talked ahost droppize ext ef snienl. 23 Palin roerds rotleck bo Sach beak she an a beak dari 1 thle perioe ui time, tial Ger mother ves vonceriss abuit her 37 abusing erie asd alochel. The school records intimately SUOTTAR WATRICT ATROATTRG, P.O. Pret reoaTen id 1 dilesesct elite tie eabice story taal pleiobiss fas tole aboot © being a sew slave in the years 1555 te 7007 3 Hiro, vor Totor, Lier go Lo dames bec ra plaisiitt 1 has claimed that she shore be entitled to a certals amount of I damages, asd her ows cxports have talked abest Sex brizg a © hredhIed m1. again, © ir somernite Hear tey elf reir Po pepidaleiv eapesl, ane be celisd on Simiog Luel she ves o © trebles child, and then he's made inferences from there abet 3 why sha shed be arhinled ke certain damages, ad | ERETE Eee 10 screed records are a Tait came or cross ecamivalion of bin 1n Molds Ln Limite fonber 10, Ger bat collet 12 hekavier. again, your setor, thin in exactly == plaizeiff weze TI ine me en pryesialeink, wel (5 Le nee bee asd oor 11 sncepeicet mesiial examiner, aie Ln Leth cases sie seacribes 13 all of ter, euotelunguote, bad ohildicod beaver, fo it gees 16 Lo ver damger, vour Toror. Tray wal Lo alicil wal Ley wel Ti Lo elicil and keep os rom elicilizg asyluing Lial vole 1: contrasiet it. 1: Sit pibRing yor vopstatios asd your karastan i PE mea, an sve bax in Lie cave, abool Lia Lime wre se wasn 21 chdld fe necessarily a Part of cur res: examizatien to explain 22 tna fury war her repstaties at the time of the asts i a Si vee a Leienl, sepurtes Lo Lor ecioule ae o linet, 27 reported by her mother to the police, cizeilated with pesple in SUOTTAN WATRICT ATROATTRG, P.O. Pret ol reoaTen 1 the vommcdly ob Lighoy Le Shc Ger, en she vas hoown se sah © in er memiiny. an te say sowtew than we aas'n talk aber Brees ar rE We a TR Ta Rea 1 the time she vas a Chile wien she claims that she was the I viotim of sex abuse, ds Get supperted by the law. z Maimhi=F Alen mites te cack om efamaies, avd | believe Lie vile do 10, Section 2. Bow gues Hoses, T Ldsk thls helps clarizy a let of what eur peeition ds in tile case. s Sank belieues, an we do, bat in is eobively 10 appropriate cise AEB) Le Gusibion 4 plainLic! whe Fax IL alleges vecamebive, vives sepilalive de a dese dbuil all 12 Rizr of had asta, They have said, Sur tee, that there is 13 just me rarer wo seelld bo allowed Le ask boul all Leese 1 otuer bac acta. 5 ack cites, your seter, to az aleventh Giremit ease, 16 ewer ve. Time, Tres Te Leal case, voor Totor, Sneb mae Lie Tr Bleverls Clreoil foo Lie sisleicl cooel fad beet vorcecl whe: 134 rules that the ceZensant, wideh allegedly accused tie 13 plaithiT of being a traitor, Yeeild be permed te mackie PE Le plainLitt ubol a “alony conviclio, a posible violalion 21 ef tie exhaequent parole, convictics for driving wider the 22 gafluecer, an arrest Ser writizg a had creek, failure te file 73 ka robires, Tailire bo pay alimony avd aild soppork, asd £1 welsenoe comming plelilics'e wiiuite Lo change Le name ai 20 somial security mamber.® In other words, coe you pat your SUOTTAR WATRICT ATROATTRG, P.O. Prep “seater » 1 Eepitetion at desime all oi thers apelilc dietaiees guliy to 1 les tax setize, fhe salts "We. Tax fra a net a private © matcer, as platstiff sosrenis, it ir a erin. it is a orinc of LRT — : Sie Sibel debs bee vomplatil Liat bes : xepstetion ves injured in her professicnel capacity ss 10 Wrekin Rw Strona, Frets TI br: 31 Fe twesies Gal Ling hes sl mel Links Lex wbligativie sis Loy nif dnon Bells ‘Wit Bow aermesson Kowsy Yooatliherk n TULL aay, fovever, that buts uf these desims, 15 failure to Sie tax retin: snd tax fad, are cxastly the Tt allen bo elebbish Lin Leal vi gece stall tial 1 plantas: ds a Mar GAVE TT FR A a A300 millics i pads, suffering, and emotical dhstress. 2 blaimeiSEs expert, oe climes, testified tia domestis £1 cer TEED. Te lew testicies St ves & very vholeit splevse sis 3 mere likely happeted more than coe. se alse testified that SUA TITTY ARAN, B.C. reoaTen ® 1 ce deste swsiticiel mezitel ait sekeal vuseellig base wi bez Tinie VE, Wie SN ATateE $5 Avie bo YER 1 oir expert, joir senor, Likewise ound that tie Sar I more likely ease of any dyeZssstien in her marriage which © armen at tee nine of thn demestin vinleean (maiden and wan meee Likely Lie vane un any PIED pein, seoomsiig, ve emoliviel © distress that she vas experisieiig. s Wat domestic wielanan imaidant, Sapper i arly 10 Maren, S015 a ciple of merle aller Lie allegedly de emery 1 slalemest, ans seven musts beiote plaiilic brugal Laie 17 dawn. iE Mees arimial procoadivgn agaiel er vubard alse are 11 relevait te er camsges, apart Srom D2. Slimane testimony. 13 mer tmshand was ordered to live away frem thelr home, leaving 16 rar ko are “or ver Lire onildrer alone. Ta Lian slope Ti perlicipalisg in Lie cotl severed domestic vivlesce 1: comsslizge ase be cles the country wit an active arrest 13 warrath bean remains eutekasdicg to tein Gate Tro Celerade. ET RIV 0° Less allar-alive so.rces of ewolioral dislress 21 zor plaintizf should be admitted, a: her expert, Jr. sliman, 22 han testified, in as far as they impact supposed Past, 73 mattericg, lens aT eiovmerh of 11%. a Mobius do Lmice combs 15, any Leelimosy tial cox 20 with a 17-year-old girl is, guote/mgiote, lawsil. rlaiseiss SUOTTAR WATRICT ATROATTRG, P.O. Pret reoaTen 1 de the ue vio claims sie fas ask wilh vazivie people at © warieis planes an varies vines, some whee she was 17, sow BGR anE un VHS SVE, A IARI, es 1 1 siglase, some in Few Yurk, seme in Few Mexico. In all uf these I cases, execpt rlerida, tho age of cexsext ds 17. H | fete keen wan vidnean plATSEITS 2 anit be To islestice abuol viel sea ste hed, oss, wilh whom, en ber age © at tiat time because those sands have shifted dramatically 3 during the couse of this Vikigation, E11 aan say, ver 10 Torer, ix, 17 ave Leies Lo inLrod.ce eeitesce Liab sre mad ses IL ele certain place ene Lime ai claims Lael 1 ves devo od, 12 wer senor will he fury hosnd ta dsorrier a dary en war is or TE Geer let ea pariielae |oeisdiation al 4 pabic dae Line 11 ane pasticiler place. 5 tour seer, | vealé submit that movies in limize 16 16 reserdivg Lie medical records, agit, ix somaliitg Leal deperis Ti ceamelically vr wal plaisliil isleodces coring fee cese © 15 chien, bit there are many statements, as 1 mentices wazliez, 13 to tar doctors wriat weild be admitted an cecbearsay §7 atoerd PE agaival ver ax parly atwizzion. 2 Tiere are many statements over the last 1 jeazs that 22 relate te ter mextal senéitien, that relate to er medisatiens. 23 “a 1 articipate arkicg about Far Terrk bitel 1 de cok. To | £1 seblclpete echicy ebunt Lis elie bilige Lisl sie lites bo bez 37 metic in limize: | do net. Sut I co believe that there are a SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen = 1 nimber ui Cmes hal abe sav Goclose, meds stalemate, suighl 7 treamaer, gor medicarinss, a1 of whist are rafleared i= er 3 medi) records an are sowskeing Ll abo Lwin rhe may be 1 cross examises. E sc claims her medical records are private. she is © ten een reekicg G30 willie i monineal dishes, paie an To eeiieelig, ead 1 Lhisk when yuo wo Liebe Tw sete be levers : acvised her that her privacy rights with respect te Ler medical 3 rocards weil so lorger ba be sams as a privake Psividal. 1 Tour Toor, Moliot ix limite Ti, agaiv, Lre dollar 11 value ul Lie Jane Dov selllsmest sepesds silizely ui wel 12 happens in terms ef plain maze in Riet and worker any 13 oleae avidenes regardieg Lee dave Jen 167 1ikigakio comes iol 11 evicence, bevaiés AZ AU Goss, tien toe settlement ase tie 17 settlemest ameiit may very well become relevast, hut 1 maz't 6 ay righL vow bow weve ihands Lo Le Leak al Leiel, wy il Ti ood be telecerl, ane T can'l say wreliee of fol Lie 1: aettlemect amoint voile Likewise be relevast. 1: Motion i Timitn 15, fn Gare) l-sdun rien errtoui ne 28 NiLigabion ane Lreir selliomarl. TLUs isbaraslicg Lo vole 21 mr. cassell te refer to himself in the third peracn wien he va: 22 ralking aber thar litigaties, a Voir Tovar, Keora arn a camber == 1 a aah Tie 1 reacone, at least, tiat tial vase le zelevast to tie fects bo 3 this case. SUOTTAR WATRICT ATROATTRG, P.O. Prep “seater ad fi PLaietiss ves « vitiese dn tat Gass. She ves depose A roca p——— 1 testimesy in that case is aatssible. H she participated in that case, yer senor, from March FET SPR J J ¥ she smpuilo Ly bs otids inl SL vas varaiog bes 2 : eigmificast amos of stress. In fact, shortly before she vas n Be. Miller, wi payetiateiel, fess Lil es 11 epmtems, acs ie sale tat they vers saverbatec by fer 15 participaties fx that livigatios, 31 cupilebiunel semees Spats gees Tones Toeine bo Un 1: Zecral svicencs trestise zelies on by plaistiif. In I uidespresd, te comnatrate St 4s Gof hat the defendant sald 52 shot rh pIASHESS her cried or pepstanion te siffor hie a our Forex tae teat lie VEZ pleacizger Malitiiite 31 experts fave pelled off the dzterset all kinds of stories that SUA TITTY ARAN, B.C. reoaTen = 1 relate Lo plelitios sis sels Liab Lives slusles are selosice oo 7 ber damaced vepiranies. whe yo look an rhe arorics thar BAIT erp Gar Fe Treat; ARR Sa ot 1 them relate to the Cassell Sovards Jerstowits litigation; wat I tappescd in the litigatien, statemests made hy the parties in © ten Vitinakies, statemeste made about Sirgisia G1aTTn rales TL Liab Litigaliv, : 12 her repitaticn ie damage by sme other litigation 3 teak var cekien te do with Hr Mawel], Me. Masel] ath be 10 resporible Tor Lal replalioral camace 1n THD COURT: Maal's your waplanalivi ui Lie cemete 12 aimed to GHuSIEe hy the orsteeits casei iE WoL WIEKTEGTR: Thm sereyi n THE COURT 1 incerstans the testimuiy part. Teat's a 17 different kind of thing, ut the case itself, how docs that 16 mee rer repolaliont 1 MEL MIETGIR: TU': Lie press allescest Lo Lial case, 1 your mene. 1: Wo Gat kav. ie te press atbesiach. ET Mi. WEETHGTR: Tears was 4 lok oF pris allevcari. Lo 21 that case which vas, fraskly, hevative to the plaiitiil that 22 had methine de with Mo. Maxwell's denial. An their cuperts 73 have eelicd er Keak prov asd alaimed Lat Leah prec romkos 41 cippurte Lisls claim sur semegee sveliel Me. Maxell, even 37 theigh she's net mentioned in the particular stories. SUOTTAR WATRICT ATROATTRG, P.O. Pret reoaTen = 1 TIT COURT: Bit ow de hal golig Le Slyure dito 3 M3. WERTHGTR: Your Torer, TLRis¥ Lhe Jory we ld bo 1 dmetrictes here not to held Me. Marvell zespereible Zor ay I arm to plaintiff's repvavies caused by third partis ox © Alterman seinen, SsAlifing stories than wer eerabed by Po lelemenle mess by bes wen counsel, Ly Blan Jeseievile, by © Prine andrew, by anyeme eles. s COURT WaT], yer. ek whan Thm brvicg de Tigire IT oil wal boll Leal cere wan camagicg Lo Gi rel 1n MEL MEEKINGER: 1 van’ Leld yun Lisl, yuo usck. 17 itt anally plaiteiti whe ave ackitg for S13 millies in 13 ropilalineal cleap ceri, avd wees yo. ark Liem wal 11 repitatical cleanip costs are jou trplay to elean ip tie 17 point te stories having to de with the Jershewitz litigaties, 6 Trey say ver repolalion was damages by Lol LiLigulion a by Tr Lie stories teleled Lo il, ane Liey val Lo post all of Lise 1: stories coun on the internet searches. bot stories tist relate 13 te MeL Mevenll, stories than relate te bar likiganion wits —- 28 rer laarts Vilicalion wile Klee Jersrouil 2 Ths cous Okay 2 Mi. MRIMGA 1 éen't Rizk that evidezes sheild 23 come i= beaaien | doth Kok ERY bared on seineas, bik | 1 realize that's sot zor tucer. EH Likewise, your soser, ber failure to sue Alan SUOTTAR WATRICT ATROATTRG, P.O. Prep “seater » 1 Bemshunite altiuigh e's puis un ald bi tises ulier stwe si 4 Finally, yeix sick, tiers ds, a gos beard fre 3 mr. cassell, talking abost fassell lawssit, a stavemcst iseied tT made sepeessilelivie, Liey it su veils Liey veie opresssliog : platstif, Tis vas vidle Mr. Cassell asd Me. Sivards vere 0 Bn Uni cs Sey aaah el Ue Sarin eal wre Http i Cedi apes puis Sees ate 11d ger Sener, LafstiSI veils Like to mks a Lt of sgimsts 12 mow she's already litigated these pests, fhe lest, she's Tr secioaly wislestiog ge Tue be sini Loe Jukes melds 1 and net dnferm the Jury thet a Jucge Zoims thet the allsgaticn EBA A A a El I net bess deposed. She as 8 Glselesed uithess, Toy add 2 mets ser nine te be witsers. well, we'll see. vos sone, Te set wn eppropiets motius dn Lintie. I Kuen wat toe 57 rides of evidence are with verard to hearsay and dochle SUA TITTY ARAN, B.C. rswaTel : 1 testesy. 7 Hants alan trie, yeir eter, largely with respect to A opirien xem tide Cort alent thlige That may or may ot 3 tappes. we: amor, | 33t den't see the Seed to waste more © time oe in i Tete is uid vie ieee, Lie ute cadet in 2 were ve have presented tie possibility tiat as the party that bears the 3 burden 0 proot, we nila bo alloeed firing elosicg anges, 1 closing esgmits i” 1# hey ase eperel over a party até tat party 1 ctinstances sie ith tie 2ivit Seiiaticn, ask for a misediy 17 witness instricties, yest seser, hat these are all advisery I ME. MCCRRISY: Toor Tutor, Slgeid McCauley os benall 15 or the plaintiff. Geils the Cost dike to take a break at tile 13 peinhi 1 ees wntun noe Tor a empl Sein. tm sok sire Fw 0 yout Vibe Lo process. Uatra happy Lo address —- a rn cou bets Zanih, 2 Mi BeGaMLGYD Lee's finish. Okay, great. hack ves a me sie a ie defense started with an overview of Jule 453 1hi, SUTIN MITRICT STIATRS, B.C nu reoaTen Leu del meet sespuie Lo Liab besides 7 Wey reteresen wind ler ad 4irkpanrink, 4 treatise Bul ws Ley be vary isle clive of Lis partic tae pois 1 Misller and irkpatzick saye, "It i: trie tat in a I defamation case there ds more latitide vo introducing © eepitaniseal types of reidnsan. -owrwnr, (E'S importash fo © cemenbes, say Moellee ans Tichpeleich, Lieb aclial viesavles is © net so mech the guestion as repstation.” s fe ih Tollogs that Mrpeai Ti instareon oF misaasdie TT cariol be proved ©° Ling were tol erarally brow baca.ze Lies 1 lhey woods sb ssiect septation” 1” They Go en to say that, "Een a defeodaels rend gens 13 to spent Tie inlaraes dar ATED, callien Crom Le |g i 11 sn ovzeer. Droviiy mlebenavicr van, dn siiect, Lecons a game of 17 character assassinaticn that adds insult te dry whieh courts 6 ca block by cure’ ly considering relevasey nse an Lie Ti rode ageinel nial prelice Coon ks Rode 2057 Raeoso dL ds 12 agaiet that backezop that te Cosrt sieils be consicerisg 13 thane 455 rier. ET Beal Twols Five Lo do iz 0 ar Lres i lalrabions 21 of what 1 think de godsg to be a pervasive Zlav in many of the 22 arguments advazoed hy thr defense. a Gown Foard Krab, "eur Coor, look weder ATEBY. Men £1 ect Lieb tor mebier pleditiii's molies ceeciibes fer se o 27 liar about uedng drags and runing avay Srem Lome, that comes SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen id 1 hn te stow repitativi.® Del me explain vig 1 belieos tial 7 argmenr in Sidamesrally Slowed, and thar will, of emirae, 3 nee oor Lo elves 111 slrations, a well 1 Tie statement to whlch Sefence voinsel vas referrise I was a statemest that Me. GinZfrc's mother made during a © Aeperinins ar a witerer i= #Rir mane where tee oly peopl in Lie coum were Lie vonsl cepurles si Lie ablusiers. Te acl that wien asked, "Wat Gid you thick of your dasgiter 17 yeare 3 agel BRTL, 1 hough ak the Lime Lal she war a Tian, t weet 10 somelring Liab coms Lo Meo Gio rats rep Lalion bacalse Listes 1 no erie angbusy hier abul dL olies Lies, yun have, Lie 17 meter wre in mee heise depese iT S016. iE Morsouer, Lee m.asbios wiz, "al did ve. Lik abo 11 the Zact tat yoix teen 17 year ule Shido ves Funadig avay Trem 13 scicel: well, I tacnght she was lying te me abest that.' Fat 16 weld go, T guar, Lo ber repulalios buch in, weal, 199, 7555, Ti ZECL, Lial Lime period, bol of voces Lie damages Lial ace al 15 desis in tile case are camaes arosic Sle ane taereaboits wien 13 ten enfamsory ctatemeet in released. » Go ita ard Lo see ever a argmerl Cor Lee slalom 21 ef the mom in a depesiticn geing to zeputaticn. 1 den't know, 22 mavhe 1'm missize semctiizg, mavhe there's seme marginal 23 relearn Keak ane be Giskilled ei of all of Kah. vik oF 1 izes tues guar Tenor tes tu weln viatever margiiel vali 27 that hes as to reputational issues againat the very signifisat SUOTTAR WATRICT ATROATTRG, P.O. Pret reoaTen 1 prelasiclal sizects 7 Shims, Rin in Gait to be aensidered by the Say 3 Le rink avats d bud Kid, Treytre ol going La live 4 Me. Giuiize, ane they're ging to Geld At agatnet her, not I booasse it Gas some teokaical Fopitational aspect to it, but © bemmien i in semennitg teat sews shale a bad porsen. Leder TALE Lhe eeideice shold be sacle, : Let me give you a second Allistratics of reputational 3 poitte. ey ray, Reba, leok. Me. GETTre week to 10 Time, ai T believe your Toor relerred Lo Lal as well IL Ret goo Duwr asked, T Ledik, a very gous Govelivn, si lel me 12 ee if 1 ean aceeer phar eestien. 1” Vou mais, WIT, why G18 se dinclose a1] Kin sl" 11 te dr. Siimanit Weld, tie aver le cbiloia, she vas index 17 smstricties from tic doster to tell cvcrytiing that happened. 1 un of corns she Lol, Lo Lhe bask of ver abilily, everyliivg Ti Lal teppered. fume of Lie sil ds golig Lo Ls oll ine 1: comet of law to be relevat, some of thls stiff dn a court ef 13 Taw ir gait fn irs enh fe be freolevath. win table cen thn 76 paverialrizits Job Lo say, ‘Fo, “a, a, do='l Lal bol 21 illegal drug nee becaise the prejudicial eifeet cutveighs the 20 probative value," he dust getsia fll medioal histers. and 23 ravig aelleaked all bab is Cermikion, vou knew, Eroih £1 Dr. limes, ur teey elec nave 3z. Miller wie dic @ elmilar curt 20 of thing. tow oace yeu have all of this vast array of SUOTTAR WATRICT ATROATTRG, P.O. Prep 2) reoaTen 1 dniummelive, Lien Lie levyese preseal ssgomeite Lo yuor Sonos 3 report arent relevisl Lo Lia Gane and, 4 Cac, are going Lo 4 be Gigely predueielal Zor the Jury! That's wy we're here I thls morning acking for some of these thizes to be exelided. H for meawple, tRnre ave some vSnreeans —= | wnsit Po belebur Lie puisl Lub Lie ceoecsioes bial ve'ee mekicg Lo some of the illegal rig usage asc so forth, that's net 3 remetrivg wntre trying be deploy aTTirmatively. Whe goed 10 doctor simply Hisles all of Lie i= ormalion Lil bac buat IL reviled se pact on ide sepurl su Lael Lie levers end Lie Jose 12 az zoe make a fetermizarion. iE Be Le Tach Weal Me. GILT Leld Te. Dimas in a 11 conilcentisl pejchiatzic examliation certaln tilige abust ery 13 use can't possibly ge te her reputatics besause fe ont vas 6 rare wo was assessivg wal bivds of brits wighl be going or. 1 Bosimilar poitl ver be mace abo.l Lex ira Me'ze 1: tole, "Well, yeir Honor, tax frais goes to her repitativa.® 1 13 rippers Keak ons to Rar repikatios wikh coms Ixs agent whe ir 26 ooking alu rele, bil iL cantl poxzibly go Lo 4 geraral 21 repuvatics that is at desue in this case 22 an ecoc again, the muses tat wo mite in eur briefs 1 73 eK make Kis posh cloar, Where ina wash risk of 1 predusicial eiiect to Me. Giiiize becanes toe lazy de golig to 27 thizk, eho she's a tax cheat, asd they're gedzg to hold that SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen = 1 agaliel ber becaise tiey won't Like ber sctitie Ln Lael © partimilar sivemstaten an eppesed te the merits of thn mane 5 Be by Le wav, wa aes Going Lo slrotly corlart Lia 1 she's a tax cheat, do your Senor ia codng to have, 1 guess, I competing tax information, and Jury dmstractiens en whether © prrmesal imu enires Rave th he eeperted se yi rewire, all Ten widen de veisy Lo eeleel Lie Joeg's Lime and allestive, fol © to mention the Court's aid vomisel's, away from the fundamental 3 imria af did Me. Mawel] doTams MeL GELTRR. Go babies eur 10 raspotze Lo Lie i+iLinl overvies recarcicg A05, ase Tw going 1 to Luss Lie Lime veer Lu my collesgie Sov bo shee Lalo sume 17 opesitine. iE Mi. MECHRIST: Trak yo, your Teter. Tim goith Ley 11 to keep tals very bries ac Juet tench uh sume of the 17 highlights guickly, 1" So we vera Lalbisg iniLinlly al Lie bagiee ig abo.l. Ti Lie dese of catives pieces of Gilleterl wiliesses, velier 1: thelr internation veils come dn, ans ve GAC en the dave 13 trey Breit ap the fren of Me. rast, and aatially ga PE ya. —- Laks ve. Leal ve was going Lo bi oak somebesy who wa 21 gedny to ait on the stand and validate the $OIA Zepenie. 2 Well, very elear from the domments they've prodiscd 23 ie ARie amen, B71 anild Rand Wham up, vein Fever, Kir in ben 41 pages taal lie prosices wilh respect to Mr. Treen. Bag juo'il 27 see on the first page, Ge gives his conclusion asd he says, SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen we 1 "Based un my skperisioe, kivleoge, si dotiee uo lisse © pretessls it ree Las preteenive erails ef spesial Agnens, 3 company orcerlivg We. €1itlenn <= sa bo ia ralvicg on His 1 expertise a: a omer FBI head Ln créer to opite on Whether ox I sot these $oonrds ac COIGST, FONE ACSOI. z Wey Biseloned Rim anon lay witeene i= Kei ence, coh Tat ae an eaperl viliese. Me weil Litu.gh @ seties oyun © knew your Homer, you've seen all the expert cepeaitics in this 3 cane whan weton Fad. Whey sav, Well, yoo eeild Rave deposed 10 vimana lay wilenst 1n Tou Huon, will remember, ve vers very Linilec. fe 17 were limited to te depos. we Sad to bea, herees, at seeal to TI cela Tee were, and we bad Ls be wary maraTi 1 wee wa ples 11 ane chose WIth respect to etablichliy wir clang, If ve has 17 hue, of course, that Mp, frech vas ening to be pat on the V6 led an an aoperls in Lin case, we, 0 co.rue, woold have Tr sougnl the cepusilivs Liro.gn Lie expel process. 1 fo, yeux Homer, 1 talk those cocimets speak Zor 13 tremenlunr. Teoy'ee very elaar, Rants OIE, wears bate 28 givicg Leal cles apiion Tre teller is aeel Lo 20 mr, Oesehovitz and he sigue iT, and then it has the relevant 22 avtastmests. dn, your seser, we fimly believe that that 73 rhoild be Repl out 0 cvidatan buaaire bo wan wok dizelonod 41 properly se en wipeil dn lide veer. tH foe ether thing | vant fo peiit your attention to is SUOTTAR WATRICT ATROATTRG, P.O. Pret rswaTel : 1 smother covimet lial hey ave June sit 1 Lilak tide covamest in veally vellizg Tor whan in dessin say, and teants the endl 1 Fight after a Se cage after sie makes tie 3 defamaters statement, she's conversize with Ala Jrrshowitz i Rial's seably dibesmabisg sbuel Lids is swiss io : thie statement cose she say, 'l GAGH'T participate in tide 1 iL appa wile TRY Tealead, sve picks slalewsls a0 sag 1 leis Like widen seis Like o Jeeloie gitlizies sie 17 nave, 1 eallee destroy and eld Sim ote Salles madly in lawn, I1 Have a aioe Lie" ans Rig Gh Gh Be." RSG she Pte di paren IF te Mr. Jershewits, "M6 she wast Jeffrey to say ne, den't do Cleaely, ste booes while eric ter veposilivs she 1 cladmed to set recollect ny clisit vistsosver, sie clearly 15 bow or and Ei chews ban they enn togetor 20 because she's pitting dn pazene inéivicials, other people tiat 22 my eliest was lent out te thar they foreet te meatien in the £1 sevameal le west IU corer’ cays but AU clearly sive sie kis 3 my olient, she kiew Wat was cecurritg, ad she's simply tryitg SUTIN MITRICR STIATRS, B.C reoaTen ¥ 1 to pick spazt nisives dn tie elatemsal. Zu, yeiz Homer, 1 7 sebmin rear te you Sor war Ir donssin say Trem we. meesl] 3 ives broytes provided Leal be ve. Lady 1 Taere aze a Sew more tilts That I Juet vant to teieh I ox that I thizk secd to bo elarificd, asd that is, with respeot © te o= ther war thin weenie abet -respaper arkieles, até an To gen howe ve'er sobmilled an sapeil vio salyoes License web : aalytice, he's the same expert that vas in the Andere case vio 3 Tollewed tak vides of kha Tor reporhar ever the itareel aed 10 bewchus Leal be Cand 4 wel I-acompline meliodatogy. Tatu ul 1 lial forth all in vir papers. 1” wit br tracked the spemifie Gioted statemests, your 13 Temer. er iT bray Rave an ines, 07 Leap wal bo sav, ov, 11 they're prepeelip tossy that tiees articles relates to tie 12 Dershowitz matter, that's subject fer cress examizaticn of him TET Ley marl, bul be bun a cary clear meliodology, nu Lose Ti erlicles Lial be Leackes vere in Lial meter, yoot Tuto, so 1 15 Jiet want to make thst pelt lice tiey Zalses it. 1 knew 13 unten men diiening the experts i= Aatail teday, Bit | Ei ark 28 ral ueslion a fo your senor, in Juet summarizing en these podite, 1 22 wmizk we made oloar in eur epenize aremest why we holicve that 23 Kein sFesldnth be sibicah te a umber of mini heigls on a 1 variety of these lessee, we're toplig to slzeamliie tide 27 matter, and that's wiy ve proposed this motion ia limise te jos SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen » 1 dn tie vay Liat ve sie 7 I'm dunn going ta len my nimnel addres any Smal 1 ME. SCHULTZ: Your Borex, © con't have anything I further te say on motion in linine mambor §. The defondast has © moh gives amy valid rears or uni Timanien for i-teedimicg any viene un prive seal assandl Lisl shonle be sacle or © all the reasons in the brief and the eral argument cer these 1 Dil regard Lo droge, Liars are col mito. wetical 1 records pressiles bere. Deieicanl's cosiesd hes stout Lp ai 12 aid shore are false statements ta doctors asd have suested 13 beak MeL Gira is seater cropping. TH submit eal bee 11 revere co set reilect tat, 5 Jefesdast apparently seeks to introduce a dotved dows 16 ala rere or Lrare rom medical records, bul Lesa are plait Ti beersey, ane a seslesce Cragmenl if Lie miele ol o medical 1: chart 1s not asmlssible evitence, it's hearsay. Rie tien 13 trayire eerkai=1v con a party admission, Hoey dont nuns 28 releeh Lie Lolalily of wal Lie conversalion ix blues: 21 patient and doctor, 2 alse, 1 wnsld alos submit that the preseripion 73 reenrdn show Leak Key are sel doctor soppite be wins 1 amoite of pille ur mecivative, Toe preccriplivi zecorse epeek 27 Zor themselves. You can cwist the namber of pills that vers SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen » 1 prescribes over o perdu ui Lime, sic juatll sdesetasd Leet © thin in on a situanies of someone heitg a dries and denter 3 cropping, someting Lakin in Una sews @ lob Wasa dave. Bo 4 trping to SUMAT LT that vay fe net caly Arrelevait to tits I case, hat the predudice ereatly citweichs whatever probative © wmlin ih omigen Be. Me. 59ST wnild met, of aeieen, shiner te To Leslioyitg wilh severe Lo whal cozzesl mecicaliv ste Lakes, © but that's a different eublect altogether. s Qiks regard to arimisel History, an 1 mentioned, 1 Me. GEUIrw die ral dw skola La warey. Se ai rar IL bugisdess Look Lie mie while de ves Livew wile fer, Bas 12 defence oninac] remiséed Geart that rhis victim in a rhief. 13 Rgain, seen oT Aris i-Cormikios comes in Leder Le Tedaral 11 Giles of Svicence. Seen bie Glargiig Covet ass tie variant 17 are classic hearsay and should be excluded. 1" Ril regard Lo Lea mel ave, Tw going Lo kip avead Ti Lo scroul tecoris, Tre records vost stor Lal she ves i 1: achoul, as mich as CeZencant seems to thick she de. They Sent 13 tavn alee wan dave she akeednd and what dave cha denstin. In 20 owsnth say ral sve was Lara on, or esawple, Map Zire, 700 21 what they do show ie that there ave fo conzees taken betveen 22 139% and the 2000 anieel year, and mn aeurses takes daring the 73 7630 ke FEE) seoel years. a He. Giiiies's allempt Lo sock aie sees scioul at 20 asether school as as a testh grader in the 2001 to 2332 schocd SUOTTAR WATRICT ATROATTRG, P.O. Prep a reoaTen 1 gear ves Limiter toe purtive on Lie evioul year stesticg 7 bemeher Tok, TORI, ending ely fn Maret Ten, 7007, erie ely 3 turer sibslacbiskes Me GELrats Leskimony hal al. ona pote 1 she attempted to get avay Tro celencant's abuse, alosg with I and mr. riguerea testificd te the samc. H cn amie, | weld Alen veitarate Hear See repihanics Pee uiile cue belie Leeanl ve @ soievay de dol veel de al issue dn thle case. fhe de a IO scmethlig year old vemas and 3 did non have a ropitabion related te har sero] atbasdaen iE Trare in aluo i Ubi oa oar videos of Far IL nel fur peosdl belies Lax cre TUMe Gol oses ens dle dn 17 cempliaten with brited rates tax rides. iE BART Ty, MeL GELTTRe Ran prod eed vol mes 6” 11 papers ur tax retirie Zils wits tie Ristrallan goversmest, tie 12 country were she has predominantly resided sizoe sie was 1s 16 yess olds Red Lnults all Tw ceive Lo say Cor Lil, Lo beep TEL bedel. 1 ML CREEZLL: Your Sener, I'm Jit guing to ascress 13 AN) af the peishe tian —= 11 Sint take wary The misites Fer, JE wile your permission 2 £0 en pedst nimber 7 that | addressed, the lesie of 22 slut, it seems like we're in agreement that that shesld he a a Tae cebate vee veer Lie Lem "proslitite’. Beals, 32. 20 aeplin, their own expert, you can see in the 702 motions, be SUOTTAR WATRICT ATROATTRG, P.O. Pret “seater * 1 Conchita that vas. ss Sdppeopriets wre. : ET. 4 then Stile be 42 that cocimest Ls in evidence sid toe ee 3 of thar word ds appropriate asd admissible and relevast, we're © on saving than than ban te bn redanked. wih ten ae1y ovampin tT Lbey vave ds Lisca's sume umnesle Ii sume dilesiel el suum : someviers, we're sot sure exactly Sov they're goin to 0 ren Wg a sb Wale AO We He vet ask hak swienes wusirel be distioetes sw Lids 12 eitzesnes bo dnseristed, on te ne that term smless it appears n Ath ragare to ftem 1, tale le tie cemsstic vileice 12 seme, med vay saz. dock, it Sas relevaser heowsse it shou we us puskliv is primarily bese os Rude KL Pe 1: cuseeces, 1 thick, that tisre's some srgiable chads of TH nl SE A I SR VR YR I Mae, 2515, sid the Statemsit at Leste iat cased the 22 worlavier repitatiozal damages was lusseied fn dassary of 2017. £1 qimetion yuiz Serer hee tur uf cusses, sort wit de tie 7 pedudicial effect. Eiere vasa't any response that | Gear SUA TITAN ARAN, B.C. reoaTen » 1 Crum cesses coiiesl sbuil @ blame lie cictim misdest tial tie 7 fury endl wry wel] adepr een hey Beard than Me. Gf:erets BATE ter Sate WEIN a GORE IRI 1 your senor hae dn rest of 46, 1 think, essentially Gncustested I evidezor, of at least uneontestod argamest of substantial © presudinial ation tran will evict wean nips desisively in Paver un eachosioy Lids, parlivedecly wien Ley gel Lo sibiedls like crimizal proceeciige. We're pein to then get into what 3 in tha seope 0 tho protective ardor 7 they Vive i Australis 10 ar Wig Vibe Lake Thala Car albald Crom any mek on 1 emoliviel distress Comsges. i” Item 17 fas te én the 1T-year-alé, 1o-yar-old, 13 Maeyerr-ali. 1 URieE we have groom Crem bole siden Leal 11 sex wath a 17 pear ole de Gdaviil Gicer tie age OF conesit 17 statute that exists in rlorida, asé we'll be asking cither to 16 cover Leal rough an esparl. wileess or Lrougt a Jury Tr meleoclion, Bil Liey saz, oh, wel 1 ate's Slows Lo Few 1: Mexico! Tie age of consent there might be clfferet. Aue thls 13 in ware | Belinun voir comer as take a elon Took ab tee 20 spark wileess on se Lea’ iabivg, Lee 107 moliow ix coreanlly 20 pending dn Zrent of you, Prefesscr Terry Conan, wie 1a at tie 22 rleride state Trafficking lzsrivite, ane we've offered him as 73 a evperh witeere. a To yun teks o 17 year ole Srum Tlurice, Sly ser bu tes 37 Mexico Zor sex:al pirpeses, it makes no difference WEAt the age SUOTTAR WATRICT ATROATTRG, P.O. Prep a reoaTen Lun cunesl Le ab lial pull beveise joo have a Secerel sex © traffiskicg avine than tar hens commithed 3 Tre same Live in Leis 17 you Tly a Viepeseeold isle 1 Bescon, or 42 you Sly her inte Vew York. ALL of those are sex I trafficking crimes, asd PEoftiser Gena: is prepared to explain © Bors tea parimilar aepest, | wild dneanibe if an a mie To geeabiun uo sacl ane daw, and aleu sume on Lie peptolugival : tecirigies that ave used to create the 1 think be refers to 3 trom ar tee ieeisible araice of soc teat Tickers iE fv wile Pave 0 erie i lorie, beso wats LL ser Lie age un coneeil, i ve hares ceseed up, dn eld 12 likelizend, state trafficking affecoe iF shots flaw to azerior LER n Raden rears to item lf, tie Cassell ad Sovaree 17 litigatien, I thick your seer asked some excellent gicstiens Hon Lak. = Be vere Lule Lial Liste ate five teesvie vig 1: Me. Giuizre's comiectiu to that vase Ges some relevance. Tie 13 Tiron argent, | ginns, if Eee streteech arpimest, wan than, PE well, ave vas a wileess i+ bral cise. Tale of co.ree, Leal was 21 a confidential depesition, so it cenlén't have anything te Go 22 wits reputational damages or something rlse. a Not. me be aloar, Meo G07 made shabowsks was ohn £1 ves seposes, sie 4s Ley sey, eh hen, you've eels X irom Lie 37 witness stad, bit last year when yoo vere deposed you said et SUOTTAR WATRICT ATROATTRG, P.O. Prep reoaTen * 1%, cals sien, cross exami fer bunt AL, Lioseletent 7 statemesr. we've “on shicerisg tn wRan sspeer of than. 3 ral, ve dont sal i Le Law feel” ard Lhe 1 clremmstances sirrosicing the lawsiit to be paraded in fret of I dwg. 12 they simply wast te pt in a dopesitics statomest te © stay inte imensisteen, amd tenis properly deme, of amiren, Po Lieb vende be eppeopeiate. : Toei second point i, she participates Zor a periss 3 of hime. 1 gins she parkicipeied £7 voitre sbpostacd an 10 wiltens ane Lesbitied, bol Leal wasstl — yoo bow, she wast 1s pety Lo Lie case. i” Wee Tid point was thar the repitatiesal damages 13 momeres Vitk Pho weal eerowit vas savicg. Saaie, ve.r 11 Honor alreasy Keove vir belt vie le te keep it Mi. Derecoct: 13 from the case, and you'll make a raling ese way of the ether on Te ELT hers bepl oul of Lie case Lies Lis bocowss + wool. Tr pelsle Bol eees 1 go. cecice he's in Lie vase, well, okey, 15 Zine. Have him testiiy and co viatewer eles you thisk is 13 apprepriste. un don't mead ko ear a1) abet Ris eealated 2 tail a Thedr Zeurth point had to do with, 1 believe, joi 22 kao, damages sifftecd by me. Giuffre. yes exestie: was, iF ZA Wim omm 1 enti ave bee bewssaripl in Trecho” me == 1 Anish 1 gus cals, well, tow core Lie vase Leeds go lo camayee? Rac 1 27 believe this is a direct quote from Ma. Mesninger. “1 can't SUOTTAR WATRICT ATROATTRG, P.O. Prep “seater = 1 bell gui that. So eves tie ceisase uissed vies hes an 7 opperhinity te artisans te relavason Tailed to do 20, f= 4 fhe sage then ber text argent Le, vel, the 3 pladstifi's exports are sing JoEIowti's STAVOMGSt:. a0 jon © enw rom sen 07 ploadienn, ma, unten nig Mellie © slalemsite. Were vidy suite Lu be proviso cess ebud viel : Maxsell's SeZamatic: Sid te Me. Giniize. 3 Tuner Kees 5 x pees b omits s Seiamebive ys sie Ban 12 vs aot yer damages. Then 4% penser a dons somthin, ve 1 ache ane others ate very Luetrietive un tit, Is ie last podst they made was that, vell, lock, these Tt cupreenbing ure Tougtve shorn siwellennity La Lime, ol ook 12 similtaeity dn the scope. V0 WR Yl OR SRNR, SRY Wave Baar Go wed Bh fr press We, Tae wes 1 delliod I the Lavetit snd made certain statements Sn Goinecticn ith 2 tne, her ther was to take care of eur oun prefesiosal 2 to cu wits seprecenticg Ne. Glicize. % 1 believe | fave tuo lest, your nencr, ad ye:'ve been SUA TITTY ARAN, Puc. reoaTen » 1 eatzemely petiel, Lela Joel lake Lio moss mites Lu cores © peitn Th. his in wien marrats relive 3 Wray may we wan Le pl Hh i ral che lork. Ball, in 1 oir view actially, that va a victory. Our geal was te try to I get hor iste the case, asd Jaden Marra raled that she could © parninipats by beitg 8 eiteers ¥ Bow, ase we ceally vuisy bo Ley Lie dmplivalivie oo 2 Judge Marra's ruling in a pro beso Crime Victims fights ket 3 organisation Filingl Fe edad on Rin, bok allowed this eter 1 Leines TL ienly, Tire iereleeanl, ane obeiossly, Fighly 1 prelisiciel bi lie seiee lial dls sudie Lo slot Lie Joey's 12 areenrinn away from the fants ar hae kere. 1” Be aie, Tee Mares sey eolad on Le Tiel a” sine 11 reasuis that ve uiieres Zor pitting those allegations dn. He 17 said pest | decsn't work, the others we'll see how things play eu 1 Tie Liligalios is mocicg Corvard, Tes Lell yoo Lie Lf goversmet will be respunsdng to odx summery Jusgmest metic, I 13 belinwn on may 15. Unt1 be replvicg ee ily 1365, fe tn 20 Vikigabio cerliv.es a Toe last pedst that 1'ML make i: seplan. Tide i: item 22 20. demember, Jerstevitz is going te aay that sovlas save that FA We. GIATTrn said enekaic Keitge. ed wn wore held beak, wall, 1 maybe ete will be a vitieee tH It's my understanding that Seylan is Tot en the final SUOTTAN WATRICT ATROATTRG, P.O. Pret reoaTen ot 1 prelzdal witiees Lisl. Magbe cozdop a break 1 ces cuniizm © tran. win iT sels men ee we witmess Vion, wele gon deikle 1 Tae last podat I weild leave jou with, yeu menor, ie 3 mazy of titer isaues are going to come dow: te balaciag. © heyivn nf misinal elevates Tor he reaseer univ seplaiced, Po veey sigiisivesl prelate, esd we woods ash Lisl sec un Lie : motions in limite ve've asked today be granted, = COURTS ask you. GANTT renime ak 1:30, asd | 10 enn, tle joo all bith ills beet covers, Lie Masel | 1 melivie. Biel co yuo Leis? i” Wi var ter senor, 1 wnild e- iE A COUNT Would ve. rakiar calen veur plat n NA. TAGLIUCA: Fu. I'm prepares to stay itil 17 temorrew, your sezor. I'm set leaving until temerrow morning, To Jul i cane vo. teed me Lin uTLarconn. Th sare votre Ti Leeilles abool Liat, 1 I tadk, your Honor, wen 1 vent threigh these, it 13 renms te we tan wn Rave daaln wits somber £73, 107, in PE eormechion wile BES, TAZ, ane VIL Tal deals wil Le 21 sedriguez, ve call At the mnavtienticated hearsay docimest from 22 a suspest semen. They sall dt thc black heck, 1 thizk the 73 Cork means argomet sbost 811 67 Kat and, i5 my view, bein 1 dose not all nest to be repeated Losey: tH esterday, ve talked abost the —— 1 can't remember the SUOTTAR WATRICT ATROATTRG, P.O. Prep “seater » 1 Gems ui Et bib IU ves the plelitiii's metus, sust ui umaibis A ER PPE) 1 make uatever showing they verted. It veld make seise 3 ell, ix defendant's 434i motion, thoxe arc some of those © dries, nn well. We ertaiely al arin parh of tan ¥ Banal may vask Lu vwles Lisl Lr Low walienly wi vows ve Bae : vhatever tie supplemect is te tiat metic yesterday. TH Gwin ra Lo Low re ow TB wonplaTE Ta bavi 3 vompeliog motivi ui lial, Tael's oofe IU seme lo am tial vas n Zo dn my view, yoix Susur, that leaves tie bifurcated 13 teil meric, whieh has been fally briefed, the selles asd Tr ve save Lies Lite 1 also bave sn my calendar thet oir moties te 15 prealidn == ar tha plain TT matin fo proctdn sling I calendaring the reply vas due yesterday, 1 thizk me, Mecavley 2 tana diffrent versie of That, and oe Srakly, © éen'e sane a Zo that's my evcwistisg ui viet ve fave tips Su 7 arpment teday, or sheslén't have argent today, as the case SUA TITTY ARAN, B.C. 1 may be, uur Humor. 1 fincieos reeves) H (roatizicd on next page = 1 Po 1” n 5 1" = 1 1” a a SOUMERR FITTER STPORS, P.O. Taetgios = 1 ErTIavoor gscetan 2 130 pm 3 A CAR Wrote pT T LEiSE Lhe detesral 1 MAL DAGLIUCA: Yes, jour soior. 1 think Me. seialtz I recuosted that wo take sp be. G66 at this pednt, which we're 5 rapper to dn ¥ TIE COURT: Qi yea. es. : ME. MEKNINGER: Your Sener, this metic: relates to cir 3 remiash Beak we evalide evideran barred an a Goesoaienan oF TE plaieLE Tt mary Doomed corcnnzions. Be asked 0 arg mel ILA un ver somecy Docemenl molivi of peslied somazy Dosemeil 17 wits respean te the oral statement en daiary 46% te a 13 reporter. n THE COURT Hole the phuie. 5 MEL MabMGA Sure. 1" TCHR Sorry. Feedlers Lo sav, Thm drewsivg. 1 Be okey. Okey. forey. Tes 1 ME. MEKKINGET: We ackes Zor partial summery Ducement 13 wits racpean tn oir Alinthis Statemech on 3 New ork Sheer PE ale Tam retereivg Lo Lee slilemerl Lal ve wise.t Ra ve 21 set forth dn eur summary fidgmest bried, this cenrt's ruling dn 22 afrlees v. sarris is direstly on peist, that a meve refereser £1 uetitite en ectivieble repetitive or sepiblivelive, Ia tiet 37 case, in Adelacn, there vas, first, an allegedly defamatory SUOTTAN WATRICT ATROATTRG, P.O. Pret 1 statemct eis lates « press selvsse hits sald, ve staid by 7 ewmeyieg wn said. AIS Siveenly me pith, wir eer there 1 that clearly fn oir argent 1 of the summary didemest metiss, 3 and platzeifs, in her reapesse to sury Sims, made Fs TS T Lhel aspomesl. Ba, Liereluce, belises Lisl abe hes wives : the poist asd ve wild ask that fo evidence rearing that 3 spies AU da sespunes Lo uit somes Jpmest molius, Liey 12 emila trv to ua tne eppertiniey ef weir respesse to this 11 net be pemities to ou su junk Ewe. Th any event, toed 13 argamests thar they have set forth in response — In TEER Tra lille losl. Peraps Loally losl: FE Bul Le peekind wena Jospmmnl Lab's sob ews dell wil; PER Ma WANA Ih er on park 67 yr Camarts a tas GOTT Tell me the oetext of the summary © samen. £1 sinber ui taligs thet ve believes plalitic: hes conven 31 hecaise they failed to respond to cir requests if cir summary SUA TITTY ARAN, B.C. Taetgios = 1 Jicgment motion, Your Sumer ruled agadiel ie us a cusple ui © peithn, bun yor comer war sleen wits vespeen to thin 3 pari. tir argumeel, argmonh Ko, 3 = 1 155 coum Rh E me, mebniNGas == dn your sling H Wear ame teat enn ¥ HE. MENTNGIR: Ou plednlio's slelemeil bo sage + ater the s WL CHAR Whe ane on a stroot iE MOL OWRETHER: TescLly. Tal in Leal slalewsrl, oor LL Chisel sels, ve sles by Lie statement, ve, Tan ceseeciie to 17 tee sraremest than we made. iE A CONN Var, yam, ver. Okay. Tim Jrh bevieg Le 11 zigize At it. fu Li a very nice, polite vay, joi're telling 13 moo failed to deal with tat meticn of yours. 1" MSL WEETHGR: ealts corrscl, your Taner. 1 TTI COURT: fe Blt LIL ul Liste. 1 ME. MEKKINGEZ: Still out there. Tiere was fo 13 rarpenea by plaiehi TT te Keak aromnch in eur poith: Kear in JE reir raspotse Lo xowmary comerl, Ley diontl meslion iL al FIRTH 22 Ta cous well, that's probably where 1 missed it. a WoL WEEKTRGAS antly. Go 1 Reick Kee Tack tah £1 teey celles to reepuis Lo AU Limi ae your Honor hee els dn 20 other cases, has consequences; namely, it's a conceded point. SUOTTAR WATRICT ATROATTRG, P.O. Pret 1 a eu thels Seblice to seeps ’ Fe GMAT ARah wan Khe pie, than Ran was on 4 ME. NEINGEZ Sractly. In the vase of Adeles © saris, fut like ia this sane, there was ee alleeccly T daeowd lial aleled, ve sles by weesylidsg ve sai. Touse : fate are very similar to cre, viers there vas a vrittes 0 copii Weak Arak vega dally vl n TED COUT: Okey. Thank yuo very min. Koval least 12 i tds Tieele small part of tris dismite, | kee wore | an rar mak n ME. MEFKINGSS Ba the Aoeleci cass, Juix Renek, 13 costrels asd says that referring hack to a Statemest, sch as a Tr hes bees prastes ws son alleges copublivativie. Su sows & 1: thts motion dn Limkoe, fe Got toe Gime to be cealing with toe 18 ribetative paint that plaihiT? barienTly snmanded frig a Toazk you. = WL Smuts sd, wer seser. Meredith senile, a Tele motion Ln Lincs Ges already bees sevioss by thle 3 cost's summary Sudgmest créer, thereby resderizy it meat in SUA TITAN ARAN, B.C. Taetgios = 1 ite sibirety, Becoreiiply Ab envnls be sommerily senies se 3 lL Te AN Ba et BRE TL Hts 1 the exact same arguments Gefeicant scvaneed Ln her summary I sdomest motien, she is acekisg rehcarisg en Ger summary © Sudgmeer morins, drereed up ar a monies 1% limien. Meey Asiees dn lide heleivl have somnezily vesivd molivie in Linke Lil seek to relitigate argamests Zrom summary J:cemest, ang I have 3 Virted six sic cases er pager 1 and § of eur repanae i 10 oppenilion. Too ordered “ine delercaelis woliors or iwwery 1 meal. Teds Coil selects Lie zpos Liab sie shoud have 12 partial sawars Sudgmest on ren daciary 45% statemest. Tee 13 lark serleren 0 Leal arden shales, Meese oF bo ori lanen 11 of triable estes of material Zact ratisr than eplilen ase 17 bosses the prelitigatis: privilece is inapplicable, tie motion To Cer cowmsry jodomerl ix detied.t Tetemdashls reileralion o Ti ber elamalory press release conlitmicg IL Lo deye leler is 12 eumetiing that tide Court Sic net rile that that de net 13 actiecable. sn shots sackicg reearion » iso imporlarilv, vo.r Toor, Mi. Gi." re opposed 21 evmmary Sudgmest on defendant's defamation in it: entirety 22 she eppescd the movies for summary Sudemest iz irs cxtireer, 23 avd mic shatemet, ar park asd pares of doandanin 41 wezemativn ens pert enc parcel of seescest's metien fox 3 summary Judgment. SUOTTAR WATRICT ATROATTRG, P.O. Prep fi TEL COURT: Well, weal co yuu sed abut Lis vase 7 tents tees cine 41's factually elatisgiishes becates here she ds two dage later 3 redveratisg her defamatory statemcst. sd J vesld alse dircor © vm tn thn carn dn my Brin®, Weenlizan v. tamoen : TEE COURT Lele Doel wel Lie Lime seams sigils : we. gomunz gure. n MEL SCHULTZ: fu, yuok Tuier, Lie emadd Lisl vest to B text cay. un Janiary 2, Eli. 31 Weebiopu ies maken Sh wher Ul Jus Genk Tet wey 1: fusgmest ona meticn dn Limine sic alec makes At clear thet gos 18 math sav, ob, Bosirn avn pores —= 2 TCA: Tre dns fn, vas La mecord slalom i cetamatery: = ML Emits eRESk tEat wns an fre at sey 2 tats alzessy bees recolies, % as BOLE: sont SUA TITTY ARAN, B.C. Taetgios ok 1 ME. SCHULTZ: Sevens AU vas denied, ju. Hour. 7 He A Te monies wns = well, say 3 MS. SCPC: Your Terr, eds anmowieg, ratio, 1 that thls fa net cases of action, It should still be acmittes I ae evidenec. Tile ds a motien in limiic to cxelide it as © widen. ¥ TOE COURT: BAL sigil. Resume sui Lie mameil Lal Lie case that counsel has given me ds accurate, and then wy wesld iE MOL SCTE TL mu whale of wise, Gelescarlls shale Ben min kn desdiy 1” Tue GETS TER Stare of mind dignir staan in tee EER n ME. SCHULTZ: Right. It saye that she stoes by Ger 17 statement asd 61d not zeerast it 1" TCUERN Wall, sve cerlaisly ix slesdive by il TE Loder. 1 ME. SCHUTZ: Rio yeur Senor, dt shove wie otier 13 teite. Wereigest this likigakion dnhedath bar tried te angi PE Lal salamat vas volt ivg Lo to wilh Lia dalumalory 21 statements. In fact, Just yesterday defendant's ceunsel wa: 22 saving that dt vas issued by her laver azd by ter press agent. 23 Aka bor shatemsekh, avd it ARie video fia in porsecally owsivg 1 it ane ene can't five bendie her lawyer or ber press agents tH Tau COLE Oh, okay, okay, okay. SUOTTAR WATRICT ATROATTRG, P.O. Pept Taetgios » 1 ME. SCHULTZ fu AL gme Lo a meleriel aspaml list 3 TU CHAT: Go Lo Lhe erat ial becowss ie inne, 4 and that's a whole otéer thlig, as to Wiether she intended the I atavemezt, 1 san sce that, H Dav. M11 rieRh. aevriee lead ¥ ME. ZCIULTZ: Yee. I'm Jel guise Lu say Liab Lids ie © a motion in Limite and there are to evidentiary problems with 3 thin pisos of cvidataa. Wein in tee dafeedart arse] an 10 camarn, Lei in tol Pearzay, av Lierals co Teseral Tole of 1 Sekdence Lael stoude exclose Lider i” Tee GE Okay. de ves wath to add atyekizai iE Mo. WIEKTEGTR: fie, Lek yo, your Toner n TES COURT: Okey. Thank yeu. 5 sat else: 1" MR. PRGLTUCR: Your Tovar, we an Lava Lp Lr Ti biliccalior dss Lial's presesles in 882 and 388, ane Lies 15 there ves a reply Siles last eveniig. 1: we a ver. » WEL PRGLIGCRS Your Toror, T Lritk well, T dost 20 thizk, whe lav de very clear en this deste dn this cizowt. 2 racer gpa = a WE COURT R11, 1 Eek wn an sherk Weis. a MI. DRGLICCE: Tee. tH Tau COLE wes, ges. Maxvell's money doesn't coms in SUOTTAN WATRICT ATROATTRG, P.O. Pret 1 un the Lisbbilty cess. Taeb's jus pusitiva : We pan Ta i my peririns, wir mr PRET Tp— H Ma. Gasssbt all Tight. Thask joi, Jour seer. : or problem, a ial, ir, vet, See sek wore donnin Toms in eb Lis Lisbidily stags, bob T Lick Lis deosiect ie : taping to get the camel's Sose wader the Tent aid say. oh AZ Ir TU COURT Ball, T don boo wal, Cieaveial fase 3 guimesn Bets sayiig ho daltetilius ui ber Clee bil 12 i, ow wink menoy Shea dot or were it ames Srom or anvtRing n ME CRESSMLG Be © incexstan ths metich, 4t's with 15 refereser to her “Simaeial statist “ TR CORT Wally T Junk hati vas wal T Lik Leal. Me. CREEL Thgnt. Ae 1 tdi, with the TH HS A A, Ve TRE Bi carcmroad abot, Lx be, Bul. bak we be alee a Tau COT What weds yon dike to present 2 Mi Eaifals Ewe enw three or oe thiser ur weil 23 Mika be pesah. 17 ymin Fear ilo Wak Mo, HTT tax £4 complies cei go to ber cewelbhdity, toe ve voids Like to be 3 able to reciprecally say, all might, thes Me. Mamwvell's tax SUA TITAN ARAN, Puc. 1 complisice, 1: Liese de guesbivie sbuit Lisl, wuuls be © rredied. we thik thar where stecldin be ras som inee 4 well, that goes te her crecibility. What's good for I me. Giaffre shesld be good Zor the defondast. sit again, te he © mlean, wn doth wasn fe Ries HER Sehe 8 Rav eeiali ee wash in Tle be a ceoamsliv Ledel. Bol Lisy've mace an sciomeil, Les 2 decuee are relevait to Me, Gizifze, Tees ve voild like to have 3a parallel opportininy Kren with aspect he We. Waeall. 1 Tre alter Lit we fave, Tor esawple, vetre Allagivg 1 here's vivenicstive Liab ds payicy viele Lo give sex to 12 sporein. ane whe's makizg the pavmestsi well, me. Maweell, 1 masedsn, wesre sists dn cares of tee 5 tea tovin well, that's édfferest, 1 TOI COURT: Teall sol her Citenciel sles 1 MIL CREEZLL Right. fo that's not her Sinascial 13 satin. Gor ovample, en with te shee torn Kisdn of pavaests 21 other girls vere not coming inte a bungalow in the middle of 22 aohoken or whatever. They were omine inte a massies in ene of a THD COURT: Well, that's gut sotilig tu se wits ser 3 fizancial statis. SOUMERR FITTER STPONRS, P.O. 101 Taetgios 1 MI. CRESEIL: BLL rigil. Well, ve Liwigil, wien ve 7 filed mir respnnan, they Aerisied to opens iE. 17 whey Bad 3G Lip.lated, vo. bow, Tee.ldetl be Labicg voor Totorts 1 time. E 33 this ds where 1 thik they're taking a arrow © mmm prizeiple, ten Ser en werts danett com in, aed see veins Lo Ley Lo cee db Lo sade svisenoe Lisl He. Hasvell 2 ie making payments to the girls, that this mansion is a very s COURT WaT, okay. 1 donth LEER ro iE MA CRSITER: Tel we Joh webs wire Lil T rave on Low 1 lable Lie Lidige Lisl ve veil Lo dolovsve. i” sor example, Mr. spsteis purekased a Eeliespter for TE Me Mall, aes Ley mich may, on, wall, Leal sows Sisaseinl 11 static ur sumetidig. Be LLisk Liat shove a very close 17 eemneotien. 1" Ball, Lee lash one uw partaps Loe worl corlroversial Tr ote dn corrective wilh Lids case is Lie Lowtocse, TL ds ut 1: belie: that a 1: He GUA Wel, win mitite. WRaRts ta basic of 28 yor balia's a MIL CREFSLLY The basi: Zor cur belie: ia, 1 believe 22 waeyter cozocded that there war a sale of a 317 millien 23 howbouse in 2G1E a TEI COURT: Okey. Ie db bow seisscente toviivses? tH MIL CREFSLLY Yes. fo the gestion iz SUOTTAR WATRICT ATROATTRG, P.O. Prep Taetgios ue 1 TID GOETH Eu Lael perl on her sel rte. Tomes, © tmants par of ree Timateinl part. | dee'n sen Sow than gens 3 bee bea LiabidiLy cane, 1 MAL CHEEILLY RAgEt. £0 Tpetels was the oie vio I provided tic leas to got that — H Mean save wma ¥ MR. CRECILL: Me. MeCaeley, wiv Louk Mesvedl's : ceposition, is acvieiny me that curing Maxell's cepreiticn, iE TU CERT Wall, all rigrh. Ohay. Sk Lal inet 1 Chnenciel dsietmativn. Thal's lie selelivietip betwee: Maxwell 1° ane aperein. iE MRL CRASIL: Righl. TRIE ve. and Tare ov Lee 11 came page. My concer: ds tat ve may, a on tier leciss, may 13 met be en the same page with the defendazt. 1" TCHERR 1 dont Lniek so, bol maybe Thm rot. 1 ME. CRESTIL: There's ure ulter poisl, ii T can isl 1: be hears en the towsioise. Tie townioise vas sole at a time 13 srertdy ather e. Maenll i Gicminsiog wits bar advisers, tev, PET Got gel sued Tor Hibal. Oa believe Leal Loans ereivg 21 37 millics esteide the Jurdsdietics of your senor 2 ms GOVE Tell me shout that after yes've got a a MI. CRESSLL: BLL rigel. Sut we vent to dntrosice it 37 caping the trial to show conselenazess of gilt, that ale ds SUOTTAN WATRICT ATROATTRG, P.O. Pept 1 tieneiesriy serie svey sium Lie Jzdeciobive on Loe veel Ta 1 Mi CAESSLLY GRU. ASter she wrote an email that I said, hey, 1 eeuld got —- fi] Te GUS ve ant are, | deste ERIE, tRan To Liable an sdmissivis : Mi CAEESLLI We believe it goes to conecicienees of 1 FLT LE yoo fave 4 CHIL wil Lal sual] 1 piece vn ves ssgomenl, Toman, T Ladik Lie evel on AL de 12 really, ve: knee, tie meat and peratons kore, ane iE A CoA okay. Yer n MA. TAGLIUCR: Yuir Renz, I'M going te et try te 17 belabor this, but 1 have to respoad to some of the points, dust ww Tie langage Lial ve proposes Lo Lie Coel abu. Lie 1: zizenciel statie comes Zrom tie very cases tiat aze in the 20 zm rillery: bo evidence a: to defendant's financial static 22 may be prescsted te the fury curize the first phase of the £1 Circuit cays tit Laet'e Los preieices mebios, Mio Casesll, 1 20 think, keowisg that he's losing this battle, thes tries to SOUMERR FITTER STPORS, P.O. —_ 11 1 change it, 7 win Siren of 11, dents walk ahoin thin sesssiniasens BT CR LT al i SRR A ANS 4 bit the law tat they cite. Tiere are relereices to a Few York I rest article that ds the == H Tea LS UR1Y, SRaRte =a gong, choise ¥ ME. PAGLICCR: 0. vu.zew. Biv Lien Lisee's reference to hacer frlize. That's thelr satire svidertiary 3 Baris Ter Lhe proton Leak they Tinh made ke you, voir Teter, 10 aoc Leb oweromss TL doses th Tlys Re T dort sees Le nape i” Tee GET Well, wait a mite. There was a little TI Bil wera. Tears wan Mawall savin sen cel loss, Ley sey, 11 Crom Spetein to biy tie heise. 5 Mi. PAGLIVGA MEAT she sald, your seser —- asd | 16 role iL cows boise T looked al. Lie daposilion Leavsariph Tr leet nigel 1 Tizet ui all, 1 taiok it's important fur tide 13 dinmirion, wn allound miaskions rolativg he ampkig Titaseinl 20 wile Me. Tpaleic. Go bre one ieskr.cLios Leal T geve Lo 21 me. maxvell during tide depeaitics vas, anything they ask you 22 abest spotedz dn fine. Um zet ening to let vos talk abet 73 your ows parsesal Timaeinl i-Tormakios boca.se PLU ok £1 wlecoverable sb tide polit, Ba eo Liey hes Sel spportoaily 20 te ask hex questions. They asked her questions abest the SUOTTAR WATRICT ATROATTRG, P.O. Prep 1 toviiome, ens sie cele part oo IL ves = dues irom Mr. Spetels 7 thar had been paid hack, asd thats eeica te be years ann, 1 Tat's my saderstasciny of the factual basds here. H #5 ve can 1 thick deal with that partieslar issue, yen © enw, AF and wens in comer ap, bt wean Um avice 0 Hen © Comtl 1 mean Lhe Sunrl ent Tacs un Lis seme pepe Lie sale of the tovsieme, the amoist of the sale of the towsiome, 3 vel beow, wal did or ide happes te tho meray Trem tha ale 10 07 Lie Lowsrome, Lose are all 07 Limils driv Lia Liability 1 phase ue Lie Ledals i” Tee GET Well, Anrrent me 7 I'm wrong. we demir neal 5 Mi CAGLILGAS We Gent, 1" LS TE 1 MR BRSLICCR: Tames is foie. 1 TE COUET: Okay. 1 Wa BRGLIGRE md ben Senies Kak thin mney enor 20 rraskly, less 4T WEST to some SUILGEY that 4'm unfamiliar 22 with, 1 thizk the furiseistier of this seurt extends preeey a TED COURT 1 tadek Let's for entices sey 28 Mi BAGLIVCAD HEE. SOUMERR WITTER STPORS, P.O. Taetgios we 1 Tae last polit T waa to make, juiz Sunez, un take © imme nf ensniminess of Guiln velates te the on mann tear 3 Ley ile or Lhe proporilion hal Ler is sows sbilily Lo 1 have a conseloseness of guAlt theory in a civil case. Tiey I oite a soeond Girewit criminal case in which the defesdazt was © aman awed ws. Weir Aran 71 3d 1751, avd inte a 153 To Gase. Me. Bee ves @ leaves ii Lie Locvtess ceime amily who, © over a coures of time, ordered 11 murders anc tien sbaceided 3 rom tre jurisdiction dirivg tha trial of a sumber of 10 comdeleriarles Ree iL war called "Pe Miscou Gaze Fare © LL ew Turk, ei gus mey semesbes il, jo.s Suis, Lecases il ves 12 rhe entese anime family thar was ancerellisg the replasemest 13 vinden in Lee sily 67 Kew ork. So He. fase Goes Lo 11 trial, an tee goveriment regiestes sie receives an Lietrictic 12 to the Sury that said net only his flight vas consciousness of TH Guill bil re lenis of Lea absaras of ia CLigh ws Tr coreciocstess ol golll, Ree dn fact, Lie Secose Sircodl 18 reverses that Lnetrictic ane clespproves At in that criminal 13 mann bin didn revaree Bir sovintins heswir tha neidatan of PE GIL van pearerelmive. So Lie one case Leal. Luey eile Tor 21 tide propraitien fn fact i: inappesite to the peaitien that 22 waey'ee takize hore today. a So 1 kk your Comer and 1 are sdeed on Lin same 1 page Gere, ane T' ack tial Use Suit elmply apply toe lav bo 3 millers. SUOTTAR WATRICT ATROATTRG, P.O. Prep Taetgios w 1 Bu Me. Mesiliger remiie me, juoz Sunur ane 1 © wRitE te Gorn and | are 6 tee same pags on Ris as well —- Be a rg mati mise by Me. Cannell. Tedead, Meo Wawel] ied 1 the plalstiff are nob on the came Sorting in thls vase with I regard ve win pit their ropitaties at issue, wie is claimisg © emenineal Aistenns damanen, ad PlaieRiTS ave i= a mis Po icereil posilive Lien seosiisile wien il comes Lo rose examizatice abeit these dssues, particularly in 3 dnTwminion carer, becwine as We. Messisgar peitiad oi cartier, 10 Leder Role Az, weerglring Leal inpacls Lie plaislicf ts 1 sepelelive Lo Lie vomncily, bicleiog Lie sails Lo sullor 12 aw, iz tho subdear of arosecxamizatie. de the aremest 13 Weal wal in ond er Lv gears in goad Car Lea qasder iv a 11 cezamatic cae elmply coesi’t apply Wash yoi're talking abuit 17 damage issues and vepstaticzal issues. 1" Trak vo, your Teter. 1 ME. CRESTIL: Could T Jel have 1: secusie, yout 1: semen: 1: we a hn 2 WAL CRGITILE RIL rigrL. Tacks 2 Ths COLI Next, 2 Mi. PAGLIVGAY Yesr meter, we ooalé next take Sp the 23 neue rolakite ke ke police rperts wie 1 Rave an 1 ceensant'e moliv Ln Linbie Lo sxclice police reports ase 27 other inadmissible hearsay at $77, response at 147, asd then SUOTTAN WATRICT ATROATTRG, P.O. Prep Taetgios i 1 reply ves elev cilec jestezsay. 7 Fen ven okay. ven 3 WR. PRGLIGCR: Your Torr, Lrara reporls, Lu are 1 loosely describes a: pulice reports, encompass a oie year I parported dnvestigatics by the ralm scach velics Jcpartmest © iehe tee aTTain of Me. aperis nsgnly hegissie | RRisk is AEs nd gedag Lisu.gs 2006. Tae veleclive dniliclly sesigies © to the case was a woman named Micielle Tagan, aid then 3 eteative Seaarey took over Ke ivestigakion Crom Me. Page 10 Truce were 4 saber of Lhing, according Le Li eeporks IL alluogi ve sun'l seally fave sy acloel wiliees Lesbinoiy, 12 wins murrene koeeledoe. The peline £1 a wher of This. 13 Weep sevilla Tpeiaiste boos, Ley 18 Lear pole, and 11 Gitimately they ekevilec a search varzast at Me. Speteds's 13 hesse, And that's sort of the totality of the Lvestigaties, 1" T give vo. Luk an Lie backirop, vo.r Totor, becs.ne Ti Lier esl vial seems Lo teppes iz very vocivos, img 1: experience, ane vas testifiss to by detective fecarey. Tie 13 pelimn nen arorenve with © state atker-eyts 07s ic 20 Tlarisa, ave Lrere ix complete dizkesl balyaes Loe lo 21 agencies. a: a result of that and there's a bunch of 22 sm-fightize that encs en betwee: these twe acezeies. fhe 23 polio mike ten decision bo, in some Tartine, hie over £1 weerylidig tial biey cers Lo Lue TSI. Bao ee beet 1 ven Sigiie 23 it eat, the SL issued a grad Jury subpoena, of the Lf. SUOTTAN WATRICT ATROATTRG, P.O. Pret Taetgios s 1 Bttusiep's Sails, Lo lie Soobiess Dletzicl 6 Tlorice, dees 7 A eranA fury sdbpesta Sor the cewivery nf rhe pale seach relies 3 eparlmerlis evidenes relakicg Le Ure Tpaleis dvasLigalio 1 fo a: ve eit Gere tossy and ined Zor the last ten years since I 2006, tho ralm seach roliot Jepartmest has net bees the © mintedian af amy of thir evidesen ¥ Fu su Lal's Lie cavload bachesop Lu Lis vial becomes costiniing problems wits the types of evicence tiat I 3 artiaipate Ke plaiehi TE are Goitg te hey be iskrodin in tin 10 Gann Tow Ciel bn Lincs police reporks Lremoslvess Red Lal LL de dbuil £7 ur 22 pages ui socamenle, Sepeilig ui whic 17 iteration of these police reports semeose is lokitg at. Tar 13 asmarbially mor regs Le course of Lhe ieveskiabion. fed 11 Im eure tilige that gens Senne seen beiore, jon Kavu, pelice 17 officer docs scmetiing, they put it down en a piece of paper, 16 somebody pole iL ivle u syslew, avd Lee Leable were iL oss: Ti BLL Lie problem tere, Ctcameslelly, wilh Liese police 1 reports 1: Tou GUAT bok mn back Gp Tint a moment. » Wa. PRGLIUCRS Vas, sir. 2 Tau COLIN mew are these going To be entered dite 22 cwidesoei They're met self authenticating. a WAL PEGLIGCR: Peete ol a TES COURT: Eu cow ere Ley gulag Lo be preesites? EH Mi LMGLIVCAD food question, Jour senor. SUOTTAR WATRICT ATROATTRG, P.O. Prep pres Taetgios 1 HE. MCCBHLIY: Du yu. vesl me Lo escives Liat, jour © cemari meas, ints eur evidean Ran entre tevieg te gen it 3 edo vo. wat me Lo wilt 1 THs COUPT Well, ye don't kiow. Tee defense doesn't T kmow H LE LE T pressil Lives Sovomeile, juot Sues. : Tas COUT Wee. Okay. ALL right. Secase there's 3 co El witeens listed. iE WAL BRALTUCR: Meare ix co record coxledia ak all Tar IL Lieee socameite. Drleclive Secarey do ids sepusilive ei 17 wes awe thin, the relevate answers to these miestiets —- 13 ambessladces Leal hey fonth aus any 67 Lei auidaen. Red ro 11 that’ geliy to be, gon knew Jui have sesh, Ln miltiple 17 filings frm thc plaintiffs, they attach excerpted comments Th conlainivg shal Urey may are prove mesmaes sec.res rom Li Ti Least polls. fo lial wold be en exemple of ecideice for wich 12 there de no zecors wistesian. Frankly, 1 sent Kaew wie the 13 reiran ef amy of than i=fermation in. Phir ir yon avertar 20 piece 0 i ermilion Lal ax appeared, Thm presi bro qr 20 mr. sdvarcs getting it somehow, you uow, in Zelatien to come 22 other case azé then it apprars in disesvery dn this ease. And 73 wan ih looks like in, vos keew, 4 cmbor 0, ve: keow weal £1 they cay are protocoples of messave pase Szom Speleli'e Lach. 37 sat there ds fe persen whe will say, this particular piece of SUOTTAR WATRICT ATROATTRG, P.O. Prep on Taetgios 1 paper vem sion Tpeleic's Lien Lo lie Sliel Listens, Teese © in me pers tan wil] sav, we kept tones dommests and wn hav 3 Le originals and vo. as coms look al Liam avd vo. cen Ler 4 them ane feel tiem. There ie vo perecd that will say any of 3 that hesazac AT west te the grand Jury and preawmably, sader Tin 55, ins sevnr momin ein 0 tRn grand Suey amaic ¥ So Lie ulies point sbul Lise mesesve pase do, 1 © dent to this cay knew vhether that's Just hand picked pertiess 3 of wakever plaieniTT coisa] got years age or inte Khe 10 wrlively of wal, yo. brow, Palm Teacr Gi or ¢idrL do, bol IL wien 1 sekes Selective Sevag Lise Goesbivie bo bie 12 deposirion, Be said, | eaztt tell yes 17 thants cverprize. | TI url Gal aed hie SLT by plaieli TT mera], ve. Yeo, in 11 tie cuizes oS bade cepeeitici, ane that's all 1 van tell yen 12 abest it. fo that's anetier piece of thls that's problematic 16 Cer Lhe plaislitte 1 There's arolter izes Lil relates Lo a Learscripl of 12 a vitoess, Me. Hall, an tie plaiitizis, 1 think, wast to tzy 13 to imkredien tan traceariph or, altar-ataly, what they sav in 20 ae usaio recerdivg oF ar itherview wile rar, ang Thm vol sre 21 widen they are trylig to intresuce, but there are problen: 22 either way, rie trazeeripe, what © will sall the sall 73 Krassariph, wes in Tach -oh prepared by tea Palm Aen Police £1 Department. Recuselag Lo Detective Tecersy, he nes sever ems 23 it before, duricg his deposition, asd he surmised that it had SUOTTAR WATRICT ATROATTRG, P.O. Prep 12 Taetgios 1 been prepares by tie slale's attoriey's wizioe Lut Ge alda't © Kem. én wan Sappens the wits tein trasseripn is, teere in 3 an ubhewpl al a dopor iio Ma. Tall i= Mim, Lvix semen, 1 and Ma. Hall comes in ane she site coun, ane she Goesn't wast I to acawer acy euestioss about asytidsg, and ale says. 1 don't © remember atysisg abesh any of £hin. one lmewnr save, fo Po eentl cemenbes siybiing abuol sy un bide and sie spel Lie © last ten years Zurgetting abost all ef tide and aie’ fet golig 3 to remember aybhiog about, Kir. Me. Gdwards hon pike bee IT Leweneripl 1% roth of Fer asd sve coset tL look al Lo Se IL sumentl ween Look al Lie Lissevzipl, Sie somen'l Lozi Lie 12 pane. ste docsnie read acy of dt. There's a miesties asked an 13 nome pail lakers Teeth ik kei Leal avery ieg ve. said ie 11 tie police cepartment vas tris? Ric tush shurtly acter that, 17 tie depeaition ends. And they're trying to say that that is a 1 et ieienh well bain and an eviseslisey basiz Cor Lie Tr eemieeion of Luis Lrarecripl, which de, yo. hiow, -apussored 1 beatasy. 1: Aharets a imilar problem with this reserdieg heswion JE Me Tall sever lished Lo Lie recorsive, secer a Lreslicalas 21 the recording, And so there's So evidence vhaticever that it': 22 Me. mall's statemezt or that it was subdest to any a fo to ey to get arouse all of tases seloestiory 27 problems, ow what's being advasced by the plaintiffs is, well, SUOTTAN WATRICT ATROATTRG, P.O. Prep we Taetgios 1 we're sob siterlig any ur bide Sur Lie Leith un bie melted © asserted. in 31 pages of peline reperts, a uedred panes or 3 ower wary Liars are oF Leash, yo. bow, eileen Lesseripls, 4 no, me, He, 6, Gene oF That de being ciferes for the trath oi I the matter asserted, we vast te offer it to show He. Maweoll's © state nf ming whee Shr ines er tatemer Heroic We. aries Tees Me. Gur. So Lie fege peoblem wilh Liab, gues Tene, widen we've alreacy dealt with, is, Me. Mamvell fae no knowledge of 3 wRakts i ere police reports, Hho Leash pila, any ef bres 10 Leingn, an 0 an 4 Waller of law, Liz castle perl of Fer 1 state ulmi, i” War dz d=strierive en ves point, Geir seer, | went 13 am een every ingle Gane Leal plaieli Ts ceueaol sited Ter 11 thle propesiticn that At 1s state of mise, and wiat's great 12 about these cases, fraskly, every single ee of them, wisever 16 Le slalemsrl ix being inbrod.ced or etal” 07, or minal, Ti ios abuol Lie slelemerl, fo wher jo. look al Lieic papers, 1: they cite Unites States v. Gottd Zor tie preposition thst it 13 cons be chan 0 mite. Well, yn: keow whe He lobed in, amd PE Wr. Gobbi war erred wile wiles Lomperiog. We. GolLi ware 21 to datrecive some iretapped statements That The £31 had, where 22 mo was talkize to az informe azd tolline the informant things 23 Krak Gobbi said week bo Rie shake of mivd. Wall, Ke Gocond £1 Clzcudt cain, yee you ven so Lust, Mr. Gelli, fizet ui all, 37 because the goveriment's intredueiig PArt of these transcripts, SUOTTAR WATRICT ATROATTRG, P.O. Prep wm Taetgios 1 anc secuit of all su thal'e & zile ui vompleleiess, sid 7 armed af a1, yo unre there ad yes Seard in asd sherefere, 3H wee go Le voor sale oF wind aed ol Tor ka Led 0 Lia 1 matter asserted. E Thc ext case ds Lnited States 7. Jipree. That's © ameter arimieal ease in tei eivesin, were a bask fra Po ensenl ves Lie sublel un a Lewpucscy ceslisiiicg wever seed to that cefendant, okay! fo, you kuow, Ge has a 3 hemperary restraisieg order, yo cast hake ay mosey ook of IE Leis bark less joo Go XT. ave 7 Bell, be Look Lie worey 1 Gil un Lie beck wilionl sedis XT, ess 2, ei ween de vane Lo 17 trial in Sin erimical ease, ton gewertmest was alleecd to 13 ieheadian Lal resteaicieg erie bodies iLowar Sie resheaieig 11 orcer, he Kiev abuit At, ane At shoved his VILLZZL dStent te 13 defraud as part of the bask frazd, So that's that cast, 1" rise Records, WC v. Line Group, TIS war arolier Ti cee Ley tely vii Tyain, Liese are smells lial ate beity 15 talkies about tet vers written by the celencant's employees aio 13 teen tea rarpeeer te there emails. an mlearly bn dnfenianr 20 TIE rau corperale browledqs of Lrose Lricga. Gersersrols 21 suftuaze programs, statement: made by an agent of the 22 defendant, those are all the thizes that we're talking shest dz 23 Keak cars, and re Karas ankial keewladgn of Kea eehiky oF 1 those statements, widen then vas go for elate of mize tH Tiere are two more cases. Creanenz v. Penguin Greip. SUOTTAR WATRICT ATROATTRG, P.O. Prep wu: Taetgios Lene lie ves cage, Al's cilepited Lie seseient hes actiel © prior ¥revledae of the Snes, 0F thn at-issie statemons tear 3 ware o™ared by Lhe deterdich, gain, Le slalomerly ver wide 1 to Crescenz. E and thes the last oace ds a Lid case, Mersey v. © mwigrem. wean iuelued mivil rigte wislatiess and shirative ressutablesess by Lie uooivess wv cusoled o sess un a © bullédng, © thick the Court kiovs frem delip this kind of verk 3 beak pronby week ayiRing is an otTiearts bead in allowed ina TE Gealitied tmsily case, bucase wrelier Lie officer ci IL sumelibi Lieb ves ubleclively seasuisble ui sol sepsis ui 12 whats in the effinerts brad, and se ther iz (a) an exeeptien 13 ie tease Kindo casas, Buk (3, §- Chel, bee vidoe Leal 11 vas being slecieses dn the Giallfies Mnity eitiaticn relates 13 to statements that the officers had heard, whieh formed the 1 bari of why Lier wel inho a building 1 To it ea an esery vie ol Less veses an all cases 13 that ceal with state of ming, the peracs wie it ia belie 13 inteedinnd aittor Tor ar agaicet, cen er fe tris ef tee 20 miller asseries bol Cor Lair shale of mine, naz Le brow bol aan 2 10 have ateacied te aur reply az affidavit frem 23 We. Mareol] wre rays shale cover read ay of tease polis £1 poste prive tu Jeseery 451i. Bes Liens de pews seesun ur 27 that, geur soner. It's Sot easy to get these police reports. SUOTTAR WATRICT ATROATTRG, P.O. Prep 106 Taetgios 1 Be guotes tears, lie chads ui vietosy bends ties Lidige acter 7 ZEEE Sn Vieele skereby. asd, got kee, ir reeves sew 3 eter. Red se, vo. brow, ordivary Telks T dosti bolic wre 1 going te be, joi kiow, FuGtisg around LEyisy To Serzet eit I pelios reports from south slerida, sven if you get them, they © are mravily eednntad, anh fe wine oon leeks at term, iRin T cieleally impuseible Lo Lell who's ab leans, who's sapity vial abut whem, because there are lots of blacke:ts tireugh these 3 police reports. Wa menaced sowstow = aed Traskly, 1 dest TT meet brow bow Lo Gel a% Sredacled copy, are Jeleclive 11 Recazey was s.tprise ven be sav Lie izesacled copy becaoss 17 ke said, we alwaw rear these tRitar. asd an I'm welear an 13 he hee aoe in redaction, Bk i any suenl, ars is eee 11 there. But T son't knew Lev ve get At. 5 Tae other point en this, your seser, is, again, thers 6 i ows libarky Laker iv Lia pluishi®T ts papers abo.l. wal Ti Me Mesvell seit vr len'l sey i ber deposilivt abu l Lise 1: police reports, sic tisy try to make Gey ever, she kis: abut 13 ten plies roports by the releative prasestario of than 28 ueporilion Leslimony. Red Thee eile Lv acloal cole or vo 21 in the reply brie, bit wiat i: tetable, in my view, 1a tiat 22 wien me. maxwell is peesested with ticsc pelic reports, it is 23 for ken Sivek hime ak For deperihios by Me. Matavley, and tears 1 le an exchange fn toe tranecript viere Me. McCauley as 37 Ma. Maxell are going back ad forth and Ma. Mameell sags, you SUOTTAR WATRICT ATROATTRG, P.O. Pret ur Taetgios 1 keer eee solelig Lies pulls sepurle sid se sage, Tokio 7 there ina police repert. we gn ne IGT pages or an ie een 3 deporilion, wee iL ix €laar row Lhe Leasseripl Lal wes vo 4 get back to the police report fesse again, Me. Maxwell i: belie I asked gucstiens by Me. Metavley. He. Mesawley says -- asd this © iran pane 155, Titer 4 termi 3 = how teat vos Sawn ten T pulive epost Lisl T stoves yuo Lids mosiiag Lisl joo ted en uppertinity te lock at 1t,* and Ma. Mamwell responds, “Yeu gave 3 ih tema. © did con leok ak i. Ged there was ce really 10 olrer gimekioniog al Lie deponilion abocl Me: Mawel |i 1 keweledge ui Lise police zepuzle. i” dn the record on thin die, your senor, whieh in 13 coin Le eoninn Lo ba Ln record, fn Lal We Maal] ha wo 11 kmouleage of tide police report, tie Livestation, ssytilig 17 that's going on with Mr. spetein sshstastively during this 16 ieveskigalion by Lv Palm Teac Police Jeparlmarls Go Lalla Tr wg ile tol evmissible. They Ley Lo cobble Logelier vial Liey 1: view as sort of ducicls of she shoile Gave known bust wiat's 13 in thar police reports, av toy Tien at all say = un get JE back Lo Leix Tersrouils Jolt selene cramer. ine, wien 1 21 touched on yesterday, but jei've godng to hear it again today 22 an i think e's wore: mentienize again. Ane here are the 73 woken eankly Trow Me. Darshedite! deposities 0 Mp Demecowile eumebusy wblecte sedis lide sepueltive, ess 20 then there's a collogsy. Toere's an assertion of privilege. SUOTTAR WATRICT ATROATTRG, P.O. Prep 1: Taetgios 1 Tassels s Little BIL mere colloghy, sie Lies Me. Derenovile 7 saya: "Reis sn lone vine aan. My reeslleerios fn wha very BERRI (Bah JT BS BY 1 the people who vere of interest to tie Glatriet attoriey ae to I the federal gevormacit. That's my recollootien, And 1 vesld © pe1y wank ko ereolun Aeihs i= Savor of privilean.t hee To Me. Dessiowile seyei We ven vievh soebies. Tweed be demy © to answer the giestien 12 it's net privilegec." That's the 3 testimony Kal they say supports teir asserkios of this jain 10 celetne soreemerL wile Alas Jersrosils 1n Bol Liwsete more, yuo Suir. Mi. Sucesse sped, 12 whe dn a party 4 eis depositien até er a lawgnr == shims it 13 be tre spesial master and Me. orseewils Wh. Geislaiee 11 Maxiell vas never tis target of tie duvestivativn, vas ener 17 confirming ad arguing that Jersiowitz is wresg abest this 16 Jeink deerme agrecwerk al Lia Lime. Fed Jarshowils is Tr eomillicg Lial be dossn'L ceally bio ax ve shold creck ane 15 we'll get back aie people can ask these giesticne 5 I'm wrens 13 abe mir agreement. » Treg alo Lave |iberly wil Me. Masel 1s ise snion 20 in ter depoaiticn abest her knovledge abect Wiat happened to 22 me. spsteis and what Be pled gxiley te. wees you lock at these 73 pager 07 the Lenereripl, vou keow, she rave, | keow be week te 1 all, ane tien toeze's a back ast sorts betvess Me, MCavley 37 and Ma. Maxuell ahost what £46 he go to Jail for, aid SUOTTAR WATRICT ATROATTRG, P.O. Prep ws Taetgios 1 wewalially Me. Mexvell ssye. jou kau, I'm sob really eure viet 7 been re Gail Tor. In ad somestitg te fo with, sh 3 Wks == MeL Mall == Loatage preskilbion or L-derage 1 prostitities or sometiing Like that. That certainly doesn't I give you tic ability thes te ram iz 400 pages of ucorroherated © Reaveay under thn iden than sowhou HRin An Sorin te femehody ¥ Bi T Lidok Lhees is vie lier _acloel vlan Lal Lisy make abost, you know, viat Me. Maxvell shoslé have knows, widen 3 in vet the kadar. Th is oh incubate as idiida 10 celenial Lo go ireeslicale Lritgs. halts ol Lie slasdars 1n TL seems Lume Lal Lowy here cuivees Lal Lives 12 ommentz are Eearsay heeioe they're savisg, we're sor 13 nrtarivg Lem Tor Len Led oF bo miller arserlad; we wank Lo 11 uiier it ser tide keovleige tieory fast ve ave. 5 £0 1've briefed the issue abest business records, Tien Lay are sol. The briefed Lie isa dboul sovermarl. Tr police recorss, wich Liey ace police tecorcs, bol sseeslielly 1: the same tests Zor bisizess reverse applies to police recorss, 13 wmien ir, wn ave te be dar a buritaes Gi to reesnd Ho 20 ie ormalion, ano co.rl aber co.rl ler co.rl 4 Ler Go.rl, 21 across the country, has ead, pecple in police reports, like 22 witnesses, are mot under a husizess Suey as pare of the pelise 23 department. Ge all 0 Keone shabemehe, Gee seasde avd 41 dssnans deezeey eletemeile, sre liesnlecible, witier ac 37 goversmest records or police records of WiAtever yoi wat to SUOTTAR WATRICT ATROATTRG, P.O. Pret Taetgios =e 1 call tiem. Toey'se Jiel simply lnecmiseible fur bie Lrith uz © ten maneer asserted. ves Kew, there may be a Tee whites in 3 Lene police reports Lal somsona co ld, 1° ray had i record 1 cistedisn available, try to cifer fate evidence, bit ve Sen’ I have thar hexe. z bm zo | RISE fhe al 6 teenn wearer, vir ener, Lie de a very sleviy mobive Lisl shuns be grenles by Lie : wre, s Wi. MECHOIAY: Good aTkaront, your Coser. Task vo iE Tr reason why Legh re balLlivg so bard on Lin 1 Coram de becase AU's su critical Lo lie vas. Tais ds « 12 police report thar reserds mameress, ever 10, sndereace mizrs 13 mavivg virk.ally ee col same slory Leal my oie gave abel 11 Ler sie, ver sie Ciera over again. Feat tay slen't say 13 to ge: —- they skirt arewnd Jetcotive iceazey. Yes have his 16 erbire deposilion Lessreripl, wrich we've “olad “or nel weak, Tr wile all of his Leslimoty. Te Look Liese slalemsile, Fe werd 1: threige the bisliess Iecorde skeptics with him. He valkes 13 ferent, ver, | reaeréed thir i tin amine of my werk. Gatun 20 gol iL i= bur papers. T dhe rin Ler my dolys Tiberias 21 these witnesses. 1 recorded At, ete., ete. ete. all in thi 22 comment. 1 mean, with fvery dosment that's como up, they 23 alam, parkindarly govermet deck, Kis in someting £1 that we've Zuon wit of tal: alr ane Liat AU hes fo value to At 37 or tristuertiizess. ae sat in his depoaitien as the detective SUOTTAR WATRICT ATROATTRG, P.O. Prep 1 Taetgios 1 who heciles Gide willoe Lovestigative eis velkes Liruogh sac 7 of thee prople, Your cptar, asd walked Hires Roe bn reaerded BONCR REL AES AAR Ti WR 4 detective Tecarey, who le a witiess dn thls trial, on our trial I exidbit list H An be ery lear, thin domimest in fe AriEiel Beawien TEL mesbivne Mamvell df iL. TU Lalke abu.l Masvell's slalivieey © being at the heise, it talks about ether estes with respect to 3 Mawel. Weer 1 asked ber ak or doperitios avd | gave ber 1 hein decomrl — ave vol Gen look al Lie Leckimorye your Taran, 1 ve wail goo Lo look al Lie testimony ste says: Iles set 12 r. karer in thar depesitien, they talk ahest fer harelize mo 13 owar sve welt, Task al earlaie Liege 1 gave Rar, in Creel 11 other, Elgiti Bo tusze was an attitice lave wizlay thet 17 deposition that I had to mazage. And tEat vas vAAt was coming To pin Liab seckion. Th wanstl Lal she didtl sey she ae sees TEAL BL juor Tuner, we are alloved Lo pol Liab in Ceol of 12 Ler, dn Zrest of tie Jury, anc say: Dic goi know abuit tals at 13 ten time in 7005 whan ved ware photeqrapted Kise prtaic on 20 Le day bee ieverligalio sharled] Vo. ware warkivg ‘or rim 21 ene admitted that. Tou Gacn't Kuow abost all these little 22 girls cemize te thc palm seach hesse that yeu were workine at, 73 Keak you alaim ves ern Kea Reine meager Tori Ue sheild bo 4 bibles to get tude dn tH Tas COLE That 43 for the trith of the matter. SUOTTAR WATRICT ATROATTRG, P.O. Prep ai fe fi ME. MCCHLEY: Musties sce hie ebuit it, Test's sot © or he mh 0f we manner, yr conor. ants whan ste kere 1 all these detisiale dn the police report, Sid she Kio abot © this. go that om be offered not Ser the Tita ht to shor © urn on Yee abot ihe Menten cn Tene shan at Sn sin Tab vas maha Lisl slelowesl, iL vas alse, bevaose sul wily © cia my clisst get abused there but eo many other girls as vell. n TE COT: Bein me. = ne wintry aes 11 cvimeits. Se Glen't aitisiticets tiem Sn the swiss OF sapii¢ 15 thar these axe pare of the file. | mean, it's Sot that kind of v HE. MCHIT: TL de. ques Teer, Towre ace Low 1 eizzerest tukige, ase I'm Jumplig arene a Little bit, so TE keamic my mle. merry. ih kere am a erin of oir desigaticns where ve valbed threigh with im Gov Ge 2 emnuered the fmvestiearion, Sow Se resnnicd the infomation of £1 toay vere seportas dn tide socamsts shove di ile testing, 7 fo that's ne piece. As that's why this cosld coms in snder SUA TITTY ARAN, B.C. Taetgios 1 tie beelimes secorse sxempbicn, Sil even Lo AL wesen'l Lo cone © in mer the Wusitess reesrds evenpriet, in cas ome §0 cer for BARRISTER ARMA ATRIA a US TOR Vesti 1 Rut gos say dn your June Jth order, “Rotvitietasdlng the I aestions are directed to reveal relevast answers Iegarédsg © antredameis koelndgn af plaimtiTTe allegation, teat heorlesge gues viseilly Lu Lie Leolh we saleily ue Lie : cefamation, a key elemest of plaistizi'e claims.’ 1 stier 3 words, hal Wasenll Yeew ak Ke Line sRats makin Lhe sharewent 10 coms Lo Lee Lele of Lie Talaily of Lrose slalewssls, ae Leal 1 dale Lede pulive sepul, ons Sonus, su ve elise Lael 17 tts aritieal reidesan to stew thar. asd ell] ser rear, 13 again, see war working Coe bee deasdanh al Lo Lime teal Lis 11 snvestigatice appease. Soe Gas testifies to tab. fae vas en 17 the flights with him at the time this was gedzg on over 330 6 Limes drivg Leal period. 1 TOI COURT: Vou how, spere we Lie Sligile, okay? 1 ME. MOCRRLEY: fire. Okay. 1: He a Len Rear an bafern. ET Mo. MCCAY: Gore. Tt sorry, your Teror. TWIN Ley 21 te ent to the chase here 2 an cereaizly, vou keee, it's interesting, heise ven 23 veard doanee anil Fora seh bea low age rayite beak Koy £1 vestes to gel be police sepuile vi an ser sge mizur, 37 virginia Ginffre, from wien she vas 1, being raped by tue SUOTTAR WATRICT ATROATTRG, P.O. Prep 11 Taetgios 1 ties buge, sighl? 3it ow police sepuste ere sol alloves Ln 7 An all, Figtei a peliee report whore I've con the demearive 3 coming Lo besliTy aboul Lo police report, bral va Leak i vis 4 suvestigaticn, oh, DST that can't come dn. Amd what's I iztercsting iz. they west threigh all of cur eases but they © Tailed te look an tRniv ows mann, Beewice Smits, weiss inn vase Lal Luey vile it Leis beies on Leyiog Lo vel Lis police © reports in, a foithers District of bew York case, says tiat 3 weiss cows in. TL save, Wolatomesie i0 a police repent. are 10 tol itacmisible fearsay were, ax rere, Ley are col of eres 1 fer lie Lecls uf Lie mello ssswrled bol Zor potposes vf 12 sheeize whother the arresting effiser tad the infermarins 13 qivivg Lem probable mire in Aral felasen.t Go weal we are 11 sodng here, jeir Foner, le pitting Surth thle police repurt to 13 show whether or fot Maxwell had the kuowledge of that, whieh we 16 are elilles Lo web er Lose doeslions al Leal, your Tver, Tr end Lo Lidice Luis pulive report ic Lil regare. 1 fo, gus Heaor, it comes in Zor the zeassie. One, 13 eden thn bearray cxeephie, wick in bea hiri-ann reaerds 28 esceplion Lire cr We. Recarapts Laslimony, which is celles i+ 20 eux brieza, se vas deposed for a Till day. se valked threigh 22 all ef these domments dn hs dnvestieaties, and we laid eur £1 kept do tes separ conser ui ne werk, Fe Leeliiles boat iL 20 vas something be had te do in accordance with that werk. se SUOTTAR WATRICT ATROATTRG, P.O. Prep Taetgios 1 beeliiie Liat oe vee Lie primary antics oo Liab ase Lael it 3 we vere very Gire’.l, boise ve keen toe imperial, Lis 4 coment vas, to valk him thrcigh that wien ve had him at he 3 deposition. nd again, your senor, those dopeaities © anrigeatiees are sen Tarts for est dedeeedey. ¥ THD COURT: uw we we kis Liab Lids is Lie Lolal © recorss Or ds it tie total recozd? We den't know. s WL MECROIAY: BAT, Seenrey beski Tied = wn shoued TT mim Li cocomerl ax an wribiL 4 Rix Geporilion, av be 1 leelities seescios Like being sumelidog Lil fe secosses do 17 te mise of Sin ews work. 1” ACHAT Lb ite park oF bbe resend. Tx ik all a” 0 tie zecurst 5 ME. Meals: Meaning all of the resord of the entire 16 ieverbialion We uve prod.ced Leal i discovers, voor Cover, Ti Luton Lie we have « TOTR tempos, which is for ve gol Lie 15 vicestapes of tiem walking Tiroigh toe Palm Seach hoses, all ui 13 ten ettar materiale related ko tha Sunchiganios. » TL CHAT: 1 vee. hav. 2 ME. MeCMMLAX: fo Then, Jour senor, ve deposed the 22 deteative to trv, of coups, to establish thar this vas tie a Tou Burr, liey elev metivies ens bide de 27 actually in the in tote motion, hut they Jumped to it so 1 feed SUOTTAR WATRICT ATROATTRG, P.O. Prep 1 to ssrves At, sid List fe wie 05 he wilissews Ln Gere, BE 7 mwas a mizor an the tine, alas gave a vennvéed Satmenh an 1 fn my view, vastly misrspresentisg the depesiticn. Ad yeu can © look at vio gueves themsclves, bit she testified dn creat LT — ¥ suit 3h dma secure sind Bh Lie akiu Spit wae di Sant : curmest. ad sie de a vitsess on cnr trial list. fie de a 1 er estima ve fave soil Lo wiles Liab se a wilives i FH Uhnimons: soning Yietin in dhe To fre mottos Wks 1 state they rates it. Is ie ether issu they ralsed are the message pads, Fr thru elise wile Ho Lk mgs pte. oe $455 4 1 nomber of ways. Tue ds Gian Alssal, vio de one ol the hoses VE Sil a ee YR wi A Se A sipavize, wee, tis ds Gov ve Tecorded cir message. se 2 whos ar the Smo. ene war Gin fury ta fo these thises. A dboit teuse, yon kiwve vere ju naviig Luzes gizle vem vo tide 3% particiler day. ste. ete.s fo those are documents that sheild SUA TITTY ARAN, B.C. Taetgios a 1 come Lote evlience Levees Ley have bees validates by on 7 employee who works an the howe asd ave ehises than sheild be 3 able Lo be LLilived al Leial, and Mawel] so.le be able Lo be 1 shown those and explain wether or not there lo some laste With I reapect te thes sratemests. H CE LJ miles ab Lie Lebel, ans vesleiidy ve fave Sone ves vilivece with respect to the police report to make size that ve do Lave 3 eneative Sessreyts Lestimony or TL 1 sbmil 07 yes review IT Leal, joo will see Lie reson wy Leal iL sro ld come ito 1 eeidenoes 3b fegarcless ul Lie featssy desc and lie boskiess 12 reeores xncptien, acaiz, as wes sald 47 yer aime Toes 13 order, Lee poieh 0 dateedaskis kouladge al Le Lim she mide 11 a cetamstury statement de very elgniiivait Ln tide case, so i 13 she kuew — eves if she €idn't belicve my aliest, if aie knew 6 Lal bare vad boss a saber of elven Ldar-age wisors Lal Ti vere abised in Leis clrcomslence, Lo cell my clissl « Lise is 15 the Zace 02 all that knovlespe de sumetilng the Juzy esvils be 13 Abin te menridnr. se than in a pines Kean in feportanh ao JE relacash Lo Leis came. Red yo. cat alas Give a co lionary 20 metrietien. 1F you're concerned at any level, as you Kaew, 22 yo: anil ae a caztienary dmstrictinn with respest te tie 73 polis roport. Suk wn roild be eekiklad to ark ber murkions 1 on the clase von stele Licer valk abut vial eae kiww with 27 respect to this very sigrificast dosamest. SUOTTAR WATRICT ATROATTRG, P.O. Pett 122 Taetgios 1 Taek you, york Tenet. 7 Wi pai: ariefly, yor otor 3 So Tirek, wares doing @ wi avd malar Mare of 1 Giizerent tinge, whlch I Like the rile: of evidence becaise I they're rales and 1 oan road them ad they aay what they say. H seen 1%, uns 5, ge had a pld-plated renord T Geelusian stem Lie Palm Seach Pulive Depacbmesl vom it bere 2 anc make all of the Finiige that you needed to Zinc as a 3 Buritess record sveophios or i counremerl. record csasphios, Khe 10 cane La ix abrol Lely clear Lal secondo and Lbirsans Sesrsay 1 de dnesmicelble Lizuogh police sepoile. 1” | zee this rxample beaxiin 60s a goed ere, | tRiTk 13 Re part oT wy praciice, | repress. people aea.red oF arines, 11 ais su ve get lecorery as part of my practice. Giese wnat? 13 iat gees dzte ny files asd L keep it a: a matter of cours, HH RoE SST. Fags? HEH Ti coorse. Fev Lial dossn'l meas Lisl iL simply wo ld gel 1: acmittes dite a trial viele cloth Zor tie Erith of the matter 13 amearted, Gut bein inte a busicans reeerd of wie. aed 20 wry? Wealtn Ure avscer? Tecdove Lee slalewals Leal are 21 smeluded in the police report, ox the discovery that i get, 22 what 1 pot dn ww file and 1 keep very sarefzlly as a business 73 reenrd, dosti magia ly become sesarray, beanise Ln paople 41 vio are making Lives elatemeile are fol Lace: any bueliwes Goly 37 to report tome. And that's what the busizess record exsepticn SUOTTAR WATRICT ATROATTRG, P.O. Prep 1 deeld amit, These de taistiurtibiess vies cums, Jos 7 Wore se FE nn BATH rear oF win, Shanthi ESAT 4 the hatn of tie hearsay Link has te be Snider a bisiiess ity © to epert. so there awe ences where sfficers axe allowed to ¥ Ming whowtesit them wi ssubbbr wilive Lube Lim wi LL vaso © test that magbe happened vithin tie police cepartaeit. Sit 3 rah aeytre “of allowed te talk abet, der a binieen ronnd TE SA ATS TIA aS 1 Ne Meaney vests Lo Ley te Lilies Lo to Jury 4 tds 12 ease == 27 pages of witsess statomests from people win wn des’ 11 sssesiaticn wits Me. Meveldl. Is Let me SHnish wird thls state of mind Less. 1 enceptiva? Mo TAGLIECR It coils be, Joiz Serer. fu 101is won ie Sh, Wa te se Te, vy, 4 Fe reparks etd gel bey Bl, “Bh Loe Sears part a HA BAGLINGRT Sxantly. That's exactly Hight, = a Er Wel, okay. 6 corse int he plaintiss a ME TRGLICGR: Weld, tows yui'ze zecectisg 28 percent SUA TITTY ARAN, Puc. Taetgios Be 1 THD COURTS I eden'l say secection. ITU's ieareay, © ints men being aTTnred, bin of airee in is beivg effneed Tor 1 MAL DAGLILCR: Sxactly. Yeu Kiow, this ds a I smokescreen abest it gocs te Mawerll's state of mind, asd when © yes AareSilly gn tRreieh Kees pelinn reperkr, Benen in Son an Tun Lise alleged ciclime vio ideslioive Me. Marvell ss baviiy anything to do with any of thie. Which de another important 3 poith 1 Deal Tine cries, agi, Me MCmelay ally says 1 liste are £0 viclime Sveslioied bn lisse police fepotle, wich 12 mtr erie. ane whe | asked cteative deearey te on threes TE bee i me ae asl Ty ew may people Re sis were Cieling, 11 there vere 10. Rie ev nev tesey sie sal Giese vers 2. So 13 she's werkizg her vay my way, sit, yes know, that's the 16 problem tere, voor Teror. Weis ix being o”larad Tor Lie Leis Ti ol Lhe meller ezserle BLL Luey ves Lo co is gel is feel of 15 a jury that tere vas a pelice cepartmest investigation in 13 which dprrnic wan the target ad petals in allaged te have 76 come all of Lrexe bac Lringe; Lrere ore, yo. sro. prise 21 maxwell because then they're yelig To say, she vas his 22 girlfriend, she had te have known, vada, vada, vada, vada, he's 73 ow bad parses, shals a bad parses, Titd hor isble, ad whack 41 eer vite a big damage avarc, Thal'e wiat's gods un eres tH Hnask yo. SUOTTAR WATRICT ATROATTRG, P.O. Prep 1:1 Taetgios 1 THD COURT: Waals ext? 7 ML GRRL en monies 0m ellen and Mari keva, mi 3 mole Lo gel i+ adverse i+ Taran 1 TH5 cou Yes E Mi. GASES LZ 1 oan be heard on ThA, OSE asier. z Be A emien me. ek me gn bask ko wRnrn un : Ticse statements, the statements of the "icting," are 3 being eTTered Tor the Grid, are they cot iE MIL MGERIST: Tour Toror, T do “ol believe Liay're 11 being uiiered cor Lie Liils because viel wee sali we're 12 zor saving whether or cot what these wierims said was 13 meesssanily bree. Uatee sayiee wan she ses Ll bears vers 11 aimber ane taey take lesie with toe saber. 1 een't ses a 17 difference betwoon 17 and 30. Sut was slic aware That there 16 were a mbar of olen ivdividals mibivg roporls al. Le Lime Ti ete seit wy cliesl meal fave bees Lyitg abo.l beitg abies az o 1: miner. fo uietier or not those are trie or tot, the reports 13 war she mene Ran thers warn shar of reparts in Hearn 20 rom obrar 1iLLle Girls savicg Leal Ley wars alse bro.grl Lo 21 the massage zoom. And That gees to her state of mind at the 22 wime she made thar statemest whers she defames my alien 73 imtereationally. a THT COURT Yee. Bob avare of tie zepurte. How voila 27 she be avare of the reports: Avare of the girls asd tie SUOTTAR WATRICT ATROATTRG, P.O. Prep ai we 1 activity, that's the Gite, Bt vase ui the sepste. 4 Ger testimony fo that ste verkss for Spatets xem the easly 3 this until 905. Ths dnvesticatien tock place dn 2306, yeux © ror, dieing thn amen 5% thn tian sh wan Al oantly mamarieg ¥ bin Paki Sean bom ai di swkive emeliyee, Khe Sight hav t peresi. fo yes, uf oizes, ve sheild be able to ask hex those VE SER, TER GO AL USA SRP Wt 3 pu howe as peat ul Usk davestigelion? his Lows sie vas FI ed owl ahin Her the Kepsrts aid says vers Jeu avere uf tiem 15 hut ear weslé or cet the hearsay pare iz. Tr Lew wtowr ul Lie sephivia, Lie baiiees teers waceplivi, 1: unten ve talks abost, sis ve also sotices this as use of toe VE Ra ny 2 weak cosnsel ds currect under the bisdisss recerés 2 eentien, th SetivTics oF the men and wat they fie, all of A set toe statemate. % MEL Menavbax: fo for example, ce of the vitissses on SUA TITAN ARAN, B.C. Taetgios 5 1 uer viliees Let de BE, veo de dn Lie soporte sie Leeliiies 3 TE CHURT Wall, Walt a i TCarenl isee. Red vo 1 said geitre else to present her E BE BoGaNLE! Ica. H FET TS LP RE PE USE Po Geesbiun Bel di lies verde, gue cued shor Ger Lie sepuil and ask her Af ale’s avare of tiess eperte. 1 assume viat her 3 areunr ir goitg te ba. Bed Kakln the and eT ih iE MOL MGERRIST: Dell, oor Toror, T wes, obeioosly IL vers dike Lo wiles Lie sepuile der Lie boeliess secon 12 rxeeprinn threset demarey and threes the residual beara -- 1” A COURT SL sven 17 yo do Leal, Tenth san Row 1 yes avele elimizaticg tis beazeay. 5 well, kay. all rigr. 1" MRL PRGLTUCR: Your Tovar, cold T huve ove Tieal Tr comment ut Lids. To Liey're sol beitg olleres lot Lie Leolt of 15 the matter assertes, toey'ze really Sot zelevait fo tals case 13 irom Tima) poict, beemiee iT thayten cet beicg ofTared far tn 28 Ler a Lee miller asserbed, al bask iL a ce.Lral a bo 21 whether these Tilnge Sid or GaGR't happen. AI they didn't 22 mappes, they wesld srrtaizly he sipportive of He. Hamenll's 23 hake 0 mite iT she keow abedh Wom. 17 they're ok boitg 41 uizeres fur tie Leth uf Lie matter tH Tau COLE Mell, 3 might be material that she knew SUOTTAR WATRICT ATROATTRG, P.O. Pret 1: Taetgios 1 thal tiers wae an duemsliyation. 7 ML PA: ves kee, Se aild be asked Ran BALI WE ye Be Lore a RRO TARE 1 she's pelt to say ne. 1 gave joi her aifidavit in wales she I said pricr te making her statement, she had sever seen vhces © pelimn reparte. an wn all koe —— ¥ TOD COURT: Teal's & ioierent goeslivi. : Mi. DEGLIVGA: I nderstaid. Bit ve all know the BARE, RAYS ARR RTI Topas, HE NY rey ie 10 arn Lael ied ak Pur depos iLion Lal are wesetl cast ly andre of 1 Unie doeestigetivn, BLL ste kee 1 ledk de viel soe 12 terrified to == was that sprtein west fo dail acd she keew ar 13 nome pail be wan a regiskorsd re eo Cnedar. Weose ara Lee Le 11 thlage 1 tlnk she Kiew at the sic uf the cay at tale 17 deposition. Anyvay, | agree with ye: that the guestien, éi 16 ve. bow Liars was an invasbicalion, vo. beow, T sppore vo Ti car eck Lal goeslivs are Lie ansver vill be jes of fo, 1: vhatever it de. 1: we a okay. ET WAL BRGLIGCR RIV righL. Trath vo. 2 Tau cou Okay. A'm sorry. rergive me fox 2 smteresprize. a WAL CRAG Re. Your pakicras Ran bee approciabed 41 teseye your Huser. tH 1 wast to address new the Mareizkeva and selles SUOTTAR WATRICT ATROATTRG, P.O. Prep Taetgios Be 1 aciezes diereice molluie, We're o muciig party. These aze 7 vemipronn] merines hott ways om Rin. | have the Sumber 3 avaiable, 4 aL vould bo Laat). T belie £13 bn bre 1 Gefendant’s motion ane 636 a cir metien. fo those weil be I the tee motions geizg, ohviesely, in differest directions. z wir por i Tamiliae with than insine heevise of Lie Speleit adeezes dfsrsive moliv lial ves argos T Lick tes veeks age by me, axc at thst time 1 know you have net 3 ven Termilly Filed on Lhe mekion, Bil Khare wan shan ive 10 heeianion abosl colle we Joh Kick bin dew Lie reed Lo Lie IL Liiel si see, yon haow, wel Spelein says ob Lil Lime sis, 12 we: keew, after be testifing, sere eur whether there's as 13 aduarne Petersen Renin, ye. est ded on Luk, bo T 11 think I fnelatec at tie time fiat certainly from Me. Giuizze's 13 pednt of view, ve wexld have mo chicotic to handling To Mel Tpelein in Leal way. Tomek Lo mabe clear Luk ve vould Ti ales face to objection Lo taselisg Lie Marcinhoce axe elle 1: deste dn that vay as well. You can pit tiem on via cepoaitic. 13 ane then wn anid sort mi in EA evtavh af ta cane wits 8 2 11 record wrelrar ar averse i+ ares i3 approprisle. Tl 21 ve surface the dase for Jou Sew sc AT wealén't be something 22 yout have te dn on the fly dn tho middle of trial. and all 23 ke allogabiees, oF course, Keak Mave boos made bere, 1 Kick 0 Abe dmportent te pub Tellen si Herclibore vi Los conepliecy 20 scheme, if you will, The tep of the conspiracy is Mr. spatein SUOTTAR WATRICT ATROATTRG, P.O. Pept 1 Gls ight fens player Liss de Me. Mewoell, sist dn tie 1 the coreplracy's next echeles Lo Selle ad Maretshova. H asd zo Zor example, 1. GisSEre Sas made allogatiess © about certain thing. we. Wael] mate vember or dnsine ¥ Mien ow 0 nie Ba, Gluiicn Lins duvke Us wussebuiats bes : allegations of a cosepizacy, aie the frat perscs sie gues to 10 Lebret pespte Ll wow gone be ar Tabb av Werth, 1 beces lie caput dmmecitely to Ne. Mewsld Ls toe 12 peeopiracy. ac Mn. GIST io grins te he talkig hei thar 11 putin to vencer, weld, gust, Tuer Het Selden says abit 15 thats 1 under var mrsiskera sae about thats nd peur FI lkiiy Tog ere svssiog: seevive Gn ed vier Te 12 cltimetely fas to come to gos Somer to get alteriative 15 roreinn, avd in wr ely ak tah pale tan wn worn shia te 2 dspesiticss few, sd hat ve Gear from the defense, if 1 So umdzesrand it, 47 Sar wr dent ave a cesé-Seits basis Sor £1 sex tresthokiog sis evk abies onsplsacy? 1 thlik the vay they ST put it in their brie is, all of this evidence shows sothisg SUA TITTY ARAN, B.C. Taetgios i 1 Uther Lien Me. Maxwell might seve bess sl Li ame plece ot Li 7 name mime. IRs fuse, ver koe, a Rappesaraen they were in Be ame place aed Laks col admissible. Ball, vor Teor 4 will notice fn oir opening bried on this, at pages 13 1 thik I through the SONt ton pages oF G6, we'Ve gone thEGNgh with a © amare aE unten maid, ekav, Sereln tie mieskies un asked, anf To Lien de Lie sighl fend cela be ves wharl ve pel ds Lie © witnesses and, you knew, the Lieut lege. 1 kuow other thlige 3 beak your Toor fn wary Tamiliae with. THs in why eatre 10 anbing Liane goesbions. Yoo bow, Lie 1g logs Fave bee IL Labhes sbunl res ei bees apelin, bol sus dus feasun, Sellen 12 7 on some of these Sliche Ings, até whats uni Toes are tho 13 auasliees Lal wn arked, av oF ao.ese she Lakes Lee TEL n Taeze are tier talige ae vell. For exemple, Saran 17 sanseme testificd, | witnessed vith my own two oyes faral 16 Teller reporkivg Lo Grixlaive iv Cronk 0” ma, bul T arth Ti remember speciiics. Trey weeen'l Lelking bool giels, Tcan'l 15 remember tie speciiic ceivereativn, bit every siigle perec, 13155 paresr, 750 parmecr, reperted te iRislaice. later en in PE bral ame deposilion —— Leal wes al. page 788 avo Lreredbo.ls 20 atopage $27: 1 witiessed the same thing all the girls 22 did == the same thize 1 tad to do was on azé report te dark 23 alles, berlin Groat, ard Wislaive Muswell. (eislaice wan ten £1 meds lasy. So evedn, we sere en allegation by va clieal tiet 27 Ma. Maxvell vas a part of a larger conspiracy. That's ee of SUOTTAR WATRICT ATROATTRG, P.O. Prep Taetgios Be 1 the veilzal desiwe, ui vuizes, dn Uae vase. One of Lie lalige 7 tran was ealled an cheinun 196. and ne wn wanr tn Brite in re 3 comcorspiralors and ar Lom, MeL GiLTTRs says vo. vers i i 4 conspiracy and what's your side of the story oh thats Rud they I take the sifth. so there we arc. The cucstien is, are wo © amity te mnmanal teat Trem te Gury er avn wn Geiee te preeeh TAL Lo Liew? Meld, Lie Sevens Ciec.il vase lial jue Tuur de © well Zamiliar with, MABittl, sets cit the Zactors that Lave 10 celenal in ob, Lis Sever bees applied ic 4 cane like Lei IT woud Joel sheecl joo ableibive, se Tis sedis Loe Speleds 17 argmesr, te the eaze af Sis w. SiEclity © epenit to. of 13 Marlene. Walt a THOU Ciredit case rom 1333, in wine 11 bank eizieer vas acvises of Slehunest ane Tzauilent acts as 13 king of bogus leans, and the Fifth cizeuit allowed sifeh 16 wedmsrl ivocilions Crow La leas recipierls Lo ba Led Tr apelel tim, teesonizg Liab, well, is Lids ise of o cee, Lie 12 collusion tien de show by the FAZth Mmenoment Lnvocativs ui 13 ten participate io the sempiraey tern. VET dmesdwes, PE irvocalions cur be mali dgainil somes rely doc.ced Lo ba a 21 part of that conspiracy, which of cviree ie exactly wat ve 22 nave geizg ex Bere in a mivil eoztest. a WIN, by Kn way, Kee Seord Giri ears, wie in 41 cuntrollisg dn bide Jalesivlive, sevrably cites tie Tite 27 pirenit case in #10 v. sidelity § deposit co., explaining that SUOTTAR WATRICT ATROATTRG, P.O. Pret 1 baat de vie uf Lie teseuie oy dn Lie Seven Clrcidt tiey tadsk BRR A RE Tay SR SE SRS SE TR RR 4 Aid LASITES hen gues Gh 4s Ji Soser a well 3 familiar, with laying est Ses difforest factors. ho fret is bondi of ie pelt sbin medion, the, rebioesin ban tds ue eepicalote. Tesy'se Li Lie bwesiele Sed eielud oo © the conspizacy. They are cirect reports in the bisizess sense, 10 Serr avs ar Font eporla te We Meslls OT cour Len 1 vusepiecy wilioes. Tbs ds sb Jeb ab Lie Lime of tines 7 JPET SU SOE WP SE WE 1 11 Uhile ve vers trutne te bats thelr testimesy Lest year, 15 sveseially they show op with Lawers, 8 swice seisiare J thick Tr Mh Suluteegee, whore an ablucoey ioe Meo Taleb cons Toye 1 both mace signiivast sifurts te svace service. Wig? Becaiss T= mir vine thn eeopivany ehiinr ta Kin dav. To I lords over an extended peried of time. Tie ccoealmest “2 eatimes thames ie efforts mee nly of the defeséut hr a Bit tisets moe tat bizce tiem topetiss wees Loney: 57 we sencr is of conse familiar with the Sonpresesitics SUA TITTY ARAN, B.C. te Taetgios 1 apreemet Liable al lie beasb on lide wesw. Semeaber Lis lees 7 tran en were alkicg shou yesterday. The sosproseeinins 3 greemstl save Lo We. Tprlais, wa will ol prosac le yo, or 1 any potential co conspirators, or, and then there were Zour I zamed indivicials. Teo of thes named individuals are © Maraiskaun ad nllen. in tryin Besed becerser asd Rave Toms iilesesl i Leyiiy Lo pressive Liab fospruseolivs © agreement, which meas, of coirae, attackiig people wie are 3 attackicg kre oprosecitios agrecmett, sin ar dae ea 3, 1 Leal in my elierl, Mel Gil res 1n Bi lial de Lie Zizel factor, Lie selize ui lie 17 relainnstip there. vers igtely bese 1” Wl RT NL Rr WR. SAR Va 11 party nae vestes tie Gunparty witiess dn sevars to hey Sacte 17 asd tae general subject matter of the litigation. rhat's a 16 diel cole Crom LiTLLLIL Red lve evidence bare — and gait, TET wntU belabur all ul Lie CLighl logs asd speciiic evivesce, 12 bit 4t's recites, you kiow, in a ten page chart in oir brie: 13 4mlian and marnickous arn wary tigely beisd wits ton JE eaanie. Treg are ivach reporls. Tray are workise closely 21 together. 1 ut guoted Ma. ianseme saying, you Kew, that 22 ehat was the person that they wero talkine te, azé so ved have 73 a very sigei Tien deren oF aothrl. a Tie tides cector Zzom LAS.tUL Le compatibility of 27 isterests. lerfect compatibility of interests here. SUOTTAR WATRICT ATROATTRG, P.O. Pret m Taetgios 1 Me. Giiiire hee sabe liere vas o conspiracy dnvelviag all ui 7 theen imfividsala. they're all anite te say =n, here wash 3 REI rave a Leial on Wal and hear Lr Gidea. ul be 1 compatibility of interests la, that team is agalzat I me. Giaffre. Teese co-conspirators are all working Togeticr te © trv te umdnrmin the AreRiBAliEY 0 MeL GHUTSRe. and nf Asien To Lbey'es all hupiiy Lieb ste will dues Lids Leial, vic Liey will then celebrate as a victory, OF cores if Ma. Giuifre 3 wine whe Leia), they wi] a1] 2iTTar a deTenk beaaine her 10 cracibilily in mabivg Louse al legabions will fave beet 1 eetablicies. i” Toe Zizal Taster Limited fireors gen te eesiider in TI hea rela in Le ederlyivg arpeels 0 Lea 1iLigakio, and 11 again, Ate hare to imagine. 1 Wea't say tip are tie mest 17 importast members of the conspiracy. apsteds is the mest 16 iwporbasl wewber of Le conspiracy, bul Lia sacl worl, Ti imprlenl, aller Mesell, who's Lie Sober Loo posiliv, Lie 15 next most importait conspirator is Sellen asc Marcizkova. I've 13 end tea expression bafere, i6' Kite nf plavicg amlen with 28 Le grosl. etre soit Lo be Lilbise dbo l a conspiracy 21 withest the conspirators in the case. We are trying to bring 22 whe aecopiraters hore in fret of tht fury se that tity san 73 hear weah bee avepirators Rave be say whos arked cienhines £1 ebuit weet tiey were sulig to Me, Sliiize ese viel Liey veze 20 doing te similarly situated yossg girls. SUOTTAN WATRICT ATROATTRG, P.O. Prep 12 Taetgios 1 Tae final podil tial tie LABLLLL veer sliecte jus Lo © eensider i werter agmitnicg te ceideean will advaten ton BHR as SE EN CV TA 4 that tem sot as a lawyer bt as a lagperec for thie purpose. I webator's defines to conspire meass to join teeTtier in a © renve sneeemest th fp an ulaetil or wremgSil ack or an ask To nin becomes silevood gs a fesodl uo sscrel ageeemil, Bid ove vast to preset the conspirator. Now ve think that makes 3 bee anne thak Win ix Righly relesash and alse appropriate Tor 10 an adeerze 14 erence. gai, oor Totor cool wail Lo role or 1 lake al Lrial, bol ve Leds Ils clesz val sow i” 2% anna pee ni dntermie tar somettine's 13 relevant, yo. ror Rave Le eaeridar possible pre) dicial 11 emzect. bvloiely thls la a case bn waden sex allevativis are 17 going te be at thelr heart. It's set like ve have a business 16 imple ware somebody warls Lo Lirow in sas ubuze. We wal. Lo Ti prove, ite vase livoleiig a ses corspitacy, wel Lie 18 conspirators Gave to say. Reo tiere's Se prelieice toes to 13 Mawel) in pe remen ef uta projudinn. 6 aan ark whatever 20 ueslions Leer ceen appropriale as well. Tol Lee ubievce 21 the eo conepiraters is of coizae highly preiidicial to 22 Me. ciuffre. wavsrally the Suv is ening te wexder, ves said 23 lon wan roporkivg bo Mowall. Wars ix felled Manis £1 gulag to be tie Slat Lidig Laey'Al cay ween Lisy vo beck Lito 37 the Jury room. Where are these peoples Ad that's wat SUOTTAR WATRICT ATROATTRG, P.O. Pret 1: Taetgios 1 they're pulor Lo say 45 ve sun't have en oppurbiadly Lo preset 3 Tre Court will rac Le os Lraordi sey Tarlts Lo 4 which Me. SLuIIre Gad te gO to procize thelr Testimony. They I zizally were able to scours it, asd they sheald be preseated. z Mra == Rink ges t1] be Searing tiene dries seen Towmek we eed sume leaiig goeslivie sing Lie depueilivi We tried to ales wee some nosleacing. Leading giesticne can be 10 perky or Low olbar side: Bally we sai Loagtee ia 1 cunepiiacy. 1 cen'l dmeclie «vase viese Lise voids be o 17 learer example of wes leadite eiesrioss ile be appropriate. iE Moe Thal argument, ey wade, TREE lank sigh in 11 thelr Late replies va: that ve somehow misses tie ceacliie Ln 17 vaking thelr depesitien. What they den't édselese | thizk dn 16 Lain papers ix, your Toror will recsll Luk we hud Lo cons Lo Ti joo oblait an spplicelivs Sor allecralice service, en Lien, 15 as a result of that, they came dn. Oe Sic all toss talnge 13 wins tea Goirnts Blersicg ad approval of kakisg deperitie=r 20 Troms cred. les vere cisc.sses vile opposing co.nsel. Red un 21 soon ae we'd taken the depositic, ATL approximately a veek, 22 wo provided the desienatiess, That was hack in robriary ef 23 Kein year. Wearats a projudiee. a fo Zor all Uieee zeacore, ve voile ack that ve be 37 allowed to presest two of the co-conspirators in the witiess SUOTTAR WATRICT ATROATTRG, P.O. Prep 1m Taetgios 1 bux ede bie cdees sepueilivie Liat we've Laken, 7 ML PsA | tegen | was back te my old dave an 3a pablic detandar wren T slarled Lee praclice of lie, vo.r 4 menor. Wow I'm argaing an 2016) (2305) meticn fstesd of a I defamation case. H | Bek wn Ravn fe Sra wits ton semie teat in tein, Lieb lide de 4 deoamelivt vase if vic Me. Mamvell is alleged to have mace a cefamatory statemest in 2013. In that 3 dnTamitory satemeri Me. Maven] dons “ol. menkio any of Kren 1 miei ane cones tL weLion Me. Tprleit, at so Lie 1 slerlisg peist cor Leds ds, ide de sn eslizely ioiesesl dese 12 han mr. vasael] ad Riz fantastisal entapirasy aremmest ere. iE TF wn nk ko slick Le te egal insan ie Lie cane, 111 talsk ve Zlret ness te uieeretaic that tere le actially a 17 speoific rile of evidence that relates te co-conspirator 6 rears caoplion, av Lal ia Sule S0106 7) oF Lee Tedaral Tr Roles ol Seitesce, ane signiliceslly, cer Lael tle ane 12 thle de wey the cases velng Tale 2006862003) Sie dscdeds of 13 bristusrtticarr in comeomrpirator eareay shatomnsts == beep P0 are wise al or curing Le cores ar i= clearance oF 21 conspiracy. snd absent that finding, statements of 22 premesspirators are deemed to he hearsay. a So sak weteo kalkicg abaik Fore are “oh skakocehs 1 prpertecly meos by any of liser dncivieiale dn 4050 or 201 27 we've talking about statements that they are seekicg to (a) SUOTTAR WATRICT ATROATTRG, P.O. Pret 1: Taetgios 1 dilzusics ue 03] asiesenly literence Lisl ase made Lo 201: Liat 7 bag martieg tn dn with any alleed amines of or = Tirtterates 3 ot uw comspiracy. Bev alloged conspiracy wo.ld Fava Larmiiled 4 gears age by cperaticn of may eiiferest rile asd lav. go I mr cassell's extire cozspiracy thicery predicate te thls Gas © metritg fe de wits ten fer Livni asters ¥ Ro viet ve Lalk sbu.l Lie LiSolli —avlute, yon kav, there ie really sere evidence that's been presestes to yosr 3 Corer. Tiesk of all, tre relationship sow, in 7217, Babess 10 Leese Ereicitials — becaire Lal in weal Lie corlrol Ling 1 relalivietdp de, Gol sume selalivietip Lisl happened vr sil 12 kappes dn 2555 er 2501. an dn the relarinzship durize the 13 moueme eT kein Titigalion, ol rows etree 1ikigakion. fed 11 sneess, tiers Le Go relaticienip betiess tosss Solke. At bet, 13 Zor a brief period of time, a brief pericd of time, ticse folks 16 orks in di Tarenl capaeilion Tor We. Tpslais, al bel, ae Ti Leal briel period of Lime is more Liar Let jeats ato. 1 Tae Stier part of tals tat Mp. Casewll cverlooks ox 13 donenth wank ko talk shout in whan really ir an nein m= an 26 Lin ralules Lo Lis close prece-l. relaliosnip —— cess Lrix 21 witness have some reason to protect Me. Mamvell, 1 mean, 22 what's really the dneuiry here. 1s the witsess fnvoking her, 73 ie Amin mane, privilace agaiseh sel isorinicabios bears ihe 1 golig to have sum benesit to Me, Maxwell? Mell, tisze de fo 37 benefit te Me. Maxwell Zor the invocation of the Fifth SUOTTAN WATRICT ATROATTRG, P.O. Prep 16 Taetgios 1 Emessmet pelillege Gere bececes lisees, 10 Lies viliceses 7 were te resriTy prinily, the teanimecy weil be heeefisial 3 Le me. Mawel) 1 TE jos ever gE The CPPORTILALY To vateh the vides of I those tee witnesses, your seser, it's romarkable beowsse © tmeratn a lok 0% oye relling ad Tamia] svpressines in peepee To Le Lhe Leasiag goeslivie by pleislio's Levyess Lie, dsomy : avalysie 1 may be testifying, your Zener, 1 mist acmit, Sit 3 in my obreruntion, iL wes basically a somuarbal TRante Sol 1 Leet an Les Lie ireocalion of Lie TEL Taescmacl privilege, IL an dn Liab gels plage cus Lie Jig, Lie Joy ven see Lisl ue 12 wean ser it. ar me point Mo. Bedaeley chided ene of rhein 13 wiinansar aes nid somelhing 1ike, yo. beow, 17 yo. keep dein 11 viet guntre slip, Velie geist to have te Go senetidiy eles 17 besser she dida't like the facial expressiess or the werds 16 Wak be wileass wan xivg Lo invoke Le TCLS fmasdwerl, Ti privilege, Thel's bow me Lise Colke vole telp Me. Masel 12 bit can't, ans they can't becaes they're protecting tosis een 13 imharnshe. Teevtrn cet profackieg He. Maveell' itereshs. 28 Meaytea worries Ural 1 Lea plaichis le lagers x eens in 21 Florida, tiey have ome threat of proseciticn, io they're net 22 ening te testify. sit again -- and this is, again, a peice 73 kak neoms be br overlooked by plaishi TT aeuenal == Arana bee 4 fsledeiale are lntees named Li tile sospruseviticn agreement 37 by name. Me. Mawvell is fot, asd Mi. Maxwell didn't chocse to SUOTTAR WATRICT ATROATTRG, P.O. Prep te Taetgios 1 deeuke ber TLL Bmesomel pelellege, She shold’ be 7 penalized hearin the people who are eavanreed asd are samedi Bin orprosac. lion agreement intl Lesli Ty bac se Le 4 plaintiiite lawyers are trying to ace thelr agreement vith the I goverment. H MeL Wavel] man cn SRilikY to castro] Heese Tolks To Yeo iow, ve verleinly versa'l guise Lu lane it Lie vay un : plantifz's trping to take their depreiticas, bit ve have fo 3 corteal ower tom, in seciritg Eoin testimony or rein 1 brew Lo cooperale in any seein, 1n Tile Lo Lie Cust Liv vase vo Coolie Toveslmeile © 12 erisrein, whist | Aime realize word] | waz reading this lash 13 sige i ireeie because Lee detedasl io Lee Sokesteis aie in 11 Mr. Sevarce! Sommer partier, wio's solig oi years Lo a Seceral 17 penitentiary right new. Sut in that case, whieh is very 6 similar ara, Ure courk vo.ldetL inpese an advarsa i area Ti apeliel an emplojer lor an emplojes, eves Lough Lie ewploger 15 vas paying Sor tie repreesiteticn of tie employee. Rio thet 13 mann ir 0 ERIK signi Sinan beavicn ten Amirt agais Temioed or 20 La relalionarip al bre Line of Ln ceposilio wn val. sows 21 price relaticneiip. 22 I talked best the se-senspirater issue. ves kaow, 1 uno. Fo ene hes weer Zuine tial tees Zolke are 37 co-conspirators. It's Mr. Cassell's and Mr. svards' thecry, SUOTTAR WATRICT ATROATTRG, P.O. Prep 1: Taetgios 1 bib AL certelidy de sel siglidig thet Lies de gulag Lo be ay © veal meinen abou in tein case 3 Tre nel Leo WILLE Taelors, Lia sel one relates Lo 1 any isterest in the citeome of the litigation. Again, I mr cassell has to masifactire seme interest here. These Zolke Tare on Aetesdashn in thin maze, thane wikeerser. Peng Rave =n Po ineiviel dileiesl. Tey face so Lise. Taser de io Juisb defense agresment. Tiere de no indemsifivaticn agreement. 3 Meare br sekkic. Thay have abel italy me deg i hin Tigh, 1 again, wien be ve delaras be Abe iLigalio 1n Tisze's Just really solblig hal would allow say 12 adverse inforenes iz shiz mane ane way or fhe orien. iE Tally, voor Toner —= wall, les Sisal poitie. Wee 1 gestienig, jes know, the BIg of Gestion tat vere posse to 17 ties witsesses vere precisely the kind of cuestiens that have 16 bee disapproved in Le Second Cireuil. Red Lealts feiskis Tr Teese. Cily of Few York, which is it Lie pepetss MorleCom 1: fecizity Litigation, alse in the papers; ane LASittd itasli. 13 Wenea are on tecteinal ebiackios. In sarees 0 legitimate JE ecivanliary porpore Tor a layer Lo coms i an ximply ask a 21 very bunch of highly charged, leading gestions to videh they 22 kane the witzess is ening te say, "I take the vifen. there is 73 ve ewidestinry ball advasend wikh Kore minhions, bears ihe 1 Jiet Lawyer argument tial cosen'l so asytodog Cer anpbesy. So 23 both sides could ask a hundred questions, they could hots be SUOTTAR WATRICT ATROATTRG, P.O. Pret 1p Taetgios 1 leasing, tig cools bulh be skact oppusile goratione, Tae © iteenser wna say the TES to enrveticg, ad hes yen look BL re fev ane vo. av, okay, tow vo. Ga impons ar adverse 4 snfersnce avatiet aujbecy Joi vant to based on the giestices I that the lawyers asked, 1 mean, that's really what this cade Tip baite, aE nln a wares oF hime, meR IR 47 0F =n reifeeniaey Po sidoiveie : Tien the last point, widen I'm Just guing to teed to 3 corrach We. Carell of, Khe plaiehi Te ware mavieg somos fu 10 ve vere iLimely 0 tol dexicralisg porlions of Lise 1 cepusilivie wnich ve believe ate violly dissmissible, st toe 12 peize of oir reply was, wait a mimite, yes didn't desigate acy TI oT En Lerkimey LED AThar ba desicualion dala wa over Ie) iCentinine un hekt pagel 5 1" 1 1 1: - 2 a SUOTTAR WATRICT ATROATTRG, P.O. Pret PE eoaTn: 1 ME. TAGLINE: fvunlinoes] 1 wua'l vere abut tial, 7 hn, yen keow, | mean, entre isa te deal wits teen fassen, 3 av wer) deal wil Lom so bea Liming ia 07 “0 Gemsen.ece Lo 4 me, bit Um net complaining aboit it, I'm Jet zesposiin to ES H it Sor tiene reazem, yur cnmor, ge reeset alles mbes Lu preseil any asveser diosisive com Lisss wiliesses. ¢ Tey should Zot Just be part of tile trial. Thank yun s WAL CRSSL 15 reply, your Cover, | ERIK you aus 10 irl see Crow Le _prel. Lier walls coits Lo be tappeticg al IL lide Lefel. Teds de Lie sdeecl Goole Scum Be. Pagliove. 12 mrazeasrical menopirany. TRAt'z geich to be the armmest from 13 bee elvan ride. Meyten obvieurly abillad Le aduases Wal 11 argument. Bit that's what Me. Gliiize la gelig to fess to 17 Eeapesd te at thc trial. And, of courac, the fury will thik To ein de a Cwslarlical comspiracy iT Me. GC Cre doessl evar Ti being in some ol Lie alleges conspielors sch es Spaleis, 1: sellen, ans Marciukova. 1: hove, wnt 1 Fear ta Gir in omeRew 8 hearsay insin PE ser SEVESLZL. Tein ix vel 4 hearsay. Trare are coivg Lo be 21 witnesses in the case, gedticied and cross examised. fo thie 22 dante a cuestien of inadmissible hearsay, this 4s a mucstien of 73 preeshivg a wikees bo tee Surv. a TES COURT: How wo yuo Ledek bide sedoencs le Atle 37 going te go dn by way of either depositics ox the depoaiticns SUOTTAR WATRICT ATROATTRG, P.O. Pret PE eoaTn: 1 elreasy taken 3 BE CHEAT: == or by Le wileansas being compel lod Lo 1 come ane lveke anc so en? 1 thlzk we know hew that's golig to I werk cst. H LE J FEE CAL FPR PX PN Ee PL be Lung Lie depuedbivn Liel's bess ecuiies. : With ME. Spetein, ve're going to bring him here live 3 boanine unten boos able fe reach Sim by sibponta, Bik bres tuo TT tae bee 6H TL Lo rest by sobpowta, Lralls why wate 1 lake Leeds deposilive. i” cd 20 Wr. spotedn will eesrify live, te wnild invoke, 13 Hadia Mareickous avd Sara Zelles, Lee deperilio Ran already 1 been taken. Rie dn oir 5 Tau GOULET WEGt de you do aboit the Statement that 16 counsel Trl made abo.l La impropricly of Lie deslionT 1 ME. CRESTIL: Rignl. fo yuo cen'l lesb sey, fey is 15 the mou mace of gress coeese aie they fake tie FIZ Yeu 13 manth pen Kak in, and Aeeky reeqeiter beak. Thorn Ras fe be JE isepaniatl. seicence Lal sporty each arlion Lalla asbus a 56 se iat we've done in eur brief, if yeu lock at 22 page 17 of eur initial paper = iF © ean fuse illustrate ene. a WE COURT He, Waki al) right. Weakts Tite. 1 gob a tee petat tH MAL ChESsLL: ight. Sut) think this is a fair peist SUOTTAR WATRICT ATROATTRG, P.O. Prep PE eoaTn: 1 abucl lie teieies, I'm fel ere Lael Lis gel Lie podat © bemminn ete said terete oo miesnion 3 TE CHURT: Ton th worry abo L ad.caling Lem. TLE we 1 geitve get to esate E Mi. GASElL Eo 1 wesld ust direst you to our -- © unten meind kn how, HEIR i7 6k A ment made oF arene sheen, we have very speeioi sppeil sue se : Tas COUIT 1 hear you. 1 bear you s MAL CEL == of the cuerkions iE TCHR: Voutwe Gol iL it Lie briet. T _rderslan 1n MRL CRESTLL: Rial. 1” in with rogare te their izternst in the ease, TI ebeianly, Key aes ae DnLarerl i LRin vem wo in acesin 11 them of Leiag Livolies 4 a eek LraIiiching ane sex abies 17 conspiracy having her lese thls ease. They wesld be poppisg 16 cumpaie orbs. Trey elaarly Mave ar inlararl is Lre care. 1 Tie olter problem, cemenber, er Svuly, Lie goesliv 1: ds well, are these witnesses that the plaintiiZ Las some 13 conhrel suari In thin romchedy than thn Anthdach Far wncred 20 combrol over Lrese Cache? 2 Taese vere direct reports. 1 don't thik 1 heard any 22 reapesc to that from the ether side. these worn direot 23 reports te Maxenll, avd so thera are Ko poopla wre, vo row, £1 ween Me. Giiiiie alleges Lisl sie’ livoloss Me. Mevell de 27 dsvelves in doing these things, these ave the vomen wie are SUOTTAR WATRICT ATROATTRG, P.O. Pret PE eoaTn: 1 ekeciling tie urdese Zur Me. Marvell, sis AU's sol perl us © carnastienl ansapirany. 3 HIV we wae Lo do i ave Lie Jury bere Lis 1 informatic. We've provides in oir brie: very speciiic support I zor cach of the cucstions THST we wast te ask. we thizk it's © nehively appropriate than te ary Sear wean tenn tan Save te 1 eap : TE CoUIT Thank yoo. s Were are we oul Ver. iE Mi. WERETHERR: Toor Parr, by wy exliselion, we Fave 1 une molive Let, which ds se wilh Lie upenig Likes, i” ee en and what's Thani iE Mi. WETHER: TL war aur welion Lo prov ibid 11 qiestiening os oir client regarciig Ger consensual acult seal 17 activities. 1" TL CHAT Ven 1 HEL MIEETGIR: Jo 1 Leke Lial ax o po ateat axe Lal oe 1: we a hn » MOL WERTHGTR: Okay. Twaseil sore 2 Ths COUT Yee, well 1 ean Gnderstand. 2 sow oan vos pessibly know what we're nize te de vies 23 donth kee wah wntro going be doi a ME. MEKKTNGER: Your Boor, I'm happy to seier tale 37 sasie. 1 believe it is someuiat SUOTTAN WATRICT ATROATTRG, P.O. Pept 1: eoaTn: 1 THD COURTS Yee 7 ML MRI om eemeted with sewn of Te otter 3 waliors Lal, Based on plaichi™T ts reprase-babion, Ley wal Lo 4 pit ei until asctier day, se satdl the 13 days belore, fn I partiealar, se I'm Lappy to wait. H We LAT ce dee teat Tigin —- 1'm sary. T Daplais Lo me bow Liab oig.ces ifle Lis : ME. MENKINGER: Inte this metioni s WE COURT WaT], en are the Ringe abel which 10 Leer Fave Lo ive “olice 1n ME. MIKINGIR: Saeclly, yues Sosvr. Tee desnw dn 12 iz merion, ace 111 trv to he Sligtely eirmmspeat, hie in 13 Weis welier, we vave agreed Lal oe alien ee be aren 11 examines VAL. respect te plalitiz, any of platitiii'e 17 allegations, with respeot to ay other mizer victim. our 6 elienl run absol Lely denind buvivg beer Pecoluad seal ly wile Ti plelsliil or wil Lie mizor ciclim 1 Tae veils Like to intrecice evicence of sume kiie 13 nuary sfrer seke wits ebrer propln. They Rave ok veh JE speci iad, apparesliy, comlelely, wal oliar sels an ural 21 other people they're talkisg abeut. 2 ms GOVE de | thizk we shesld = a WoL WEKTRGAS Rig. a THD COURT Bu I tadik we etoile vedl Gitil ve get it 20 all. okay. fo that takes care of that. SUOTTAR WATRICT ATROATTRG, P.O. Prep 6:5: eoaTn: 1 ME. MCCBMLEY: Toor Furr, there's Duel one more lidag 7 pressdirally, £1 asild flan whe ieire while | Rave yer 3 alekion Botore ve all Tara, al would be alpr.l 1 THE COURT Don't went en At. E BE. BoGANLEX! Sorry. H wear vee ¥ HEL MGCRRLIY: TL'e Jes, di gues vives sbuol Lie 361 and the deste wth the nen procicticn, yeu sald that we sheild 3 suggesh bearicg dates. | sen ran your Coser has mowed bee 10 rearing calex Lo Mactesiars, ro ve vers Fopity Lo, nitce 11 lieze's wily = Sev Pedieseys lool beivze var Lisl, sessive 12 ene of those te handle thar Searizai iE A COURT Wall, Thm ak sre n ME. MCCRMLEX: Or viatever cay veils werk. 5 Tau COLE Be. Okay. Kew, §t seems tome, correct Tome iT Thm wreng, on Le ale watre gait Lo do Tpeleints weliow, Ti Lee epusilivs vesigralive, Lue bilorcelio: 1 MIL CHEEZLL: I'm surry, ve Just Sic that. 1: Tou GUA av Hen wav, mabe wn ceils de thn 28 bitorcation fxs vary cickly. Beal ix iL yo. wal Lo 2 MA, ChSSALL: 1 TRASK ve Jet Gié that a ew momenta a WoL MACHETE Peat wr Kee ovo about bee Timasaial a revorce. tH Ta COLE 37 whats SUOTTAR WATRICT ATROATTRG, P.O. Pret 1: eoaTn: 1 HE. MCCBMLEY: We Jiel ele biel abucl Lis liesciel © vemenn, ad ye ques ue some diveeties ee than, sn than sents 8 wees 1 THs COURT Oh, okay. fo that's dene. Okay. fo 3 her's the Ith. z MeL MeL: tne. sn ees teernte april 1768, unin PT belies de Lie cullociig Pediesiey, si Lie 1 Leich Lie wie © aster that de the Loth. s WG CHUARS el, are wn goivg te de a bearitg —- | 10 Lake BL wate going Le Ge @ Peariog on Lie recorsideralion noe 1” MeL MELT Rants wan Lm talking shee, ges 13 Forer. Um sorry. Ves. de balls ten evidesbiney iso. eT —= 11 gun eat they coils preesit a Sorensld, bases Gn oir vieer ui 17 reommsideratien of the bevember Zid, fo that's tie date U'm 16 looking Tor. Thm serey, T she.ld have bees clearer abo l Lal. 1 TOI COURT: Mer are ve volte Lo do Lial? 1 ME. MCCRMLEX: Mage the Lith ox the 13th pussiblyt 1: He Ga Coe abet ta 106 » Mi. MeCTRLETE Gay 2 Ths COUST Joes that werk Zor you alll 2 Mi. PAGLIVGAD | saz’ de the 9th, veur sezer, I'm in 73 a deporities all day i= Colorado. 1m orev. a TED COURT: Huw wunle yuu puseibly Lek solier cece? tH MIL BAGLIVCA: Well, believe me, 1 have a lot of SUOTTAR WATRICT ATROATTRG, P.O. Prep PES eoaTn: 1 cliente Lieb are capiog Lieb wxecl same Lily 2Lil Sow, yout 3 M3. WEKTHGTR: Your Torr, co.ld we do bre 1305, Lhe 4 Teizeday ui that weeks E Tau COVERT Eee. 1 GORE S00 AGF KEAIC SOT TOL 5 okay ¥ HE. MGCRRLIY: Tael's ald 1 hed, gues Tur. Tasch gus. And thank yus for your patisnce, everyone, today. s COUNT: Faves we completed tha brinTing avd 10 weerglning eonrybody varle Lo sbuil on Lie black book izz et 1n ME. MGCBLIY: Mell, ye, yout Suivi. Su fue, as oo 12 ae mighr, it was S21y hriofed, sn there are three briefs oz TE i anmenlial le Da Sad a mekios i Limite Le allow iis, 11 they hac a motion dn Limine to exclice At, ans Lt came Gp 12 previessly —- 1 forget, we argued it a couple vecks ago in the 16 coral of arelrer mokion == of, Thm sorry, bucs.se, voor Tr Toror, goo tegoesled Lal wilt tespect Lo diate Tlores. fo ve 1: cion't reargue it tosey, it de Tully brdetes for you. 1: Tou Guat Okay. I= etter words, |lun Gok cunrvtsicg 2 a bral a MEL MOCAMLAY: You Se. OUI ROTer, je. 2 Tas covsr okay. ssyehize elani a MeL MACHETE Rot Keak 1m agar of. a MIL PRGLICGE: I tack we're conclices tusays joot 2 menor. Task you. SUOTTAR WATRICT ATROATTRG, P.O. Pret PE eoaTn: 1 THD COUETS Okey, Lusch, Fave a sive veeheis. 1 1n 1% n 5 1" 2 1 1: » a a SUOTTAR WATRICT ATROATTRG, P.O. Pret UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA 1 GIUFIRI, H v H i 15:0y-07433-RWS GITISLAINE MAXWELL. i Defendant. H Defendant's Response in Opposition to Plaintilt’s Omnibus Motion in Liming Laura A. Menninger Jellrey S. Paglivea Iy ties TIADDON, MORGAN AXD FOREMAN, TC 1581 Last 10% Avenue Dever. CO 80203 FRITH TABLE OF CONTENTS LEED. R EVID, 40531 REQUIRES ADMISSION OF ALL SPECIFIC INCIDENTS OF PLAINTITF TYING OR ENGAGING TN DECTITTUT, OR TRAUDUTTNT CONDUCT | A. All allegations or corments made by PlaintfT are *eonnceted Ur the alleged defamatory FA NN SO Be ROSpansos 10 ENCE MOYIONS 57 LOINC vss sess © 1, Swuies aud allegations conserning Desshoneitz. foreign presidents, and world leadess ars highly relevant ind admissible (MoU i TATE roo 8 2. Mecing Bill Clinton at Jeflvey Tipsicin's private iskand twice (Motion in Tinsine 2).... 8 2. TOI responses und related materials are admissible (Maton in Timing 3.......oo..... 4. Tanai Froeh's lestimany and report ars admissibls svidenee {ation in Liming 3... 9 5. Prince Androw and Buckingham Palace's denials of Plaintifls claims ars not niferad for the truth of the mater asserted (MOON 6 LASS). 11 6, Evideace Regueding Phaiatifls Sexual Mistry ad Reputation is Adutissible (Motive in TPT aot prohibit se of swords sash us “prostituls.” which she wed to dsseribe osselt, ov fy other “derogitory”™ feruts that describe bet sspucativn (Motion in Lisine S$. Plaintifl's drug use is relevant by her memary and lack of mages (Motion in imine 9. Information regarding Plainri’s criminal history is relevant and admissible cvidsnce when chacacter is an essential elewsent of the claisn (Motion in imine 9) 1® 10. Toidenue concerning sehuol altendance is relevant Lo Plaintill*s allegations af how the <pent her tne in 1999 10 2002 {MAOHON 1 LINE 10Y cs 19 11, Plaigut? pur bee toll chihood history sal character at issue Moto io Linas 11). 20 12. Victions Refuse Silence is a sham not-for-profit established to crete a claim foe AOTAMELIN PET 50 IVHION 1 LATING 12) rms 20 i 13. Phainti's faitoce to pay her personal tax obligations is relevant to hc chiacauter for Ath abs (MOO i LING 13) eos 22 14. Plaintifl's hushand"s domestic violence against her in arch 2015 is probative af other intervening casos of eencianal distiess snd related damages (Motion in Limine 14) 25 15. Plants lies above her age and the year she wee Mr. Epstein must be exposed o the 16. Alar Plainii%s medical records ane relevant to PLaintfT's damages claims Mion in 17. The Parties agree to preclusion of all documents and discussion of the Jane Doe 102 eas, including, the settlomont of those ehiims (V10HON in THE 17) ere 20 18. The Cassell Edwards v. Dershowitz litigation is relevant ind adreissible (Motion in 19. Judge Marr's ruliag is elerant sad admissidle {MOTo0 ia Line 19)... 29 20. The tenscript of he wpe cevordiag of Mr. Decshowitz’s conversation with Rebecca Haglan i dmisesible (NOGA 10 LANE H0)..oeeee 31 C. Plaintifl’s Remaining Motions In imine Are Premature and Regusst an Uinisvessars Advisory Opinion (MOHOBS in LIM 21-29) courses: 32 2 Discussion of missing witnossos and avscace of cvideuce is apprapriste, and missing WilTESS WSAUON LY DE RUSE... rrr eres 35 ii ‘TABLE OF AUTHORITIES Cases Brady: Chemical Consmiacsion Corp. 10 F.2d 195 (2d Cit 198). 1 Camnisivset vi Kirsoppn No. 1:10-CY-950 MAD/DREL 2012 WL 3089657, 41-2 (N.DN.Y. Condit v. Doubleday & Co, Tne, 5182 638. 639K 26 Cr 1978). 13 Chomble v. Hareis o Harts tac... 15% 1. Sopp. 24 670, 681 (SDR. 2000 cn 22 Chnaskova v. Kab, 9%5 Fd 79, $1 (8 Cit 1993). I. Danicls by Glass Wal-Mare Serer, bc, 634 $0.20 58, 93 MISS. 193d Dtianlv €arign B16, SH N.Y S20 483 (2 1D VK corre 35 Dodd v. ON: LSA. 49. 101 Ed 448, 459-60 (th Cit. 1996). 10 Dounelfs v DeChristofors, 416 115, 637. (46-47, 94 S.C 1865, 40 LId.2d 431 (1974)... 33 Edwards v City af ¥ 2. No. 08-2199 TLM, 2011 WL 2743665, at *4 (ED.N.Y. July 13, 2011) FOC v. Grigf Brathers Carp, 18 TRI. $9, 61 62 (FDNY. B03. 33 Tiguas Employment Oppuociuity Comm v. Reed Pierce's Sporoman's Geille, 11, No. 3:10- CN-S41-WHB-LRA, 2013 WL 12133370, at *L (5.0. Mist. Ji 11. 301 mrss 2 Gailind v. Jan's Water Service, fae.. S35 FI TT1, 778 739 (8th Cit, 2008). 22 Geran v. Fil, of Awioct, No. 09 C 6992. 2015 WL 127917. at *7 IND. Ill Jan 8.2015)... 9 Gordy Co. v. Mary Jane Girls. Ti., No. 86 CIV. 6514 1RWS). 1989 WL 28477, at *6 (SDNY. Mar. 24, 19) SARE Re ALY Gow of Virgin Islands v. Gros, 775 F.2d SUR. S11 & 1.4 GA C195 cee 3 firaaswov. Maer. 50% N.Y 5.2 376, STR BADD 1 ces Cicerone. Hasler Magacine, ic. SUK E24 29% 313 (2 Cit. 1986)... 13 ii Jae: ». Redmond. SIS US, 1. 116 SCE 1923, 135 LEL2I2IT HI) comers 22 Kondous Jolson dnc. v. 0) Amico. No. CIV.A. 10-2869, 2012 WL 2190897, at *1 (ED. La. Je Kevorkian 1: Am. Med. sy'n, 257 Mich, App. 1. 12. 602 KWAI 233, 230 (199). 13 Samgoni v. Ala. Sane itr, 131 FRA AA ATS (MDA oneness Minemper v. Refloc Representative, Ine., No. 1 C1763. 2012 WE 379904, at 4 0.0. II. eb. OBrien v. Alexander, 398 F.Supp. 162. 171 (SDNY. 1995) a 0 Latin Denia, $8 E30 136. 141 (4 Cit, 1996) vn oes: 33 People v Thomas, 21 N.Y 1 236 (2013), —— " PO. Peaphev. Wiiians. SN.Y 30 732, 734 (2003). = > iis Prefered Properties. duc. v. Ilia Ro cr Lsiates. fic., 276 F.30 790.799 05 16th Cir. 20021. 13 Rowe v. DPI Specaalty Foods, fn... No. 2:13-CV-00708-DN, 2015 WL 3533844, al *5 (D. Uh S.C v Collins ok An Corp, 256 ERD. 405, 312 (SDNY. 2009 cr 19 Seger v. Tine, tne: 142 F.3d 1361 136475 (10h CIE 19 oe Svligoon, Morris & Neuburger v Fairbanks Whimay Carp, 257 N.Y. 5.20 70 (1st Dep, 1963135 Sido vi Reo, 95 CIV, 955% (KMW), 1998 WL 164823, "2 (S.ON.Y, APEL 7 1998) smn 35 initedt Sates » Dota, T27 E20 340 37 (0 Cit 19841 mms mss 17 Tinted States v. Hatchets. 918 F263, 6H 16h Cir. 1990) corns 22 ited! $105 v Lujan, Ko, 05 CR 924 (RB DNM. MAL 25. 3001) rns 32 Tinted States v. Picks, 981 F.2 706. 713 (4h Cie. 1992) 3 Tinie States v. Rabbani, 382 T. App's 29.42 (2d Cir. 2010) wun8S, Tinted States v. Rodunson, S53 F 30 1265, 1272 (10 Cit. 2009%. coc | T Tinted States v. Var Meerbore, 548 T2015, $17 18 Q2ACI 1976) srs 17 iv Tinted States West, 58 F.30 133, 141 (56h Cit. 1995) vcs 22 United Sates v Wander, 79 E2526, 529-30 (24 Cit. 1938). comms comms 33 CR SH SR I, So SEE World adc Ass'n of Specialy: Programs v. ire, ive., 430 £3 113%, 1138 (100 Cir. 2006)... 3 BR RR LN PE CTE TY STR TIT —— Rules Bod HOARSE Wiimote OL B20 EE LL er IA BOE BUSI mmm m——— TU eR BT Fed. R. ENid 90204) 800 S021} ces WN v PAGES 1-36 REDACTED Dated: March 17. 2017 Respectfully submited 5 Fawr of. Mnninger Lavra A. Menninger (LM-1374) Jeffrey §. Paglinea (pra ba vies) i 2 (pro hae vice) Tavion, MorgAN AN FOREMAN, P.C 150 East 17" Avenue Denver. COR Phone: Fux: Aitoress for Ghislaine Mivovell CERTIFICATE OF SERVICE Sigrid, MuCimvley Pali. Cassel Meredith Schultz. 328. Liniversity Strat Bus, Seal Tus, LLP Sal Le Cie TT 64112 01 Fast as Olas Hovlevarel, Se. 1200 [ Fi. Lauderdale, FL 3330) Budiey J Edwards 49 Twin Lakes Bd. TARMTR. JATTT. WEISSING. EDWARDS, South Salem, NV 10590 FISTOS & LEHRMAN, P.1 |] 425 North Avdrews Axe. Se 2 HL auderdale, HI 33301 38 Night Flight They say that you can read a pecson’s feelings on his face. But if so. either I'm a very good actor the opposite of what anyone who has warked closely with me would tell you or the journalists ¢lustered in front of me weren't very good face-readers. They said that T looked defeated. Distressed. Depressed. Yet as 1 delivered my brief final statement outside an olive-green cabin at Carn David, the Amenean presidential retreat in the forested Catoeun hills noth of Washington, | fel none of those things. Yes, Twas disappointed. I realised that what had happened over the last 11 days, or mare crucially what had nof happened, was bound to have serious. consequences, both for me persoually, as Prime Minister of Israel, and for my country. But 1 had been a politician, at that point, tar all of five years. By far most of say life, [had spent in uniform, As a teenager, small and sight md nol even shaving yet, [ was one of the founding core of a uni called Sayeret Aatkal, Istael’s equivalent of America’s Delta Force, or Britain's SAS. It may be that the way 1 thonght und acted, the way 1 dealt with danger or with crises, came from someplace inside me. Even as 8 young kid, | was always quiet. serious, contemplative. But my 13 years as a part of Israel's main special-forces unit, espeelly once | becume its commander, etched those qualities more deeply. And they added new ones: a sense thal you coubd never plan a mission too carefully of prepare wo assiduously; an understanding that what you thought, and certainly what you said, muttered a lot less thin what you did, And above ull the realisation that, when one of onr ightlime cormusmdo operations was over, whether it had succeeded or failed, you had 1o fake a step back. Cvaluate things accurately, coolly, without illusions. Then, in the light of how the situation had chimged, you had to decide how best lo move forwind, I hat approach, to the occasional frustration of the politicians and diplomats working alongside me during this critical stage of Israel's history, had guided me from the moment | beeame Prime Minister. In my very first discussions with President Clinton w year earlier — a long weekend, beginning al the While House and moving on to Camp David — T had mapped out at great length. in great detail, every ane of the steps | knew we would hive to take fo confront the central issue facing Israel: the need for peace. 1 In choosing Lo retura, now, ww Camp David for Lwo weeks of summit talks, T Kaew the risks. OC all the moments of truth in my life — and in the life of my country tow, it any, would camy higher stakes, Success would mean not just anc more stiter-step sway from our eontury-long conflict with the Palestinians. Iu would signal a real, (inal peace: in Leeaty-speak, end of conflict. Whatever the complexities of putting an agreement into practice, given all the suffering and bloodshed endured by both sides, we would have crossed a point of no return. There would be two states. for two peoples. And if we failed? I knew. if only from months of increasingly stark intelligence reparts, that an explosion of Palestinian violence not just with stones or boliles this time, but wilh guns nd explosives — would be anly a mater of time. knew something else as well. This would be a moment of truth not just for me. Or for Bill Clinton, a man who understood our conflict more deeply, and was more determined to help us end it, than any other president before him. Tt was a moment of truth for the leader of the Palestinians, Yasir Arafat, The Oslo Accands of 1993, groundbrealing though they were, had created a peace process, not peace. Over the past few years, that process had been lurching from crisis co crisis. Political support for negotiations was fraying. Aad yel the core ssties of our conflict had not been resalved. In fact, they had hrdly been talhed about. The reason for this was no secret. Lor both sides, these questions lay at the heart of everything we'd been saying for years. to the world and to ourselves, about the roots of the conflict and the minimum terms we. could accept in order to cud it. Al issue were rival claims on security. final borders. Israeli settlements, Palestinian refugees. and the future of ancient city of Jerusalem. None of these could be resolved without painful, and politically perilous, compromises, Tintering the summit, despite the prossuces ahead, T was confident that I. with ny team of aides and negotiators, would do our part to make such a tinal peace agreement possible. Nor did 1 donb tat Presickent Clinton, whom 1 had come io view nol just as a diplomatic parties bu a friend, would rise 1 the occasion. But as for Arafat? There was simply no way of knowing, That wits why | had pressed President Clinton so hard ta conveng fhe summit. Thal, wees why, despite the misgivings of sare of his closest advisers, he had taken fhe plinge. We both knew that the so-called “finul-status issues™ 2 the substance of any real peace — could not simply be put off foreves. Untangling them was getting harder, not easier. And we ealised that only in en environment like Camp David “pressure cooker” was how | described it to Clinton, und 10 US Sceretary of State Madeleine Albright — woukd we ever discover whether a peace deal could in fact be dane. Now. we knew. xox Iscuel’s equivalent of Air Force One. perhaps in a nod to our country’s piancering carly years, was im almost prehistoric Boing 707. 11 was wating on the ruwway at Andrews Air Force Base outside Washington to ferry me and the rest of aur negotiating team back home, It contained i lowsrent equivalent of the American version’s presidential cabin, and a few 1960s-vintage first-class seats. but consisted mostly of two Tong lines of coach seats, three abreast, separated by an alist tightrape-narrow aisle. 1 dare say 1 was alone in finde an odd sense of comfort in boarding the plane. This museum piece of an aircraft was part of my past. Tt was the same model of 707 for which 1 with a couple of other young soldiers and engineers. had come up with whit we dubbed the “submirine door” system outside the cackpil lo protect EI Al pilots from future sucks aller one of iis plies hid been hijacked to Algiers in the summer of 1968. It was also the same kind of plune a Sabena tight, hijacked to Tel Aviv's Ben-Gurion Airport which 1 stoned, before sunrise, four yes later with a free of nearly two dozen Matkal commandos. The shooting was over within 90 seconds. One of my men a junior officer named Ribi Netanyahu was wounded. By ane of our awn bullets. But we manged to kill two of the heavily armed hijackers. capture the aters, and fice all 90 passengers unhaned Still, even [ had to accept, it was no fun to fly on. As we banked eastward after takeoff and headed out over the Atlantic, the mood on boasd was suber. Huddling with the inner eure of my negotiating team — my policy co-ordinator Gilad Sher. security aide Danny Yatom and Foreign Minister Shlomo Ben-Ami I could see that the way the summit ended had hit them hard. Tt was probably true, as all three often reminded me, that the greatest pressure fell on me. | was the one who ultimately decided what we could. or 3 should, offer in search of a true peace with the Palestinians. T was the one who would be blamed by the inevitable critics, whether for going loo far of not far enough, or simply for the fat the deal had eluded us. [knew the drill the same hing hod bisppened when | id come tmiahizngly close 1 Fafizing 1 pence deal with Syria's then-dying dictator, Uafez al-Assad, a few months earlier. Yet these three dedicated men — Gili, who was by training a lawyer: Shlomo, an academic: and Danny, a former Mossad chief — had just been though dozens of hours of intricately detailed tall with cach of Arafat’s wp negotiators at Camp David, not to mention the dozens of other meetings betore we had even got here. Now they had to accept that, even with the lid of the pressure cooker bolted down tight, we had fallen short of gelling the peace agreement which each of us knew had been within touching distance. 1 don’t think that even they could be described as depressed. On our side. afterall, we knew we had given ground ou every issue we possibly could. without facing full-scale political rebellion at hame. We had proposed an Iscacli ‘pullout from nearly all of the West Bank and Gaza. A support mechanism for helping compensate tens of thousands of Palestinian wefiges from the serial Arab-lseacli conflicts of the past half-century. And most painfully and controversially — my rivals and critics back home were already accusing me of “treachery” we had agreed 1 lel Presdent Clinton present a proposal for the Palestinians 10 get soverigaly over the Arab neighbourhoods of Jerusalem as well as “custodial sovereignty” over the Ilaram al-Sharif, the mosque complex perched above the Western Wall, the holiest site in Judaism But precisely becuse we had been sad 10 offer so much, only for Arafat lo sefiect it all. even as a basis for talks on & final deal, T could sense how gutted my key negotiators were feeling. Sill, Um sire none of them was surprised when my own old operational instincts kicked in. In my stawement to journalists, | had been careful to say that Arafat was net ready at fhis time to male the historic compromises needed for peace, Bul before partmg with President Clinton and Scerclary Albright, I'd. been more focthright. 1 was clear, without my saying so, that the ehianees of our getting a peace agreement on Clinton's watch were now pretty much over. Tle hat barely five months left in office. Yet my deeper fear was thi with Arafat having brushed aside sn offer tht went far further than auy other Ismchi hud proposed — far further than the Americans, themselves. had expected from Iscael the prospects for peace would be set back for years. Perbips. 1 said, for wo decades. 4 The challenge now, T told my exhausted team, was to make sue we were prepared for this new reality. Pact of the spadework was aleady in place. Much as ['d hoped that Arafat and [ could tum a new page in Middle Fast history, | Tie directed our army ehicl-of-stalT, mine months before the summit, 10 draw up contingency plans for the likelihood of an unprecedentedly deadly eruption of Palestinian violence if we were to fail. Now, | felt we had to go even further, and to prepare a proactive alemative 10 the negotiated deal we'd been unable w scour. | proposed considering a sntlatera! 1sraeli pullout from the West Bank and Gaza. The territorial terms would, necessarily, be less far-reaching tham the proposal Arafat had rejected, Bul | fel we should still withdraw from the great majority of the land we had captured in 1967, stil leaving the Palestinians an area which the outside world would recognize as wholly sufficient for them to establish a viable, successful state. Aud crucially, this would finally give (sracl, on country, a delineated, inal border with the territory captured in the Six-Day War. Gil, clearly uneasy about accepting the idea that the chinces for a negotiated peace were definitively gone, lefl to ry tw gel some sleep on the long Night ahead. Danny and Shlomo Ben-Ami as well. Within an hour or so, the plane was full of irreuularly shimped bodies, the silence broken only by the drone of thie 707s engines and the occasional sound of snoring. 1 sa, wide awake. in one of the seats at the front. My sleeping habits were another inheritance from Sayeret Mathai, During those years. niemly everything of significance which 1 did bud lsppened atic sundown. The commando operations were, of course, set (or darkness whenever possible. The element of surprise could mean the ditference between success und Fenlure, indeed life and death. Bud sll of my planing, ull my thinking, tended to happen at night as well. The quiet, and the lack of distractions, helped to discipline my mind. I found that it helped to free my mind as well. sometimes anly lo discover that it went off in mespecied dircenons. 11 did so now. Perhaps oven | was still reluctant 10 accept that Camp David meant that the opportunity for a transformative deal with Arafat was finished. Yet whitever the reason, 1 begin thinking bic to the first ne that my path and his ad crossed. 11 was in the spring of 1968, nearly a year afer Isracl had defeated the armies of our three main Arab enemies Egypt, Syria and Jordan. Israeli forces were advancing on a Jordanian town called Karameh, across the 5 Jordan River from the West Bank, from which a Nledgling group called Fatah, under the command of Arafat, had been staging a series of raids. In une of their most recent attacks, they'd planted land mines, one of which destroyed an Lane sehoolbus, killing the driver und one of the leachers and injusng nearly s dozen children. The so-called Bautle of Karameh was our single most significant operation since the 1967 war. In pure military terms. it succeeded. But at a price: more than two dozen Iscacli soldiers dead. It also had a major political impact. 1 caused shock among many Israelis. still wrapped in a sense of invincibility fiom the Six-Day War, as well as a feeling in the Arab world, actively encouraged by Arafat and his comrades, that compared ta the great armies Isvael had defiled iu 1967, Vatah liad at least shown fight. Vaal had drawn blood. 1had just turned 26 years old. Iwas finishing my studies in mata, physics and economics at the Tebress University in Jerusalem, and had joined ny Saperet Matkal comrades the night before the assault. 1 was a huge operation: ten battalions, including crack infantry unis. Our own role was relatively minor. We were to seal the southern enmnce to the lown. Bu it proved a longh slog just to get there. Our vehicles got bogged down in mud. By he Lime we arcived, Tatah fighters, although many were in civilian clothes so we couldn't be sure. were racing past us in the other direction. One of them, we were later told, wis Yasir Acafal. Ona moloceyele. Tt would be nearly three decades before the two of us actually met — shortly after the assassination of my langtme comrade und friend Yitzhak Rabm, when 1 trad bivome Foreign Minister under Shimon Peres. But in the intervening years, Acafat was sacely off of my radac. By the early 1970s, he and his (ighters had been expelled by King, Hussein's anny from Jordan and were re-based in Lebaron. Arf wiss becoming i significant figure on te Arch und world political stage. and an incceasingly uncomfortable thorn in Terael’s side. Twas hiead of Suverer Markl by then. Over a period of months. I drew up a carefully constructed plan — a raid by helicopter into a Fatab-dominated ara in southeastern Lebanon, during one of Arafat's intermittent, mucale-boostiog sits from Beirut — to assassinate him. My immediate superior, the army’s head of operations, was all for our doing it. But fhe chief of military intelligence said 20. Asafa, be insisted when we met to discuss the plan, was no longer the lean, mean fighter we had encountered ia Karameh. “Ile’s fat. Iles a politician. Ile is not a target.” 6 A decade later, the idea would suddenly resurface. Tn my first meeting, as a newly promoted Major General, with our then Defence Minister Ariel Sharon, Sharan tumed to me and the armys Chief of Staff, Rafael Fitan, and said: “Tell nie. Why the hell is Arafat sill alive?” He looked fins a Raul, then al me, and added: “When I was 20 years younger than you ace, | ever wailed for someone like Ben-Gurion or Dayan to ask me to plan an operation. I would plan it! Then Ud take it wo them and sey, you're the politicians, you decide, but if you say vcs. we'll doit” 1 smiled, telling him that ('d done exetly thal, a decade cali, only to have one of his mates in the top brass say no. Sharon now said yes. But the plan was avertaken: by his ill-fated plan to launch a full-scale invasion of Lebauon in 1982, tacgeting no just Arafat, bu with the aim of crushing the PLO militarily once and for all. 1 finally met Arafat face-to-face at the end of 1995. Although the Oslo peace process had dramatically changed things. it was olear that the real prize — real peace — was still Rr away. We were in Barcelona. for a Euco-Meditereancan meeting under the auspices of King Juan Carlos, aimed at trying to re-invigotate negotiations. The ceremonial centrepiece of the event was 3 dimer at one of the soyal palaces, and it was arranged for me and Arafat to meet for a few minutes beforehand. T arrived firs. 1 found myself in 2 breathtakingly opulent. but otherwise crpty, toon. Empty, that is. except for a dark-brown Sicinwiry pro, Ueom ehildbond. J have loved music. And while {am never likely to threaten the career of anyone in the New York Philharmonic, I have, over the years, developed some ability, and drawn huge enjoyment, as a classical pianist. pulled back the red-velvet heneh and began w play. With my buck to the doorway. Twas unaware that Arafat had arrived, and that he was soon standing. only a few feet away, watching as 1 played ane of my favourite pieces, a Chopin waltz, My old commando antennae must have been blunted. [ may not have become “fat”. Bu, undeniably, T was now a politician. ‘When I finally realised Aratar was behind me. I tamed. embarrassed. stood up, snd grasped his hind. “11s 4 weal pleasure to mee! you?” | sand. *) must say | lave spent many years watching you by other means.” Te smiled. We stood talking for about 10 minutes. My hope was to establish simple, human contact: to signal respect: to begin to ereate the canditions not to try to kill Arafat, but to make peace with him. “We carry a great responsibility.” said. “Both of our peoples have paid a heavy price, and the time has come to find a way to solve this.” 7 1 sensed, at the time, at lees! the start of some connection. T suspected that Arafal viewed me. as he had Rabin before me, as a “(fellow fighter”. But if so, [ now wondered whether that might have been part af the problem in his ever funly understanding my mission al Camp David. My motivations. Or my mind. Liven in Israel, my reputation as a soldier has sometimes been as much a burden as an advantage. A whole body of stories has followed me from my 36 years in uniform a career which, after Savered Maskal, led me up the military adder until | was head of operations, intelligence, and eveaually of the entize army as Chief of Staff. By the time [ left the military, 1 was the single most decoruted soldier in our country’s history, Some of the stories were actually fone: that when we burst onto the hijacked Saber airliner, for mstance, we wore dressed as a maintenance orew: or that, in leading an assassination raid in Beirut against the PLO group that had murdered Israeli athletes at the 1972 Munich Olympics, [ was disguised as a woman. Not the most attractive young lady, perhaps, though T did. painfully, pluck my eyelashes. and, with the help of four pairs of standard-issue Israeli Army socks. develop quite a comely bosom. I rejected the fee of wenring u fom dress, in Givour of sty hshly Mared trousers. | was going on a commando operation, after all, nol a prom date. But 1 did weae heels. So ves, a woman, of sorts. Yet some of the staries were just plrin myth. | had given up counting the times I"d heard about my alleged prowess in reeording the festesi-cver me on the most gruelling of the Israeli army’s obstacle courses. Tn fact, T was a lot more like Goldie Hawn in Privaie Senjanin, The rin misunderstanding, however, went deeper. The assumption appeared to be that my military achievements, especially in Suverer Matkal, were down to a mix of brute force and raw courage. Courage, of course, wis a requirement: the willingness fo fake risks. 1f the rewards for success, or fhe costs of inaction, were geal cough, lew of the operations | fought in or commanded were without the real danger of not coming back alive. But whatever success 1'd ad as a soldier, particularly mn Madkal, was not only, nor even mamly, about biceps. It was about brains. 1 he ability to make decisions. To withstand the pressure of often having to make the most crucial decisions within a mateer of sceonds. [¢ was, above ull, about thinking and analyzing nd always, always, looking and planuing ahead. And as our place droned ouward towacds Israel. [knew that I would now need ll of those qualities more thin ever. 8 xox This book 1s only in part the story of my life a life that, from my beginnings as a kibbulz boy in pre-state Pakstine, has been intimately entwined with the infancy and adolescence and. now, the increasingly troubled middle use of the Stare of [src Still hess is it only a record of its, or my, uchievemeuts, although they are inevicably a parc of the story. In sefting out fo write it, | was alsa determined ta document, from the inside, the erilical setbacks us well. Mistakes. Mispdgements. Missed epporinmtics. And the lessons that we can, and must, be prepared to learn from them No less so than | when | was planning a hijack rescue or a cross-border commando operation in Saverer Matkal, | remain convinced that Israel's security, Tsrael’s very identity. can be safeguarded oaly by evaluating dispassionately the situation in our country and the world. And by looking ahead. Liven when © was a soldier, [ never stopped thinking this way, especially when first as military intelligence chief and especially as Chief of Staff, 1 knew. in detail, every onc of the scenrily threads thal faced Ismael snd wis part of discussions and decisions 10 wy to confront them. 1suill vividly remember as Chief of Staff, every Friday before the arrival of the Jewish Sabbath. sitting with Rabin, who was then [srael’s Defence Minister. Our offices were along the same hallway of the Arve, the ministry's headquaners in the heat of Tel Aviv. Rabin had a very low table in his office. with twa chairs. We would sit across from each other, each with a ready supply of coffee and Yitzhak smolcing an apparently endless supply of cigarettes, and we would just talk. Politics. Strategy. Tsrasl. The PLO, The surrounding Acab states. And the wider world Many years before I becare Prime Minister, I gave 2 lecture at a memorial meeting for an lsc academic. Nol many people were there. | doubt even they semember it. But 1 do. because what | said bas, sadly. become moc prophetic than even I could have imagined. I talked about the imperative for peace as part of [srael’s security, There was a “window,” 1 said. We were militarily strong. In regional terms, we were a superpower. But politically, resolving the conflict with aur Arab enemies would almost certainly become more difficult with time. 9 Tra, pechaps Tran and other Middle Eastern states, might gel auclear weapons. A violent form of fundamentalist Ista could over time, erode existing Arab and Muslim states, threatening Israel of course, but alsa the stability of our neighbourhood and of the workd. tn hese eircumstimees, even if an lsmach goverment was song enough, wise caough, forward-looking enough to pursue avenes for negotiated peace with its immediate neighbours. getting the popular support cequired would be all bul impossible Ihe windonw is still there. But it is only barely open. 1 fear that I was right, as well, in predicting thar our failure to secure a final peace agreement with the Palestinians at Camp David might set back peacemniking nol ust for a few months, but for many yeurs. | have persisted in trying, very hard, to make tha particular prediction prove wrong. That was why, despite intense pressure from my awn political allies not to do so. | decided to Return to government m 2007 as Defence Minister. | remained in that vole for six years: mostly in the current, right-wing Likud government of my onetime Severe Marka! charge, Bibi Netanyahu, Much of what | say in this book about war and peace, security and Isruel’s future challenges. will make uncomfortable reading for Bibi. But very litle of it will surprise him, or his own Likud rivals further to the right, like Foreian Minister Avigdor I icherman and the Economy Minister, Naftali Bennett, [ have sai almost all of 1 10 them behind closed cours in the past few years, more than once. When I fiaally decided to leave the political arena last year. it was largely because | realized that they were guided by ather imperatives, In the case of Bibi, the must gifted politician with whom I've worked except for Chinton, the priority was to stay in power. For Avigdor and Naftali. it was to supplant Bibi. when the opportunity was ripe, as Likud leader and as Prime Minister, And much wo often as with their higely ill-advised recent proposal fo amend Lsracl’s basic lave 1o define it explicitly as a Jewish state, and deny “national Tights” to non-Jews the three of them have ended up competing for party political points rather trun weighing the serious future imphations for the country. Peacemaking, as T discovered first-hand, requires taking risks. Statesmanship requires risks. Politics, especiully if defined simply as staying in power, is almost hays whol Lhe avoidance of sk. 10 The problem for Tsracl, no matter who or what party is in government, is that there ace risks everywhere une looks, and they show every sign of getting more, mot less, serious, The “Arab Spring” has morphed info an [slamic winter, National frontiers that were put in place by British and French diplomats ater the fall of the Ottoman Empire are vanishing. Centuries-old conflicts between tribes and rival relygians communities have reignited. The old Cold War system of nanons has given way 10.4 world without u single geopolitical centre of gravity. Perhaps most seriously, [ran seems determined to get nuclear weapons, and. in my view. may succeed in doing sa, Where Israel is concerned. relations wilh on indispusably most irpoant ally. the United States, are more swrained than at any time in decades. Diplomatic ties with Furope, our single largest trading parmer, have been growing steadily worse. And the only real ecrtiinty bs Wt smyone whe tells you that they know absolutely where things are heading next is lying. Just ask Uosoi Mubarak. who, despite having nearly halt-a-million soldiers and security operatives al hus disposal, was nilerly blindsided, and very soon toppled and imprisoned. by an uprising that began with a sudden show of popular anger in Cairo’s Talurir Square. Internally as well, Isruel faces dangers. Chief among them is the alaming crasion of the standards of civil discourse, wid the increasingly shrill, ofien hateful, divisions between left and right. secular and religious. rich and poor and, most seriously of all, Jews and Arabs. While we remain economically suceessiul, he fruits of our wealth are being ever move imevenly shared, und the prospects for continued growth constrained by the lack of any visible prospect of Tong-term peice. Bibi Netanyahu, of course, knows all of this, Indeed, he has repeatedly spoken of the multiple threats Tsrael faces. not only in somber terms, bul at times almost apocalyptically. That worles, politically. Paliticians, not just in Israel but everywhere, know that it is a lot casier Wo win elections vn fear than on hope. Yet my own prescription — learned, as this book recounts, from years on the battlefield, then reinforced by my years in govemment is that Israel must sesist being guided by either of those allernatives. Not fear, certainly. Bul neither by simple. untempered hope. Though the stakes have become much higher sinee my wight tight buck from Camp David nearly 15 years ago. our " need comaing what T tried Lo impress on my negotiators thea: realism. A meticulously informed, utterly unvamished, understanding of the threats we face, of each altered situation after every success or a failure, and an ability to set aside the buckground noise and political pressures and chart a way forward. So what is that way? [t begins with the mindset. Ou more than one occasion in the past few years, after Prime Minister Netanyahu had warned our country of a nuclear Irn ar the spread of Al Qaeda-style hatred ind violence, as if prophesying the coming of Armageddon, [would sey to him: “Stop lking like that. You're not delivering a sermon in a synagogue. You're Prime Minister.” Having been privileged to live my own hfe long with the entire modem history af our conniry, | went further. Zionism, the founding architcetre of [sracl, was rooted iin finding a way to supplant not just the life, but the way of thinking, which hard-pressed Jewish communities had intemalised aver centuries in the diaspora: in [lebrew, the galuf. We would instead lake control of our pwn destiny. building and developing and sceuring vue ows country. Now. I told Bibi, he was back in the mindset of the gafur. Yes, al-Qaeda. and more recently Islamic State, were real dingers. The prospect of a nuclear Iran wes even ose so. “Bul the implication of the way you speak. not just 10 Barack Obama or David Cameron, but to sraetis, is that these are existential threats. What da vou mage? That 1f, God forbid, we witke up and ram is 8 nuclear power, we'll pack up and go back to the shierds of Europe?” Of course not. Tsracl, as my public life has taught me more than most, remains strong militarily, We are, still, fully capable of tuming back any of the wndenihle Uneats on our doorstep. Keeping that strength, developing it and modernizng it. are obviously critically important. But as Israel's founding Prime Minister, David Ben-Gurion, used to say, the success of Zionism, and of the Israel stite, requied Iwo tims: strength und “ghiconsness.” He didn’t mean the word in purely religious terms. Le scant that lsracl, if it were to retain intematianal backing and intemal cohesion, must be guided by a core of moral assurptions as well. Tha, in itself, would be season enough w pursue every possible appovianily for “end of conflict” with our neighbours. And. at home, to protect and re- inforee pur commitment to Israel as both a Jewish and a democratic stare, But Lsruel’s sireple sel nlerest — its hope For prosperity, social eolesion, ad prowth in fnture — makes this nothing short of imperative. 12 Bibi is right shout ous thing. The negotiating challenges have become more difficult since Arafat's refusal of our offe at Camp David. Arafat is no longer alive, Palestinian politics have become ever more fragmented and messy, nat least. ws a sesnlt of the Hamas uskeover of Gaza, But Churchill once said that the difference helween a pessimist and an optimist was that the pessimist always saw ditficulties in every opportunity. The optimist suw opportunities in the difficulties, 1, of all people, do not look at such opportunities without hard-headed analysis. even a dose of scepticism. But the opportunities are undeniably there, and never has Israel risked paying a higher price for failing to see and at least to ry 10 act on them The first port of call should still be the Palestinians. T have repeatedly asked Bibi, and the right-wing rivals that seem often ta loom large in his political culentations: “IF you're so sure you don't have a negotiating paviner in the Palestinians. who not at least try? Seciously. What do you have to lose? But beyond this, there is a whole ranpe of relatively moderate countries — ancl, 2s Sunni stsfes, sivongely anti-Jrunian countries — which share with [sracl seal, practical intecest in putting in place a new political acrangement in the Middle Cast. So does the United States, Russia, even China. Tach, in their own ways. is threatened by i terror threat thal will requive intemtioni action, und many years, linally to defea A Saudi “peace plan”, for instance, has been on the table for years. Formally endorsed by the Arb 1 cai, it proposes a swap: [srueli withdrawal for full und final peace and Arb recoguition. Successive Israeli govenmments lave dismissed it out of hand, arguing that the withdrawal which the Saudi proposal demanded every inch of rerritory, back to the borders before the Six-Day War — would be not only politically wnsceepiable, bu practically impossible In the final days of the Camp David summit, as our failure was becoming inescapably clear, a disheartened Bill Clinton said to me that he could understand, just bon, why Yasir Arafal bud nat aceepted the unprecedentedly la-reaching proposals | had presented. But what he eouldu’L grasp was how the Palestinian leader could say no even to accepting then as a basis for the hard, further work which we all knew a final peace agreement would entail, Wasn't Arafat capable of looking beyond the political risks, of understanding the greater risks of inaction. Of seeing the rewards? Ot Joofing ahead? 13 My fear not just on issues like the Saudi peace plan, but in charting our place in a dramatically changed world, and safeguarding our twin Jewish and democratic identities at home, pairing our physical strength with an equally strong moral eerie — is thal we [ssachis are now in dager of jellisonig the example of David Ben-Gurion. For Yasir Arafat's. 14 Chapter One Liam an Israel, but also i Palestiman. | was born in Febmary 1942 in Brinshe ruled Palestine on a fledgling kibbutz: a cluster of wood-and-tarpaper huts amid afew orange groves and vegetable fields and chicken coops. If was just across the road from im Arab village named Wadi Khawarct, which disappeared, with the establishment of the State of Israel, when T was six years old. As Prime Minister halt-a-century later, during my stubborn yet ultimately fruitless drive to secure a final peace treaty with Yasir Arafat, there were media sugaestions that my childbood years gave me a personal understanding of the pasts of bath our peoples, Jews and Arabs, in the land which each of us saw as our own. But that is in some ways misleading. Yes, [ did know first-hand that we were nol alone in eur ancestral homeland. AL no point in my ehildhood was 1 ever taught to hate the Arabs. I never did, even when, in my vears defending the security of Israel, [ had to fight, and defeat, them. But my conviction that they, too, needed the apportunity to establish a state came only later. afler my muny ‘years in uniform. and especially when, as deputy chiet-of-staft under Yitzhak Rabin. we were faced with the explosion of violence in the West Bank and Gaza that became known as the first inifidda, And while my determination as Prime Minisier Ly find 2 negotiated resolution 10 our conflict was in part based on a recognition of the Palestinian Arabs’ national aspirations, the main impulse was my belief that such a compromise wus proformdly m fhe interest of Israel: the Jewish stale whose birth | witnessed, whose exisience [had spent decades defending on the battlefield and which [ was ultimately elected to lead. Zionism, the political platform for the establishment of a Jewish state, emerged m the late 1800s in response 10 a brutal reality. And that, wo, wis i parc of my own family’s story. Most of the world’s Jews. who lived in the Russian empire and Poland, were trapped at the time in a vise of poverty, powerlessness ad anti-Semitic violence, Kven m the democracies of Western Europe, Jews were not necessarily secure. Theodor Tec, a thoroughly assimilated Jew in Vienna, published the foundation text of Zionism in 1896. It was called Der Judensiaat, “Jews hae sincerely tried everywhere to merge with the nations] communities in whiel we live, seeking only W preserve the faith of our fathers,” he wrote. “In vain are we loyal patriots. sometimes super- loyal, In vain do we make the seme sacrifices of life and property as our fellow citizens... Tn our native lands where we have lived [or centuries, we are still decried as aliens.” Zionisi’s answer was the establishment of a stare of our 15 owe, in which we could achieve the sell-deteemination and security denied Lo us elsewhere. During the 1890s and the early years of the new century, more than a million Jews fled Kastem Europe, but mostly for America, It was only m the 1920s and 1930s that significant numbers arrived in Palestine. Then, within a few years, Hitler rose to power in Germany. The Jews of Europe faced not just discrimination or pogroms. They were systematically, mdustially, murdered. From 1939 until carly 1942 when | was born, nearly two million Jews were killed. Six million would die by the end of the war. Almost the whole world. including the United States, rejected pleas fo provide u haven for those wha might hive been saved. Even afler Hitler was defeated, the British shu the doors of Palestine 0 those who had somehow survived. EE Twas three when the [Tolocaust ended. and it was three years later that Israel was established in May 1948. and nicighboring Arab states sent in their smmies 101ry 10 $nulT the state out in its infancy. It would. again, be some years before | fully realized that this first Arab-Israeli war was the start of an essential tension in my country’s life, and my own: between the Jewish etbical ideals ut the core af Zionism and the reality of our having wo tight, and sometimes even kill, in order to secure. establish and safeguard our state. Yet even as a small child, T was keenly aware of fhe historic events swirling around me. Mishmar Hushavon, the hamlet north of Tel Aviv where [spent the finst 17 years of my life. was one of the early kibbutzim. These collective farming, settlements had their roots in Herz1’s view that an avant-garde of “pianeers™ would ned To settle i homeland tht was still ceonomeally undeveloped, snd where even farming was difficult. Members of Jewish youth groups from Fastern Furape, among them my mother, provided most of the pioneers, drawing inspiration not just From Zionism but by the sill untainted colleetivist ideals represented by the triumph of Communist aver he czas in Russi. Tuis hard for people who didn’t live through that time to understand the mindset of the kibbutrniks. They had higher aspirations thn simply planting the sods oli ule stale. They wanted lo be part of anstorming whi if mes lo be a Jew, The act of first taming, and then farming, the soil of Palestine was nat 16 just an economic imperative. TL was seen as deeply symbolic, signifying Jews finally taking control of their own destiny. It was a message that took on an even greater power and poignancy after the mass murder of the Jews of Furope during the Holoesust Liven fur many Israelis nowadays, the all-consuming collectivism of life on an early kibbutz, and the physical challenges, are hard to imagine. Among; the few dozen families in Mishmar Hasharon when [was bom, there was no private property. Everything wes communally owned und allocated. Every penny — or Israeli pound earned from what we produced went into a communal kitty, from which each ane of the 150-ar-sa families m Mishmar Hasharan when | was a child gol a small weekly allowance. By “small”. 1 mean tiny. For my parents and others, even the idea of an ice cream cone for their children was a matter of keen financial planning, More often, they would sive each weekly pittance with the aim of pooling them at birthday time, where they might sireich to the pries of a picture book, or a small toy. Decisions on any issue of importance were taken at the aseifiv. the weekly mccling of kabbutz members eld on Suturday nights in onr dining ball. The agenda would be tacked up ou the wall the day before, and the session would usually focus on one issue, ranging from major items like the kibbutz's finances 10 the question, for instance, of whether our small platoon of defery divers should be given pocket money 10 buy a sandwich or a coffee on their days outside ihe kibbutz or be limited to wrapping up bits of the modest fare on offer at breakfast time, That debate ended in a classic compromise: 4 bit of money, but very fille, s0 as 10 avoid violating ie egalitarian thos of the kibbuiz, But perhaps the aspect of life on the kibbutz most difficult foc ousiders w understand, especially nowadays, is that we children were ussed collectively, We ved in dormitories, organized by age-group and overseen by a carciver: iin Lcbeew. a merapeler, usually a woman in ber 208 ur 30s. For a few hours each afternoon and on the Jewish Sabbath, we were with our parents. But otherwise, we lived imd lcamed in a world consisting ubmost entirely of other childuen. Everything around us was geared towards making us feel like a band of ‘brothers and sisters, and as part of the guiding spirit of the kibbutz, Until aur Teenage years, we werenl even graded in school. And though we did’L actually study how to ill the land, some of my fondest early memories are of our “children’s Farm” — the vegetables we grew, the cows we milked, the hens sud chickens that gave us our first experience of how life was created. Aud the 17 aroma always walling tom the stone oveos in the bakery at the heact of the Kibbutz, where we could see the bare-chested young men producing loaf alier Touf of bread, nat just for Mishmar Hasharon but villages and towns for miles wound ws. Until our teenage years, we lived in arrow, oblong lomes, four of us lo a room, unfumished except for our beds, under which we placed our pair of shoes or sandals. At ane end of the comdor wis u set of shelves where we collected a clean set of underwear, panls and socks cach week. Al the other end were the toilets at thar point, the only indoor toilets on the kibbutz, with real toilet- sats, rather than just holes m the ground, All of us showered together until the uae of twelve, 1ean't think of a single one of us who went on 10 Tory someone [com our own age-group in the kibbutz. Tt would have seemed almost incestuous, Mistmin Haashavan and other kibbutzim have long since abandoned the practice of collective child-rearing. Some in my generation look back on the way we were raised not only with regret, but pain: a sense of parental absence, abandonment or neglect. My own memos, and those of most of the children | grew up with, are more positive. The irony is that we probably spent more waking time with our parents than town or city children whose mothers and fathers worked nine-to-five jabs. The difference came at bedtime, or during the night. If you woke up unsettled, ov ill, the only immediate prospeet of comfort was [rom the metapeled, or another of the kibbutz grown-ups who might be on overmght duty. Stull, my childhood memories are overwhehmmgly of feeling happy, safe, protected. | do remember waking ip once, fale on a stormy winter night when Twas nine, in the grips of a tereible fever. Pd begun to hallucinate. T sot to my feet and, without the thought of looking anywhere else for lielp, made sy wobbly wiry through the nisin 10 my parents” room snd fell into their bed They hugged me. They dabbed my forehead with water. The next moraiag, my father wrapped me in a blanket and took me back to the children’s home. To the extent that | was aware my ehldhood was different, 1 was given to understand it was special, that we were the beating heart ofa Jewish state about 1o be born. T once asked my mother why other children got to live in their own apartments i places hike Tel Aviv, “They ure ironim,” she sind. City-dwellers. Her lone made it clear they were To be viewed us a slightly lesser species. vee 18 Though bath my paseals were pact of the pioncer generation, ny mother, unlike my father, acuwally arrived as a pioncer, part of a Jewish youth group fiom Paland that came directly to the kibbutz. In addition to being more swsally outgoing than my Rther, shi came lo see Mishmar Hasharon has her extended (amily and spent every one of her one hundred years there. Esther Godin. as the thea was, grew up in Warsaw. Born in 1913, she was the oldest of the six children of Samuel and Rachel Godin, Polind at fhe time was home 10 the lavgest Jewish community in the world, more than 3 milli by the time of the Holocaust. While the Jews of Poland had a long: history, the Godin did not, Before the First Warld War, my mofher’s parents made fheir way from Smolensk in Russia lo Warsaw, which was also under warist sul. When the war was over. the Bolshevik Revolution had toppled the czars. Poland became independent, under the nationalist general Josef Pilsuldsii, The Godins had a decision lo make: either retucn Lo now-Communist Russia oc stay iu the new Polish state. though without eilizenship because they liad not been bora there. No doubt finding comfort. community and a sense of safety amid the hundreds of thousands of Jews in the Polish eipital, they chose Pilsuldski over Lenin. They lived in what would become the Warsaw Ghetto, on Nalewski Street, where Sanwel Godin eked out a living as a bookbinder. My mother came to Zionism as i teenager, und it was easy to understnd wehy she, ike so many of the other young Jews around her, was dave lo iL. She saw how hard her parents were struggling economically, oa the refugee fringes of a Jewssh community itself precariously pliced in a newly assertive Polind. She sin no fume Gor hersel Fihere. Though she attended 3 noroal state-run high school, she and her closest [ricads joined & Zionist youth group called Gordonia, which had been founded in Poland barely a decade earlier. She started studying Hebrew. Finch summer, from the ge of 13, she and her Gordon Friends would spend deep in the Carpathian Mountains. They worked for local Polish landowners, learning the rudiments of how to farm and the rigors of simple physical labor. aie into the evening. they would fin not just abort sgneuliure but Jewish history. the land of Palestine. and how they haped to put both their new-found skills and the Zionist ideals into practice. She had just turned 22 when she set off for Mishmar Hasharon with 60 other Gordouia pioneers in the summer of 1935. 1 took them nearly a week to pet there. They travelled by train south through Poland. passing nol fac from the little town of Osswigeim which would later become infamous as the site of fhe Auschywilz concenteation camp. Then. on through Tlungacy and across Romania 19 to the grand old Black Sea part of Constaata, and by ship through the Bosphorus. past Istanbul, and on to Tlaifa on the Palestinian coast, from where they were taken by truck to their bunk-bed rooms in one of a dozen prefib structures on the recently established kibbutz, Though the water came from a well, and it lacked even the basic ereatuse comforts of thie cramped Godin apartment in Warsaw, thar, to my mother. was just pat of the challenge, and the dreamt, she'd embraced and had come wo define her. J know that she felt, va arriving in the kibbutz, tha only now was her life truly beginning. Tt was a feeling that never left her. Yet it was always clouded by the memory of the family she left behind, When fhe Second World War bean in September 1939, the Germans, ancl then the Soviets, invaded. overran and divided Poland. Twa of my mother’s three sisters fled to Moscow. Tler teenage brother Avraham went underground, joining the wnti-Nizi partisans. All three would survive the wer. Yet in the autumn of 1940, the rest of her family fouad themselves inside the Warsaw Ghetto with the city’s other 100,000 Jews. My mother’s pares died there, along with her 13-year-old brother lizik and her litle sister enya, who wis auly 11. When my mother arrived in the kibbutz, her Gordonia lviends assumed she would marry a young man named Ya'akov Margalit, the leader of their group buck in Warsaw. But the budding romance fell yictm fo the Zomst cause, As she was embarking on her new lit, Je was frequently back in Poland waining and accanging papers for further groups of pioneers. Tle continued to write her long, heartfelt letters, But the letters had fo be brought from the centeal post alfice in Tel Aviv, amd the kibbuumile who Fetched the mail was 1 quict, dimunitive 25-year-old named Yisrael Mendel Brog — my father. Known as Srulik. his Yiddish nickname. he had come to Palestine five years earlier. Fe ws an ovelinany Libbuz worker. He drove a tractor. My father’s initial impulse in coming Ww Palestine was more personal than political. He was born, in 1910, in the Jewish hie! of Pushelat in Lithuania, near the larger Jewish town of Ponovezh, u major scat of rabbinic leaning und teaching. His own father. though the only meniber of the Pushelat community with rabbinical training, made his living as the village pharmacist. Many of the rangghly 10,000 Jews who lived there had left for America m the great exodus from Russian aud Polish lauds st the ond of tie 19% century. By the time my father was born, the community had sheunk to only about 1,000. When he was two years old. a fire broke out, destroying dozens of homes, 1s well as the shiell’s ouly synagogue. Donations soon artived [zom the US, and my paternal 20 grandfather was put in charge of holding the money until cebuilding plans were worked out. The problem was that word spread quickly about the rebuilding fund. On the night of September 16, 1912, two burglars burst into my srmdlithir’s home and stoke the mony. They beat him and my wandmother to death with an axle wrenched loose om a neacby carciage. Their four-year-old son Meir — ny father’s older brother ~ suffered a deep wound from where the attackers drove the metal shall into bis head. Ue carried a gol bel l-sized indentation in his forchead foe the rest of his life. My father had burrowed into a comer, and the attackers didn’t see him The two orphaned bays were raised by their paternal grandmother, Jzila. Yet wy ret lo nomnaley they may have experienced was cut short by the outbreak of the First World War, forcing ec to flee with them by train ahead of the advancing German army. They ended up some 1,50 miles south, in the Crimean city of Simferopol. Initially under czarist cule, then the Bolsheviks and from lace 1917 wl the ead of the war under the Germans, they had to deal with cold. damp and a chronic shortage of food. My Uncle Meir quickly learned how to survive. He ler told me that he would run aller German supply canfuges and collect the odd potato that fell oft the back. Realizing that the German soldiess had been wrenched from their own families by the war, he began taking ny futher with him on weekends lo the neighborhood near their barracks, where the soldiers would sometimes give them cookies, or even a loal of bread. Yet they were deprived of the basic ingredients of a healthy childhood: nutritious food and a warm. dry room in which to sleep. By the time Itzila brought them back w seule in Ponovezh at the cud of the war, my Ruther was diagnosed with the bone-development disease, rickets, caused by the lack of Vitamin I) in their diet. In another way, however, my father was the more fortunate of the bays. The Tost schooling of those wartime years came at a less formative Lime for him than for his brother. Meir never fully made up the lost ground in school. My father simply began his Jewish primary education, cheder, a conple of years hier than usual. Te thrived there. SHIL when it was time for him Lo enter secondary education. he decided against going on with his religious education. Meir was preparing fo leave for Palestine, so my futher enrolled in the Hebrew-language, Zionist high school. When hie graduated, one of the many Brog relatives who were by now living in the United States. his Uncle Jacob, tried to persuade him to come to Pittsburgh for university studies. But with Meir signing on as his sponsor with the British Mindeate anthorines, he leit for Palestine shortly before 21 his twentieth birthday. Jacob did still insist on helping financially, which allowed my father to caroll at the [cbrew University in Jerusalem. He did well in his studies literature, history and philosophy but abandoned them afer two years, His explanation for nol staying on, when | asked him years later, was that with the aceelerating activily of the Zionist pioneers. it fel wrong to him to spend his days going: to lectures, reading books and writing essuys. 1am sur thi he also fel isolated and alone, with Meir, the only link 10 his life before Palestine, working in Haifa on the coast, four or five hours by bus trom Jerusalem. When he began looking for a way to become part of the changes woing an around him, Mishmar Hasharon didn’t yet exist, Its founding core — u dozen Russian Jewish pionicers — was still working on argicullural settlements near Terzliya, north of Tel Aviv, until they found a place to start their kibbutz, But they had been joined by several young men and women who, though a year or two older than my father, had been with him at the Iebrew Iligh Sehivol in Ponovesh. Tle decided Lo join them. Late in 1932, the Jewish National Fund, supported financially by leading Jewish figures in western Europe and the US, bonght 2,000 acres from an Arab landowner near Wadi Khawarel. The area was sel aside for three Jewish settlements: a moshav called Kfar Haim, where the land was divided into family plots, and two kibbuizim. One was called Muabarot, Next fo it was Mishmar Hasharon, My Rather was mong the seventy youngsters who set off in three trucks with everything they figured they would need to tura the hard, scrubby Till into a kibbutz, They built the core from pre=fab kits: wooden huts to sheep in anda tightly bger one for the dining hall. They dug a well sud ordered a pump from Tel Aviv, at first for drinking and washing. but soon allowing them to begin a vegetable garden, a dairy with a dozen cows, a chicken coop with a Few hundred hens, and to plant first orange grove snd a small vineyard. Sill, by the time my mother arived three years later, there were not enough citrus trees, vines, cattle and chickens to occupy a membership which now numbered more than 200. Along with some of the others, my Father worked ouside the kibbute, caning a regular paycheek to help support the collective. Ou his way back, he would stop at the post office in Tel Aviv tw pick up letters and packages for the rest of the kibbutz including Yu'ukov Margalit’s love Totter to my mother. That was hos my parents” Gricodship began, low a friendly hello led to shared conversation at the ead of my father’s working day. and how, u few years kiter, my mother decided to spum her Gordania suitor in favor of Srulik Brog. the posunan. Tt was not watil 1939 that they moved in 22 together. They didn't bother getting married until the summer of 1941. Perhaps because this was less than nine months before | was ben, my mother always remained vague when asked their exact wedding date, My prents were am unlikely pane, My mother brghi, lively und energetic was a doer. who believed passionately in the grand social experiment of kibbutz lite. Having helped her mother raise her siblings in Warsaw. and with a natural affinity from children, she became the main authority on issues related to childbirth and early childeare. She actively pattook iu the kibbuiz's planning and politics, and reveled in its social life. My father was more detached both politically and soerally. He was mare contemplative, less ussertive, less self contin. | hough bic agneed broudly with the founding principles of the Kibbutz. and wanted to play his role in making it a success, T could see. as grew alder, that he was often impatient at what he saw as its mtellectual insularity and its ideological rigidities. Though it didn’ strike me al the Lime, he was nol a large man. As a result of his childhood illness, he never grew to more than five-foot-tour. Still. he was a powerful prescrice, stocky and strong from bis work on the kibbutz, He hid a deep, resunaut voice and wise-looking. blue-gray eyes. IL was only through Uncle Meir that by the time I was bom, he had moved on from driving: a tractor fo a mor influentiyl role an the labbutz, Meir worked far the Palestme Electne Company and when Mishmar Hasharon installed its own electricity system, the PEC was in charge of the work. Meir trained my father and put him forward as the kibbutz contact far maintaining and repairmy the equipment, He was well sirled for the work. He was aiusal finkorer, a problem-solver. He wis good with his hands, and his natural caution was an additional asset as the kibbutz got fo prips with the potential, and the potential dangers. of electric power. Once the system was instilled, hie became vesponsible for ruunaging amy spect of the settlement that involved electricity! water pumps, the irrigation system, the communal laundry and our bakery. My pirents were courleans and polite with cach other, but they never showed any physical affection in our presenee. None of the adults did. ‘This was part of an unspoken kibbutz code. Not only for kibbutzaiks. but for all the early Ziomists, outward displays of emotion were seen as a kind of selfishness that sisked undermining communal cohesion, tonecily and strength, Besuuse 1d Known no other way, this did not strike me as odd. Besides. T was a quiet, contemplative, bookish and sclf-canfiined child, Only im kite years did | come to see the Jasting effect on me. IL was be a long time before T became comfortable 23 showing my feelings. beyond my immediate family aod a few close frieads When T was in the army. his wasn't an issue. Selcouteol, especially in high- pressure situations, was a highly valued asset, But im politics, [ think that it did fora considerable time mbabit my ability lo conneel with the public, or ut least wilh the news media thal played such a writical intermediary sole. And it caused me fo be seen not just as reserved or aloof, but sometimes as cold, or arrogant. 1 did get mueh that 1 value from my parents. From my mother, her boundless energy, activism, her atiention detail, and her focus on causes larger than herself her belief that politics mattered. Also her love for art and literature, When | wauld come home from the ¢hildren’s dormitory to my parents’ room — just ine feet by fen, with # wooden trundle bed fo save space during the day — there was always a novel oc a book of verse sharing the small table with my parents” mast single prized possession: their kibbutz-issue radio, As achld, however, | spent mie more time with my father. He was my guide, my protector and role model. Like my mother, he never mentioned the trials which they and their families endured betore arriving in Palestine. Nor did they ever speak to me m any detail about the Holocaust. No onc on the kibbutz did. 11 was as it the memories were seabs they dared not pick at. Also, it seemed, because they were determined to avoid somehow passing on these remembered sadnesses to thei sons and daughters, Still, when 1 was ten or cleven, my father did — once, inadvertently — open a window on his childhood. Every Saturday morning, we would listen 10 a classical music concert on my parents” radio, One day, as the beautiful melodies of Tehuikovsky's violin concerto in 1) eamic through the vadio, 1 was siruck by the amost iraneelike look that came over my father’s face. TTe seemed to be in another, faraway, place. ‘When the music ended, he turned and told me about the first time he'd heard it 1 wass on the Insin ride ino Crimean exile with liza and Meir in the sinfy dys of the First World War. The teain took five days to reach the Crimea and sometimes halted for hours at a time. Every evening, a man at the far end of their camrisge would take out his vio nd play the seeond movement of the Tchaikovsky concerto Thave heard the piece in concert halls many times since. When the orchestra begins the second movement with the violin notes climbing higher, trembhng ever sa subtly — it seuds a shiver dawn my spine. | can’t help thinking of the railway car in which my then foue-yeac-old father and other Jews from Panaverh escaped the Great War of 1914, And of other trains, m another war 25 years later, carrying Jews not to safety but to death camps. 24 Listening 10 he concert progeam inl my paseals® oom was something 1 always looked forward 10. Tt was my father who encouraged me, when [ was. eight, to begin learning to play the piano, I took lessons once a week all during my clhnldhood slong with several other of he kabbus children. When we got old enough, we took urs playiog a short piece — the secular, kibbutz equivalent of an opening prayer at the Friday-night meal in the dining hall. I have always clierished being able to play. Sitting dows at the piano and immersing mysell in Tohaikovsky, Beethoven, Schubert or Mozart never ecascs lo bring me a sense of calm, freedom and, especially nowadays, when [ have finally worked ta master a particularly intricate piece. a feeling of pure joy. PE Asa young child, © spent most of my waking hours in the company of ny several dozen hibbulz “siblings” in the childsen’s home, the dining hall, or running through the open spaces in the center of the kibbutz with ou metapelet. She would ofien fake us through the orange groves in the aftemom, sd sometimes ac0ss the main wad to the Arsh village. Wadi Khawaret consisted of a few dozen concrete homes built back from a min sweet bordered by shops amd storehouses. She would buy us sweets m the litle grocery store. The man behind the counter had a kindly, weathered face and a dark moustache. Dressed in a gray gafabiva and a keffiyeh. he smiled when we came m. There was ilways a group of Palestmian women, in full- engi robes. seated on stoops outside bresusifoeding their babies. We saw calle, bulls. even the odd buffalo, being led 1 or from the fields. 1 sensed no hostility, and certainly uo hatred, toward us in the village. The people seemed warn, and benignly indifferent to the dozen Jewish loddlers and thei mesapeler. My own attitude to Wadi Khawaret was of beniga curiosity. T did not imagine that within a couple of years we would be on opposite sides of a war. 1 enjoyed these visits. as Lenoyed every punt of my carly childbood. Hach age-group on the kibbutz wes given a name. Ouws was called dror. It was the Hebrew word for “freedom”. But dro was also the name of one of the Jewish youth movements in the Warsaw Gihello, heroes in their doomed uprising against ihe Nazis. Litke by little, from about the age of five. I became more aware of the suftering the Jews Tal so recently endured in the lands my parents had left behind, the growing 25 tension around us and the sense thal something momentous was bout to happen as the prospect of a state gol eloser The memories remain with me to this day, like a series of snapshots, It was on a spring moming in 1947 that 1 got my first real sense that the Jewash state was something which would have be fought for, and that youngsters not all that much older than me would have a critical role to play. I got a close-up lock at the elite of the Zionist militias, the Patmach, tt numbered something Fike 6,000, from a pre-siate force wialing around 40.000. The Palmachniks were highly ‘motivated, young political activists. They had no fixed base. Each platoon, almost ull of them teenagers, spent five or six manths at « time on various Kibbuwzinm. For the first 1wo weeks of eich month, they would carn their keep by working in the fields. They spent the oflier weeks taining. Thad just turned five when | watched three dozen Palmach boys and girls, in their T-shirts and shore Khaki pants, rappel confidently down the side of one of our few concrete buildings. The building was only 25 or 30 feet high. but it looked like a skyscraper from my perch on the grass in front. and the feat of the young Pabmachniks seemed 1o me nothing shoul of heroic. A few months later, on a Sawrday allernoon in Nuverber 1947, [crowded into my parents” room as the Haganah radio station crackled out its account of a United Nations debate on the future of Palestine, The session was the onfeome ofa loug train of events starting with Britain's acknowledgement that its mandate to rule over Palestine was unsustainable. The British had proposed a series of amangements to wecommodate both Arab und Jewish aspirations. Now, thie UN was meeting fo consider The idee of splittisig Palestine into wo nes states, one Arab and the other Jewish. Since the partition was based on existing areas of Arab and Jewish settlement, the proposed Jewash site looked like s boomerang. with a fon. very narrow center strip along the Mediterranean, broadening slightly into the Galilee in fhe north and the arid coastline in the south. Jerusalem, the site of the ancient Jewnsh temple, was not part of it. 1 was to be pliced under intermational sule. By no means all Zionist leaders were happy with partition. Many, on both the political right and the left, wanted a Jewish state in all of Palestine, with Jerusalem as its conterpicee. But Ben-Gurion and the pragmatic miinstream wgued that UN endorsement of 8 Jewish state — no mailer what its borders, even with a new Palestinian Arab state alongside it — would represent a historic achievement, The proceedings went on for hours, At sundown, we had to Tetum io the children’s home. But we were woken before dawn. The vote (or partition 26 = for the Jewish state Tlerel had first decamed of $0 years before — had been won. A huge bonfire blazed in front of the bakery. All around us the grown-ups were singing and dancing in celebration, On the Arh side, there wis no rejoicing. very one of the Arab delegations ut the UN voted against padtition, rejecting a Jewish state even if it was erated along with a Palestinian Arab one. Violence erupted the next day. An aack on bus near Lydd, near the road up to Jerusalem, left six Jews dead. Similar wicks oceurred around the country. Shooting broke out in mixed Arib-und- Jewish towns and cities: Jatfa on the southern edge of Tel Aviv. Safed, Tiberias and Haifa in the north, and in Jerusalem, allowed all ris with curiosity and trepidation trough my hilting alicmpls to read Davar le Yeladim, the weekly children’s edition of the Labour Zionist newspaper Davar, We children felt an additional connection with what wus going om. One of our Dror housemates, boy aed iors Ros, had left the year before when bis father took & job in Jerusalem. As the battle for the city aged through the end of 1947 and into 194R, its besieged Jewish residents fongeht for their ives, We sent our friend packuges of clothing and food, which we saved up by cating only half of an cpp at break fast and smaller portions al dinner. The mood darkened further at the end of January 1948, four months before the Brith departed. A cluster of settlements known as Gush kizion, south of Jerusalem near che hills of Berhlehem. also came under siege. Around midnight on January 15, a unit of Haganah youngsters set oft on foot w try to break ttnongh, They became known ws “The 35”. Marching through the night from Jerusalem, they had made it only within a couple of miles of Gush Iitzion when they were surrounded and attacked by local Arabs, By late afternoon, all of them were dead. When thie British wut horites recovered their badies, they fond hat the enemy had not simply killed them. All of the bodies had been battered and broken. Rumors spread that in some cases, the dead men’s genitals had been cut off and shoved mio their mouths, Since | was soll 4 few weeks shout of my sixth birthday. | was spared that particular detail. But not the sense of horror over what had happened, nor the central message: the lengths and depths to which the Arubs of Palestine seemed ready to go in their fight against us, “Uit’alelu bagafin” ves the only slightly sanitized account we children were given. “They mutilated the corpses?” Even afler The partition vate, slatchood was nol given. In tie weeks before ihe British lef. two senior Americans —the ambassador to the UN and Secretary 27 al State George €. Marshall - recommended abandoning or at least delaying the declaration of an Tseacli stale. Yet Ben-Gurion feared that any delay risked the end of any early hope of statehood, After he managed to secure a ane-vote sijonily in his de facto cabmet, Uh state was declared on May 14, 1948 And hours later, the armies of five Arab states crossed into Palestine. 28 Chaplet Two The 1948 war und the decide tht followed remain vivid in my mind not just for the obvious reason: they secured the survival of the infant state of Israel and saw it into a more assured and independent young adulthood. It was also the time when [grew from a young ¢hild introspective and contemplative, aware of how quickly my mind seemed to grasp numbers and geometric shapes and ‘musical notes, but also small for my age and awkward at the sports we'd play on the dusty field at the fur edie of the kibbutz into a sense of my own place iu the Family and community and the country around me. | did, along the way. ‘become arguably the most effective left defensive hack on our kibbutz soccer team, But that was not because | suddenty discovered a buried talent for the same. Physically, T was like my father. T had natural hand coordination which made delicate tasks come easily — one reason 1 would soon discover a pastime that lent itself to ucts of kibbutz mischief bardering on juvenile delinquency, Bul when if came lo larger miseles, 1 was bpless, i 0) hopeless. My prowess as a socoer defenseman was because no oppasing player in bis right mind, once I'd inadvertently cut his knees from under him when aiming for the ball, felt it was worth coming anywhere elose fo me. But when the war broke out in camest in the spring of 1948, my focus, like that of all [sraelis, was on the fighting. which even the youngest of us knew would determine whether the state would survive at all. Day ufter day, my father helped me to chart cach major advice wnd setback on a ttle map. Dozens of kibbutzim around the country were in the line of fire. Some had soon fallen, while others were hurely managing to hang on, Just five miles inland from us, un Isuseli seitlerent came under sitasck by an ngi force in the nearby Arab village of Qagun But inside Mishmar Hasharon, [ had the almost surreal feeling that this great historical drama was somethmg happenmiz everywhere else bul on our kibbutz. If it hadn't been for the radio, or the newsreels which we saw in weekly movie nights in the dining hall, and the litle map on which [ traced its course with my father, 1 would barcly hive known a war was going on, One Arab army did get near 10 us: the leagis, in Qaquu. IF they had advanced a tow miles further. they could have overrun Mishmar Hasharon, reached the coast and cut the new Jewnsh state m half, | can still remember the rumble of what sounded like thunder one morning in June 1918, as Lhe Alexandronis, one of the twelve brigades in the new Israeli army, launched their decisive artack on the Iragis. 29 “Na reason to be afcaid.” vue mesapeler opt telling me. That aly made me move scared. Yet within a few hours, everything was quiet again, and never again did the shellfire get near to us, A few weeks later, 1 heard the only gunfire inside the kibbutz itself. [1 came from the lop of ow waler lower. The mun on euard duty thought he saw movenient on the road outside. But it turned out to be nothing. It wasn’t until well into 1949 that formal agreements were signed and “armistice line” borders drawn with the Arab states. By the measure that matcered most survival Israel had won and the Arab attackers had lost. Jordan did end up in control of the West Bank, as well as the castem half of u divided city of Jerusalem, including the walled Old City and the site of the ancient Jewish temple. The new Tsrae] remained, at least geographically. vulnerable, It was just 11 miles wide around Tel Aviv and even namower, barely half that, near Mishmar Iasharou. Ceyplian-held Gaza was seven miles [rom the southern [sracli city of Ashkelon and just 40 rom the outskins of Tel Aviv. Ise] did sceure control of the entire Galilee, up 1o the pre-war borders with Lebanon and Syria, aud of the Negev Desert in the south. ‘The territory of our new state was about a third larger than the area proposed under the UN partition phim rejected by the Arabs, Yet the victory cme at 2 heavy price: more than 6,000 dead, one per cent of the Jewish population of Palestine al thie lime. It was as if America had lost two million in the Vietnam War. One-third of the Israeli dead were Holocaust survivors, The Anh paid s heavy price wo, and nol just the roughly 7,000 people who lost their lives. Nearly 700.000 Palestinian Arabs had fled - or. in some cases, been forced to flee towns and villages in what was now Israel. The tull extent und circumstances of the Arabs” Might became known lo us ut Mishmar Lieshacon only later. But it did not take long 1o notice the change around ws. Wadi Khawaret was physically still there, but all of the villagers were gone. As fia as [contd discover, none id been killed, They left with a first wave of refugees in April 1948, and eventually ended up near 1 ulkarem on the West Bank. After the war. the Israeli government divided up their farmland among, nearby kibbutzim ineluding Mish Hasharon. The absence of our former neighbors in Wadi Khsware! seemed 10 me al the time simply a part of the war. From the moment the violence started, I understood there would be suffering on both sides. When we sent our care packages to Giora Ros in Jecusalen, [remember Lying lo imagine what “living 30 under siege” would feel like, and what would happen o Giora if it succeeded Especially aller the murder and the mutilation of The 35, [assumed the war would come down to a simple calculus, If there was going to be an Israel it’ there was omg fo be a Misha Hisshizon — we had To win und tie Arb had 10 lose. At fivst, even he fact our kibbutz had been given a share of the land of ‘Wadi Khawaret seemed just another product of the war. After all. Ben-Gurion liad acecped the plan for two states. The Arabs had said no, deciding lo attack us instead. Someone had to farm the land. Why vot us? Yet events alter the war did lead me w begin tv ask mysell questions of basic faimess, und whether we were being fiithful to same of the high-sounding ideals heard spoken whout wath such pride on the kibbilz. The Palestinians were pol the ooly refugees. Mose than 600.000 Jews fed fro [sracl from Arab countries where they had lived for generations. More than 100.000 arrived from rag, and several hundred thonsand from Morocco, Timsis and Algeria im north Alrica. Immediately aller the wav, about $0,000 were airlified out of Yemen. where they had endured violent atcacks ever since the UN partition vote. The reality that greeted the Yemens in Israel was more complex, Most were initially seuled in tented transit camps. I'm not sure how several dozen Yemeni families made their way to Wadi Khawaret. bul it made sense for them to move into fhe village's vacint hames. It was empty except for several deserted buildings which we and other kibbutzin began wsing for storsge and, ler, for our transport co-operative. Ye a few nights afer the Yemenis moved in, a posse of young men. including some trom Mishmar Hasharon, descended on hem and, sned with elubs id wooden staves, drove them away. [was shocked. I'd seen the photos in Davar Je Yeladin celebrating the airlift, with the Yemenis kissing the airport tarmac in relief, gratitude and joy at finding vefinge in the new Israeli state. Now, for the “crime” oF maving into a sow of cnply buildings in search of a decent place to live, they'd been beaten up and chased away. By us. 1 realized Wadi Khawaret no longer belonged to the Arabs. But, surely, our kibbutz had no mare right to the builds than Jews whe had (led from Yemen and veeded them a lot more than we did. For days, | fried to discover who had joined the vigilante attack. Though everyone seemed 10 know whl had happened, no one talked ihout il. In the dining hall, 1 ren my 31 eyes over all the boys in their late teens and carly 20s. T was suce thet aflec something like this there had 10 be some sign of who had done it. Bul they Tooked the same as before, eating and talking as if nothing had happened. The Yemems also needed jobs. This led 10 a challenge for Misti Hasharon. ‘The core of the kibbutz ethos was that we would live from our own labor. Yet Ben-Gurion insisted we and other kibburzim provide work for the Yemenis and other new arrivals from the Arab states, We began hinng Yemeni workers when | was about ten, the age when we kids started working for an hour or so each day in the fields. We worked alongside several dozen Yemeni women who lived a few miles north mn a masbarah, a transit settlement which Hiutor evolved into a village called llyakhin, Esch moming, the Yemenis anived ina bus, and they Jef at the end of their day’s work don’t know whether | expected ta feel a Gordonian sense of jay af the sedermptive value of physical labor when 1 began working in the fiehds. Our first assigurment was o plant long tows of lower bulbs — gladioli — spaced at intervals of four inches or so. Bur as 1 joined the other children and the Yemeni women, what | Felt was more mumdane. Heal. Fatigue. Boredom. To make the tine pass, | thought of it as a competition. Liach of us began together. planting the bulbs in furrows stretching to the end of the field. The point was obviously to do it right, But | found it interesting to see who fished first, and how much longer it look the rest of us. The same worker always led the way. She was a Yemeni in her carly thirtics. Her name was Raddura, Short and stoclcy, with dark curly hair, she was nearly hways smiling, whether we were planting bulbs, sowing seeds or picking oranges and grapefruit and lemons, potataes or peppers and tomatoes. When I remarked to her how much better and ster she was than fhe rest of us, she iughed. SHll years away from growing into my adult body, {looked more like sight- or a nine-year-old. She took me uader her wing. The next day, we were picking tomatoes. “Da the row next to mine,” she said. Watching the almost bulletic grace wath which she moved made it easier. [deeded it was hie mastering a new picee on the piano. The sceret was 10 achieve kind of unthinking fluidity, by focusing on the passage one or two ahead of the one you were playing. Physically, Baddura was fir stronger than me. Before long, howeser, | was Fishing my sowing or reaping a good ten yards ahead of the other kids, and not loo fa behind her. “Thongh the Yemenis worked fn our elds, they were nol menbers of the LibbuLe. They were paid a day-rate. Though they were by fac the most 32 productive workers, they got no share of wha we produced or possessed. A few years later, Tsaised this at one of the sepacate aseifa meetings held by young people on the kibbutz, only to be told we'd never wanted to employ outsiders in the fist place. 1 was only becanse of Ben-Gurion ted we fell able 10 refine. Ut sure that was true, but it seemed to me an incomplete answe, and an evasion. It struck me as an exercise in finding a verbal rationale for a situation that was obviously unjust 1 wes an accidental glance up from picking carrots which focused in my mind the sense of unfaimess I felt. We were working on a tract of about seven eres of rich, dark sol where we grew carrots, tomatoes and potatoes and cgephants. 1 think {was 17 or 12. We had nsseblod in the carly aftemoon near the kibbutz garage. We piled va to a Natbed trailer. a dozen kids and a dozen Yemeni women, We were towed by a tractor driven by a man named Yankele, Tle was in his mid-40s. Like my Father, he was one of the vriginal group at Misha [ashacon. Beloce the Yemenis came, he had worked planting and harvesting. Now, he was responsible for “managing” the Yemenis. and us kids is well, during our fieldwork. He paced among 1s every bul Chonr or so 1 mike sure the work was going smoothly. Though the arca was ankle-docp in mud during in the winter, it was hot and dusty in the summer. I'd been working for an hour ov so. crouching alongside Baddury, when {looked up. On the ede of the field, under the shade of & elump of banana trees. | saw Yankele. 11e had a set of keys on a metal chain. Tle was twirling thei around bis finger, first one way. then the other. as his ees tracked us and our Yemeni co-workers. Like a KibbuLnik-umed-plantation-owncr. PE As a Tebruary baby. Twas the youngest in our age group. Tu the tiny world of the kibluz, there were not enough children to organize separate school classes for each year. When | started school, 1 wiss Rve-and-aehall. Most of the others were six. A few had alicady tured seven. Maybe it was this age pressure, or maybe something inside me, but from the outset, 1 had a thirst for knowledge. I was aware early an that some of the schoolwork came easily, almost automatically 1 me: numbers and math aod reasoning most of all. | also began reading books, even if T could not fully understand them. By the time Twas cight or nme. 1 was burying myself m volumes of the children’s encyclopedic at 33 the kibbutz libeacy, trying to untangle the mysteries of aicplanes and automobiles, or the creation of worldly wonders, from the Tlanging Gardens of Babylon to the Fmpire State Building and the Golden Gate Bride. Al first, | gol many of the answers from my father. On Saturdays, we would walk around the kibbutz as 1 plicd him with questions. In mauy ways, he always lacked self-confidence. [ remember decades later. after he had passed away. asking my mother how come they had spent their entire lives on the kibbutz and never moved away. She replied: “What would your Biber have done ouside?” But he had a quick mind and, despite having left Hebrew University carly. had secured enough credits to wet his degree one of o handful of men on the Kibbutz to ive done so. He delighted in scquiving. snd sharing, knowedge. Low come the moon wasn't always round, [ remember asking him in one of our first educational strolls. How did anyone fnow that the sabertooth tigers I'd seen in the encyclopedia setudly exisid? And where were they now? There was not a singh: question he did not try 1 help me answer. When | was nine or ten, he took me to see the first water pump on the kibbutz. I watched as he disssembled the ens, hen the power unit, which hid a big screw-Hike clement in the middle. | wanted 1 know how it worked, how it was designed. How it was made. A few months later, he took me to the tactory near Tel Aviv. where the pumps were manufactured Twas an inoveried child, not so much shy is self-contained. comemplasive, at times dreamy. Our merpelet from when [ was three until age eight was named Bina, She was the mother of twins a year younger than me, She was mone harcbsome Than heantiful, with wavy dark hair. Bul she was full of warnth. She was especially kind to me, which was no doubt one reason I felt the effects of my collective upbringing less dramatically than some other Kibbutz clldren. When we sere both such older. she used tell a slory about my slightly ethereal approach 10 life when 1 was in her charge. One winter afternoon when 1 was four, she took our group an fo the gentle rise on the northern edge of the kibbutz, which at that time of year was full of wildflowers, When she got there, she realized 1 had gone missing. Retracing her steps, she found me standing in front of a rock in the middle of the dirt path. “Chud.” she snd, “why didn’t you come with us?” | apparently replied: “1m thinking: which side of the rock should | go around?” Still, important though Bina was as a presence in my life, it was the fnlenee of mother Gare — another youngster — who muttered more and for longer. 11is name was Yigal Gacber. ln first rade, every child gol a mentor 34 Yigal was mine. Solidly buill and sel-confident, with a knowing smile, he would 20 on to become one of the most respected members of the kibbutz Though [ was the only child he mentored, he was also in charge of our class’s extreurricntar educational program. [began when | was len, and Yigal wis sixtoca. It was & mix of ideological training — the Mibbule equivalent of what my mother had done with her Gordonia friends in Poland — and a scouting course. One evening a week, he would spend several hours with us. He begin by sending 1s a story or a pocrn. One which | rementber with panieuls clarity involved a slave who had a nail driven into his ear in hopes of remaining in his master’s service forever, He had become enslaved not only in budy, but in mind. Another night, Yigal read us un account of s Palmach unit sumed on hill they had taken, with anti-personnel mines all around them. The readings were gripping and they were always an entry-point for a discussion: how did we understand the story? What would we do if laced with a similar choice? When that part was over, be walked us into the fields ouside the kibbutz. The only sound we heard was the occasional screech of a jackal. Sometimes, he would split us into twos and hive cach piri set off from a far edge of the field and find uur way back. Yigal stationed himsellat the enter. We would have to sneak up and see which of us could et closest withaut his sein: or hearing us appronch, (n his lust year with us before leavin for bis army service, he gave cach of us w narrow wooden stick and began drilling us in the teenage introduction 1o martial arts. But T was less interested in tha part of the training thin the scouting exercises. Not only was 1 the youngest in our group, and the smallest, except for a couple of the girls. Notwithstanding my accidental prowess on the soccer field, Tlacked the strength and coordination 1o hold my own in most physical contests at the time. ore ei then, shortly afier [med thirteen, 1 overheard u conversation between i couple of older kids iu the dining hall. hey said there wes this guy in Gan Shmuel, a kibbutz to the north of us, who had an “amazing” ability. Using a strip of steel shaped to work fike a key, he could open locks even chunley Yale padlocks. the gold standard in those days — i less thaw a mine 35 Twas intrigued by the meebanical puzele and managed to locate two slightly rusted Jocks. One was a Yale, the other an [sracli-made lookalike called a Nabob, One evening after dinner, | searched the ground around the kibbutz guruge for shurds of metal that looked hke they naght G1 nto the key slot, und spent the nest half-hour or so propped against a tree, trying and failing to coax either lock to open. I realized I would need to discover how the locks worked But how 10 get inside to sce? Saturday aflemoons in Mish Uasharon were a quiet time, like the old Jewish neighborhoods and shtetls back in Europe but minus the religious trappings, The next day, [waited until mid-afternoon and walked past the bukery towards the garage. Its vol l-down, corrugated door was locked. So was the structure next Lo it, where the blacksmith and metalwork shop were. But attached to the blacksmiths was a hut where our scrap metal was dumped. [ doubted it would be locked, and it wasn't Pausing lo Jet my eyes get used to the dark. T made my way int the metalwork area. 1 crossed 10 Lhe cabinet where the tools were kept. I took out a steel jigsaw used for cutting through metal and, hiding it nner my shirt, made my way onl again Lurtunaely. the saw was up 10 the task of culling into the sofler alloy that made up the body of the locks. Once 1d cut inside them, [ saw they shared the same basic construction, ‘There was a series of springs and shafls which, in sesponse 10 the indentations of a key. aligned in such a way to allow the lock 10 open. [sneaked back into the metalwork shop five or six times. By trial and eror, [ managed to shape one of jigsaw blades into a pick tool that seemed like should do the job. For dis, | manipulated it imo cach of The padlocks. | kuew Thad the principle cight. but Tstill couldn’t gel it to work. Blisters formed oa my thumb and tingers. Then, finally, the Yale sprung open! With each successive fry | wot beter st knowing how 10 put the blide fn, when and where 0 rote it and how much pressure Lo apply. After Fashioning a half-dozen other tools, cach slightly different in width and shape, 1 reached a point where I could pet the saechanism lo work on my First try. Other locks — coors, Trunks, closets — were even easier afier [ made picks foc them as well Tcouldn't resist sharing my newly acquired skill with a couple of the boys in my class, amd word gradually spread. There was a handful of slightly older boys who we referred 10 as the “rogues”. | hey weren't delinquents. They were free spirits. bridling at the uniform expectations and rules of kibbutz life. Over the next few years, as co-conspirators mare than close friends, 1 found myself drawn 10 two of them. Tdo and Moshe were 18 months older than me. Though 36 Tdo was just few inches over five feet, he was strong and athlelic, a star even an the basketball court. Moshe was taller, if a bit overweight, Tle was nowhere near as strong as do, but still stronger than me, and had a streetwise intelligence ands sardine seas of humor. Both had tested the patience of or leachers to breaking point. [do had been sent off to a vocational school in Netanya. Moshe was moved to Mikveh Israel, a school which focused mostly on agriculture. On Utiday evenings and Saturdays in the kibbutz, however, they filled their tine with 2 variety of minor misdeeds. My role — the cement in our budding partmership was as designated lock-picker. Our first caper targeted the concrete security building near the dining hall. It conteinedd the kibbutz ’s store of weapons, with a metal door scenred by a padlock. Late one Friday night. with do and Moshe as lookouts, T erouchied in front af the lek and took out my tools. In less than a minute, | had it open, We daned into the stocecoon. These were about 80 rifles, along with a few machine guas, on tacks along the walls. Ido wok a rifle from the furthest end of the cack and wrapped it in a blanket. Moshe pocketed a box of atununition. As the atliers hurried bck to our donmitory, | closed the lock, miking sure i ws fo the same position 1°d found iL, and joined them. The next aflernoon, we stole away through the moshav of Kfar layin into a field on the far side. We tesc-ired the fle nul sunset, when we retmed to the labbutz and replaced it in the armory. 0 felt like the perfeet crime: foolproof, since 10 one was likely to notice anything. Dssentially harmless. And repeatable, as we confirmed by returning on Friday nights every month or two. This modest pre-adoleseent rebellion never extended to doubling the national mission of Tsrael. Growing up on a kibbutz in a country younger even than we were, we all felt a part of its brief history. and irs future. That was especially re afler my kibbutz menor, Yigal, left for his mifilary service and joined one of the Tseacli amy’s elite units The 1918 war had been won. But it had not brought peace. Palestinian irregular, fedayeen operating from Jordan and the Gaza Sp, momited hit-mds sun raids. (1 armed ambushes or by planting mines, they killed dozens of lseacli civilians and injured hundreds more. The country was in no mood for another war, The newly created Israeli armed forces known as Tada, & Hebrew weronym for the Issac Defense Force — also seemed to have lost the cutting edge, or perhaps the desperate motivation, of the pre-state militias. AL first, Ben- Gunon relied an young recruits in the new army’ infuntry brigades to counter the fedayeen auacks. Nearly 90 reprisal operations were launched in 1952 and a7 carly 1953. Neadly all coded with the soldiers failing to ceach their target or taking casualties. Sometimes both. By mid-1953, the army decided to set up [srael’s first dedicated commando force, 11 wis called Unit 101, 1 was led by i 25-year-old named Ariel Sharon, wha had been a platoon commander in 1948. With Ben-Gurion and especially his army chiet-of-staff, Moshe Dayan, determined to hit back hard at the feduyeen atfiucks, Sharan took a few dozen hand-picked soldiers and began outing a differcat kind of selitory witacks. | he largest, in October 1953, was in response to the murder of a woman and her two children in their home in centrul Israel, It was wgainst the West Bank village of Qibya. Shuron and bis commndas surrounded and attacked the village, destroying homes and other buildings — and killing at least 40 villagers sheltering inside them. Tscael immediately came imder intematiomal condemmation, accused of allowing its ttoops to unkash a massacre. Unit 101 was disbanded. IL lasted just halla year. But that was not because of Qibya. While cealizing the importance of avoiding civilian casualties, Dayan remained convinced that only units like 101 offered wny reahistic hope of faking se fight fo the fedayeen. He made Cini 101 the core of a larger commando force merged into Battalion $90 of the paratroopers’ brigade. and he put Sharon in overall command. Tt was this farce that Yigal Garber Joimed. He became part of its elite commando team, Company A and took part in & serics of attacks on the West Bank and in Gaza. While avoiding a repeal of Qibya. they inflicted heavy casualties on Jordan and Egyptian army and police units, und also suffered casualties of their own. Bauahon 890 was bused just i couple of miles from Mishmar [Tasharon and Yigal returned Lo the kibbutz every few weeks. [Te never talked about the commando operations. But every time there was a report of sruclis killed in u fedayeen stack, | knew there would be a retaliation rad, with my Yigal almost certainly involved and, Thoped, returning unscathed. Ile did. And in 1956, two years into his military service, he was part of Isruel’s second Fullescale wir, For a while, the reprisal anaeles seemed lo be working. "The fedayeen attacks deercased. But that didn’t last, especially in the south along the border with Gaza. Egypt's pro-Western monarchy liad been toppled in 4 coup organized by a group of army officers led by a stridently pane Arabi! — and anti-Israeli ~ liculenan colonel named Gamal Abdel Nasser. Egypt began providing not just tacit support for the fedayeen in Gaza, but arming and traming them and helping organize cross-horder attacks. Then, in 38 the summer of 1956, Nasser nationalized the Suez Canal, which had been ovened by the British and French. Ben-Gurion was emboldened to go war by the fact that both Britain and France wanted to retake the canal, Under an agreement reached beforehand, Isracl was w begin the hostilities, aller which the British and French would enter under the guise of separating Israeli and Egyptian forces. Ben-Gurion’s hope wis to end the threat of feduyeen strikes, ut least m the south, by taking contol both of Gaza and the enormous natural butler aiforded by the Sinai Desert. Militarily, it went to plan. On October 29, 1936, Yigal and other paratroopers from Battahon 890 were dropped deep mto the Sinai, They landed nar the entrance fo the Milla Pass, a sinuous route botsween two fines of craggy hills 25 miles from the canal. British and Trench air strikes began three days later, Nasser pulled most of lus forces back across the canal, By early November. [sacl was in control of Gaza and the whale of the Sinai. Politically, however, Ben-Gurion and bis Luropean pactoees had catastraphically miscalculated. Britain and France were fading imperial powers. The balance of power afer the Second World War rested with Amenca and the Soviet Union. Both were furious over the ubsiously pre-arranged seizure of Sinai, Gaza and the canal. It took a while for the message to sink in. [n a speech fo the Knesset fier the conguiest wits complete, Ben-Gurion declared the post- 1948 armistice null sud void, and said [sacl would never again allow “lowcign forces” to control the territory it had captured. A few duys later, however, he hud no choice but to deliver a different sessiuge in a vidio address 1 the country. He had af feast mamsged 1 scour a concession with the help of the Americans. The Sinai and Gaza would be placed under supervision of a UN farce. He also got a US assurance of [srael’s right of passe throngh the Sirils of Tran to the Red Se, and an agreement that iF the Lioyptians blocked Isracli shipping we would have the right to respond. But he announced faat we would be leaving every inch of territory taken in the war, By carly 1957, we did so. The one lstiniz gin came in Giza, On their way out, tsracli troops destroyed the fedayeen's military installations, and cross-border attacks from the south ceased. Unlike m 1948, the Sinai War touched me directly, 1 never felt Israel's existence was in danger. The fighting was brief sud Gar away. But Mishmar Tlasharon had a small role in the war plan. Ben-Gurion and Dayan were concerned thit the co-ovdmated attack might lead lo a wider war, with the possibility that Cpyptian warplanes might get involved as they bad in 1948. 39 Among the precautions they look was 10 base several hundred reservists fron the Alexandroni Brigade in a defensive position near the Mediterranean: the eucalyptus grove at the top end of our kibbutz, where the cover was so dense they were all but invisible from the wir. We kids seized on the chance 10 talk to the reservists. can’t remember whether it was Ido or Moshe who noticed an area at the back of their encampment, an the other side of the kibbutz cemetery. where neatly stacked Boxes of munitions were being kepl. Bul we spent the next several aflerivons on reconnaissance. A soldier was always on gard. But there were times the area was unwatched, either when one tard hinded over fo the next, or on their cigarette breaks. We struck the following [viday. Nowadays. the cemetery consists of a hall- dozen raws of headstones. Walking through it, as | still do at least once each year, is like revissting my past. Ahnost all the grown-ups | remember from my childhoud now vest there, including my parents. My father died in 2002, at the age of 92. My mother passed away only a few years ago, a few weeks atter her 100° birthsy. Bul in 1956, the cemelery was tiny. The chances of anyone being these aL midnight on & Friday were close 10 zero. Crouching in We shadow of the headstones. we could see the guard. We waited until he left for his break. Each of us took a wooden box and one of the slightly larger metal boxes, Inside, we found w treasure rove: thousands of bullets fo all kinds of weapons. The metal cases held heavier firepower: grenades and movtars. We returned those. We were mischievous, but not crazy, Yet each of us now had a crate full of wnmunition, even including bels for machine guns. My experience at school began to change in my carly teenage years as well. Shortly before my fourteen birthday, our age group was sent to a school outside Mishmar Hasshavon, The kibbutz had deeded that since there were only a dozen-or-su children in cach class, it wasn’t economically viable 10 provide a quality education. They sent us to the regional high school It was several hundred yards down the rad in the direction of Tel Aviv, It wass Gir more rigorous. [was mio longer the only kid in my class who hiked fo read or could do math problems in his head. It was there [ first sat truly 40 interested in science. When T came across conoepts T couldn't understand, our teachers always scemed able to answer my questions or help me find the answers myself, 1 liked the school enormously. | might well have gone an fo finish my secondary education there. [probably should have. But the nex year. he kibbutz brought us back again. One of the considerations was financial. Like many kibbutzim, Mishmar Hasthiran concluded tit m order to make its school more economically sustainable it would take in a number uf “outside children” — yelde chariz - trom towns and setclements around Israel. Yet this latest policy change was also triggered a debate over the kind of education kibbutzim should provide, Should kibbutz school offer s curricnhu tailored w prssing the bagra, the maticulation exam, and going on to university? Or should it limit itself Lo a fairly husic education geared to develapini the talents needed for a productive life on the kibbute? In a series of heated debates in the dining hell, almost all of Misha [ashacon supported the model of a basic, kibbutz-oriented education. My father was the leading voice among the dissenters, and though it seemed obvious he was fighting am uphill bale. 1 remember feeling a sense of prides at watching him — and an ceho in my own impulse to reach ny own judgment about issues and to act an it as | was growing older. Not only was he opposed to the new policy, He was aghast, [n the only time | can recall bs speaking ant at anc of the weekly kibbutz meetings, he asked how Mishmar Hasharou could take upon itself the right to constrain an individual childs life potential. “We are Jews!” he said. “We are people who have left aur impact on history through aur scholavs, not our peasants. | can’t understand how we, who came here to open a new chaplec in the history of our people. can choose to keep our sons and davghrers from studying. We should encouruge them to study!” He cece that Ue inlerests of Ue kibbiut mattered. Bu what kind of “model sociely™ would we be ecealing if we chose 10 “doom our own childsea to ignorance. and cut them off from the great forward momentum of history in tel and the whale world?” Lspecially in & hibbulz, however, the majority ruled. In this case, it was nearly unanimous, my mother included. T could see she felt torn, whether because she agreed with my father or becanse she realized how deeply he felt. Bul she secepted the decision. For her, that was what wes meant by being part of the lacger kibbutz family. all, my father didn’t give up. Tle couldn't change the kibbutz” ruling, But he fried to et me ta stay at the regional high school. A couple of yeas earlier, examiners had fanned out accoss Israel to administer its a4 first aptitude tests. T finished among he top two dozea results in the country. “Tow can you throw your pifls away? Tor whar,” he asked me. “If you leave that school, and give up on going to university, it will be like betraying yourselC™ At ane point, he walled me oul 1 the pated of hard-packed soil where we packed the actors and farm machinery. “What do you want 10 do with your life.” he asked. “Do you want to be a firmer? I thought about it before answering. “I don’t know what will hippen in the future.” | said “Bu it you ask me now, | would say | want to drive one of the Kibbutz trucks.” 1 could see the shock and disuppointment in his eyes. But it was the truth, | did immagine tn at some point §mght wnt 10 make s ie ouside the kibbutz. But I'd never lived anywhere else. If I was going to remain a part of it, I could think of no better way than to join our little corps of drivers, Though they lived an the kibbutz, they spent most of their time delivering or prekng up goods in places like Le] Aviv. Lolon ur Ashkelon. As the US Marines might have put it, I guess 1 figured I'd join the truck-drivers and see the world, The deeper reson | said no ta my father, as 1am sure he suspected, was that [lela need ww take control of my owa life. That was simply part of growing up, a process which probably happened more quickly for 1950s kibbutz children thun for town or city kids. We loved and respected our parents. But we were living with other teenies, We weren't just residents of the kibbutz, We were parc of the economic collective, working in the fields or orchards, the garage and the metal shop, This bred a sense of independence, 1 listened to my father's arguments. Bi tris was w decision shout my fue. 1 el [act 10 make if for myself. I cared about my education. But ['d reached a stage where my life outside the classroom, and my circle of friends, mattered more, [am sure that the sume impulse drove me m my contin freckanee forays ino lockpicking and petty larceny with Ido and Moshe. Sol returned to the kibbutz school. The level of teaching was nowhere near the regional schoal’s, But we did beg studying new subjects like economics and politics. There were two other welcome suprises as well. The fist was the arrival of a new history teacher. Knowledgable, enthusiastic and eloquent, he had a rare wif} for igniting excitement in his students, We studied the French Revolntion. He brought it 10 fife wills insights info Montesquicu, Rousscan sd Jolin Locke, Louis XVI and Mary Antoinette. Robespierre and Napoleon. Lie traced the dynamics that led 10 the revolution, and the way its ideals descended in the bloodshed and tearor that followed. Tle presented history as a human 42 process that aised as many questions as it answered, as something we could lear from. The second high-point was a couple named David and Leah Zimmerman, Thongh Mishmar Hasharon, hike other kibbulzim, was sceular, they miroduced us w the lalnud, the ancient compendium of rabbinic discussion and debate on the meaning of passages trom the Bible. We focused on two tractates, Baba Kama und Baba Meiziah, m which the rabbis drew on verses from Exodus to argue oul a system of rules for resolving civil disputes. 11 was he Talmud of torts. The intricacy and the depth of the rabbinical debate tascinated me. ox Yigal returned from the army a few manths after the 1956 war, when, like other lecnagers, | was about 16 enter i pre-military progenn known as Gadna. There were several options kids could choose. One was linked to the air force, another to the navy. But most of us joined the reconnaissance and scouting gro, Gadna Saverim. It involved sludying lopography und navigation, as well us field exercises that were a lot like the ones Yigal hed put us though a few years earlier. At year's end. we rook part in a national exercise. [twas called, a bit urndiosely. Aivan ef Yani. from sea to sea. We had to find our way from the Meditenanean, near Haifa, across northem Israel W a lake which was a sca only in name, the Sea of Galilee. Il lasted three days. We were placed in teams of four. We were each given i topographical map and a compass, with landrourks marked along the way which we had 10 find und draw in a notchook to prove we'd been there. A couple of hours in, we faced our first challenge. We were making our way wong a shepherds” sil, with brush und bramble on eather side, when the path split in wo. We had to decide which fork to take. The map didn't help. Lach inch covered the equivalent of a mile-and-a-halt. The key was to be able to mile it with what we were seeing around us, To use points we could identity from the map — Haifa and the sea in the receding distance, and a taller bill 10 our northeast — and then figure out which path was more likely to take us in the ght diteetion, 1 knew this mix of culeulation und mmagination wis somethmg | enjoyed Bul it was more thau that. ach of us had had the same prepargtion fos the exercise. As my rrek-mates trned to me for this first decision, and then on 43 cach successive stage as we crossed the Galilee, Tecalized that it was also something that [ was nawally good at Still, the closest thin: to real military activity remained my excurions with Ido and Moshe, Our ammunition Irunks were stowed under our beds. But the final picce of our arsenal fell into place in May 1958. For the tenth aniversary of [srael, there was a national exhibition celebrating the achievements of the state. | paid a first visit on my own. 1 wis curious to see what was on show, But us walked through, 1 couldn’ help noticing the lack of scewrity. wo days later, 1 recurned with 1do and Moshe. There was a stand devoted to the Israeli military industry, We already had a supply of smmunition for un Can submachine wun, conricsy of onr raid on the Alexandroni Brigade. Now, when the guy in charge of the stand was chatting with other visitors, we came away with an Uzi, 1 wass then the trouble began. Along with Ido, Moshe and the other older boys, 1 now lived in a larger docmitory under the cursory gaze of an older mictapelet. She was doing routine cleaning when she decided ta dust around the boxes under our beds. She’d never given them much thought. But when she tried 10 move one of them, she was amazed by its weight. She ol vue her sons- in-law to help. 1 think the box he pried open first was Moshe's. Bur within a few minutes he'd opened Ida’s and mine as well, Inside cach were hundreds of bullets and the machine-gun belts. side mine was our prized Uzi. 1 would nou exactly have taken the KG 10 work out the rest. The kibbutz leaders ordered an inquiry, Ido was summoned first, and attempted a brief show of defiance, “What's the big deal,” bie asked. “It’s just staff we colleeted. Why should yon care? Bul sepacately questioning Moshe, then Tdo again. the inquisitors worked out every detail. The fact that the ammunition had come from the Alexandroni Brigade, the reservists sent lo defend us, wis bad enough. Bui the U4 hud been stolen from the National Exhibition. That was even worse. It was left to the core of young men in their late 205 and 30s to figure out how to punish us. Everyone agreed we could not be reported lo the police. That would risk scandal for the Nibbutz. They decided to beat some sense into the offeaders. in foot of all the rest of the teenagers in the dormitory. wasn’t there. One atterncon each week, 1 now boarded a bus into Tel Aviv for my pino lesson. But when [retuned after sundown, 1 sensed immediatly something was wrong. Yigal was waiting at the bus stop outside the kibbutz. Tle told me that what [ had done was terrible. Nat just because it mvalved weapons, but because it was a breach of trust. Did you really steal ammunition from the 44 ary, he asked, his voice rising. Aad from the National Fehibition? 1 didn’t bother denying it 1 suppose T felt lucky they hadn't found out about our raids on the kibbutz armory, He did not administer my beating, That came a few weeks liter finn one of the kibbutz elders. He snnply taok me by the shonkders and shouted: “You must never do this again.” Twas worse for my parents. Ac first, they believed T was an innocent party. They were convinced | couldn't have gol mvolved in something ike this without being diagied in by the others. My Father even asked me whether the reason I'd been “dratted” by Ido and Moshe was because | was small, and able to squeeze thraugh tight spaces in windows nd doors, As it huppened, that did sometimes come in handy. But © told therm, no, | was nol an unlucky bystander Twas as much a part of it as the others. My father was angrier than T had ever seen him. My mother, faced with what must have seemed like a betrayal of every one of her Zionist principles, told me that if the kibbutz bad decided to sepoet us 1 the police. she would not have objected. Their mood lifted slightly when I began my final year of high school in September 1958. Afier Iwo years bck in the kibbutz school, our age-group was sent out again in another shift in policy. 1 his one was in response 10 signs of rowing support in Mishmar Hasharon and other kibbutzim for the argument my futher had mide against the quality of education we were offering, In order 1050 1 least some way toward meting that objection, Mishmar Hasharon was banding together with two dozen other kibbutzim and sending all 12"-graders io one of two outside high schools, The first, called Beit Berl, was a Libor Zionist nslitution focusing ou The humanities. In addition 10 a few of the less scadenie boys, most of the girls were sent there. The rest of us went to a place called Rupin. It was a few hundred yards past the regional high school. It specialized in agriculturally relisted scientific research. A few of the teachers were enormously sifted, and they were in the areas that most interested me: math, physics and biology. Yet the rest of the curricafim wis almost numbingly arinspiring. | did not mss a single math or scicnee class. But otherwise, | began seiting my own schedule. Some days, | would sleep late, or not 20 atall. When I did go, T'd often show up without having dane the homework, Neither [do nor Moshe was with me at Rupin, They were sturting their military service. But | assembled a ew band of mischict- makers, and it was not hard to entice them to go AWOL. I was warned several Himes by the school adminisiraior. He said be could not accommodale a student who seemed oblivious 10, or dismissive of. the rules. Ile 45 was especially upset because my attitude seemed to be infecting others. A fev months into the school year, he told the leaders of Mishmar Tlasharon, and thes my parents, that [would hive to leave, My father was especially upset, A couple of years warlicr, he'd hid visions of my suyinig on in the regional high school and going 10 university. Now, 1d been unable to hold my ow in Rupio Still, both he and oy mother were relieved when Mishmar Iasharon and the school worked oul a compromise which did not end my studies altogether. The expulsion stood, but | was allowed to continue attending math and science classes. For my mother, the blow was softened by the fact I began working almost full-time on the kibbutz. alongside Yigal, driving a tractor. | woke up early and accompanied hin into he fields of wheat, barley or rye. We also made a series of trips 130 miles south inta the Negev to a moshay called Patish, It had been setup by newly arrived Moroccan Jews. Since they didn’t have the equipment ar know-low Lo cultivate all their fields, they were realing out some of the land. Mishmar [asharon had contracted to farm a parcel of 450 aces For ten days ut a time, Yigal and [would place a imetor on the buck of a pickup and head to Patish. We worked irom four in the morning until sundown. After work, we ate at a tiny family-run restaurant a tew miles away in Ofakin. a so-called “development town” populated by Vioroccan Jews who had been moved there is soon ws they arrived in Israel. Far from regretting not being in school, T drew satisfaction, and pride, from knowing that [ was functioning as an independent adult, But t also gave me time to think. My whole fife had been circumscribed by the strugghe to erate sud secure the state. Bu | again Round myself pondering issues of basic fairness in our young country, and the challenge of reconciling our words and principles with our deeds amid the dificnlt realitiex of building the stale Back on the kibbutz, it was the example of the kindly and hard-working Baddura which had caused me to question how we were treating the Jews who had anrived from Yemen. In the Negev, [ mel members of the even larger poste weer influx from Morocco. One inkage struck ine above all. IL was from the place Yigal and ate dinner. Ofakim was a development town that had yet to develop. tt add no visible means of support, and there was no sign the govermnent was doing much w remedy that or inlegrale the new immigraus cconomically and socially. The “restaurant” was a side business a family had set up in the dining Taam of their tiny home, The sixth ar seventh fime we went there, | was startled by sudden movement a couple of feet away from where we were sitting 46 Looking more closely. I saw a wooden bos, the kind we used in Mishmar Tesharon to erate oranges. Tt was filled with hay. Au first, 1 thought the stircing inside was a family pet, Then, I saw it was a baby. I said nothing until we had Teli. “Was thal really w child?” | asked Yigal “A baby?” He replied, with a tinge of sadness but also a look that scemed Lo convey surprise at my nzively: “Yes. They don’t have room for him.” or My evolving feelings about the Arabs, the other people with dreams of what they sill saw as Palestine, would become more complex as my childhood drew 1o.an end. As mentioned, T barely registered the fate of the absent villagers of Wadi Khwaret, And yetas | got older m my teens [eame lo understand why the Palestinians were fighting us. Before the 1956 war, Dayan gave a brief speech that had a powerful impact on me, It was a eulogy. but it was for sameane Dayan didn’t know personally. His miended andience was the rest of the country. 11e spoke in Nahal Oz, a kibbutz on the border with Gaza often targeted by fedayeen. In April 1956, a group of Arabs crossed from Gaza and began cutting down the wheat in Nihal 07 fields. The kibbutz security officer, «2 l-year-old named Roi Rotherg, rode out on horseback 10 chase them away. The intruders apened fire as soon as he got close. They beat him, shot him dead and talk the bady back over the irmistice line, The corpse was retumed, silted, afer wn Jsracli protest trough the UN. With Iscecli newspapers full of agonized accounts of what had happened, Dayan’ messajre was that we should not blame the Arb for Roi Rotbers’s death. We should look at ourselves, und the neighborhood in which we lived. “Why should we talk about their buring hatred for us? he asked. “Uor cight years, they have been sitting in the refugee camps of Gaza, while betore their eyes we have been teansforming the lands and the villages where they and their Fathers dwell” OF course, they haled us and the state we were building. Rotberg had allowed his “yearning for peace to deafen his ears, and he did not hear the voice of murder waiting in ambush,” Dayan suid the danger was that other Israclis had become similady naive. “How did we shu our eyes, and refuse 10 see, inall its brutality, the destiny of our generation” A generation which was 47 settling the land but which, “without Lhe steel helmet and the bacrel of the pun, will not succeed in planting a ee or building a home.” Still, if I was part of a generation that understood the need for military preparedness, strength and a readiness to fight if we were lo survive m the Middle ast, the 1956 war also brought home to me the need to consider ow we fought. This meant grappling with a contradiction wired into Zionism from the sturt: the need to tuke up arms to defend our state, whiks recognizing the Jewish moral code that was its foundation. When the Israeli armed lovees were established in 1948, Tzahal's doctrine included the principle of fofar Aaneshek “purity of grms™ and an explicit requirement for our soldiers fo use the minimum necessary force and do all they conld to avoid civilian casual tics. Putting “purity of arms” into practice was always going 10 be hard. All aos ill, In all wars, civilians die. But that did not make the principle, or the need to be aware of iL in combat, any less important Liven if the soldier called on the make that judgment was someone who had mentored me fiom the time 1 was six. and whose military prowess 1 had come to respect, Kven i'it was Yagal Garber. His parachute jump on the fst day of the 1956 war went smoothly. But the battle for control uf the Mila Pass wrned out fo be the most deadly of the war. It was also unnecessary. Under Isragl's pre- war choreography with the British and French, the very fisct of aur kinding near the Mitla Pass was 10 be the trigger for an Anglo-French attack. In fact, Avik Sharon, the commander of Battalion 890, received orders from Tel Aviv nor take the pass, Only grudgmpgly, did they let him send in a recamnssance force 10 establish whether il wis sale fo eros. The reconnaissance company walked into a trap. Machine-guo and mortar fire rained dawn from Fygyptian troops dug inta the caves and other natural defensive postions above the pass. 1 tok hours to extricate the stamded men Yigal’s ait fought its way in from the caster side of the pass. A small group from the reconnaissance force managed to get 4 foothold on the western side. Almost 250 Fgypians were killed. But 38 Israch paratroopers also died, the Target single toll in any battle since 1948. Battered and bitter, the surviving men from the reconnaissance force parachuted into the southernmost part of the Sma, near Et=Tur on the Red Sea. Yigal and the others headed overground to join up with them. By the lime they gol there, Egyplian resistance bid all but ended. Yigal's company had a brief exchange of fire with several dozen hold- outs m fhe Firyptian farce. The Firyptians surrendered. And then, apparently, Yigal and his fellow paratroopers shot all of them dead. 48 Atlcast those wees the rumors afier the war. T asked fricads what they were hearing. [asked some of the older men on the kibbutz, my Father included. All of them responded with a slightly different version of events. But | knew what [ wasn ’s hearing. Noone of them told me if was lie. When |asked Yigal, he averted my glance, and then changed the subject. [knew it was Leue. at least broadly. [realized that, before it happened, Yigal and the others bud seen dozens of friends gunned down in an eyptian ambush in the Mitla Pass. But [didn’t need alesson fohar haneshek to know that the killing of captured Egyptian soldiers should not have happened, Or that it was pluialy, simply wrong. When Yigal and [mad ous ial irip lo Patish in 1959, 1 knew it would be poindess to ask him about it. Whatever he said wouldn't change anything. T still respected his courage und his fighting spirit, and the part he'd played in defending Imac. | appreciated whit he'd done for me as | grew up. But what mattered now wasa't what Yigal had dove. [was what Lwould do, and how | would live my life. Especially since [ too, was bout to begin my army service, 49 Chapter Three 1 reported for induction on the second Sunday of November 1959, three months short of my eighteenth birfaduy. Military service was u neur-tmiversa site of passage for Tsracli teenagers. For ohildren of the kibbutz, it held even greater significance. Now that we had a country, the kibburzaiks' role as the avant-garde in taming and faeming the land had ceased to he relevant. But the sense of mission we'd been raised with — what we were led 10 believe set us apart from the mere “city-dwellers™ — drove us to aspire, maybe even assume, we would leave an imprint in oftier spheres of the new state”s life. | doubt it's an accident thal nesnly every ane of the boys with whom | grew tp fn Mishmar Ilasharon went on to become an officer during his time in the military Tudyging: from my own first few weeks in uniform, however, there was every seuson to believe [would end up us an unfortuae, mdistinguished exception This was not due 10 lack of anibition. In fact, T thought at frst of joining the air force. But a question on the application form asked whether I ever suffered from any breathing dco fort. Like ahnost everyone on the kibbutz, | did gel a bit clogged up whea the weather ened cold and damp. So 1 uaively answered yes, ending any chance of training 25 a pilot. My fallback choice was a tank uit. But when {joined the hundreds of other draflces at the processmg center near Tel Aviv, about a hundsed of us were shunted. by alphabetical lottery. into training tor armored personnel carriers instead. Known as battle taxis, tae APCs which Israel had at the time were lumbering, World War Two-vintage lalfiracks Our eaining battalion was based, aloagside the country's majo armored brigade, in a huge. hillside army camp outside Beersheva in the Negev. I knew thst on tironat — basic teaming — woukd be ough. Thal was the whale poinl. But we endured a seemingly endless array of inspections, under the waichful eve of a corporal who meted out punishments for the tiniest scutf on a boot, a bell, av ie nifle. The rest of the tine was spent m physical inuizing, which 1 found especially hard, al least at the beginning. {sill weighed barely 130 pounds, and by 0 means all. or even most, of it was muscle. My military career, such as it was, looked very likely fo invelve spending: my required couple of years baling inside an APC in the Negev before moving ou to something more useful, and certainly more fulfilling, with the rest of my life 50 But a series of accidents. in Israels life and in mine, would soon point me in 2 deamatically different dircetion. The first became known as the Rotem Crisis. and it delivered a jolting reminder of Israel's vulnerability fo a surprise attack from neighboring Avab states. Mililarily, we were far stronger tian in 1948. Bul we were still a young country, at an early stage in our economic development Our defense strategy rested on a recognition we could not afford to sustain a large standing amy, relying insicad on a pool of trained reservists. The problem wees that a full call-up of the reserves would require something like 48 hours That meant some form of early warning was critical. Rotem erupted in February 1960, about halfiway trough my sons. and began almost Farcically. The Chil of Mility bielligenee, Chaim Herzog, was at a diplomatic eceiption in Tel Aviv when he began chaing with a guest he knew well; the head of the local C1A station, What, the American asked, did he make of the fat that Egypt had moved its two main armored divisions into the Sinai, wad the border with Tsracl? Ilerzog came up with a suitably woolly reply, about how it was obviously a situation which bore watching. But the truth wes thal neither hie nor anyone else in Ismet bad amy iden abo! the Fgyprian mobilization. 1c left the party as soon as he could, to tell Dayan and Ben- Gurion. When a reconnaissance flight the next day confirmed that dozens of battle-ready tanks had been rolled forward toward the Suez Canal, Ben-Gurion and the generals scrambled for a response. They did not want a war. Ben-Gurion was particulady worried that in responding to Nasser’s buildup, he might inadvertently eseulste things further, He vetoed the idea of a full mobilization. But he did order a moss limited call- up. of ehout 7,000 reservists. Tle placed the air force on alert. Tle directed the four brigades responsible for the defense of southern Israel, including our wmored brigade near Becrshesa, lo move within i few miles of the border — and pave us the additional cole uf sending several overnight munitions convoys to equip the hastily assembled border force. The first sim | saw that anything exirordinary was gomy on was the sudden movement of tanks and APCS inside our camp. At first, 10 ane told us raw recruits anything. We were left to look on. and stay ouc of the way. But with our operational mits prepiring to mave forward, the problem was that there seemed 50 one elie wilh the expertise, expericnee and local knowledge to lead the supply columas. So our training bautalion was summoned before the platoon communder, “Any volunteers,” he asked. When none of us raised a hand, he said: “Come on. One ofl you must have grown up around here. That means the 51 first 25 miles will be familiar territory.” le lelt unspoken the obvious postscript: the need to negotiate the final five Lo ten miles, through open desert, and to find fhe right area, on our side of a border that wasn’t even marked, “Cant any of you.” he banked, “leads convoy of a Few dozen nicks? Pm not sure what possessed ue. But | thought to myself: yes, | probably can. 1 had been scouting and navigating in one way or another since those first evenings with Yigal in the kibbutz orchards, 1°d trained with Gadna Saverim, And while I'd never lived in the south, the farm scitlement of Patish, where I'd worked along with Yigal after getting kicked aut of high school, was not far from the route the conveys would hae 10 take. So raised my hand. “Can you lead a convoy?" hie asked. “Yes, sir,” L said. “Of course, I'll need a map. And a compass.” “Why do you think you're qualified?” he prodded. 1d been in Gana Sperm. | said | was good wilh maps. “Okay.” he replied. and be seat me. along with two of the company’s junior officers, to the barcalion commander, Someone must have phoned head. becaise he was clearly expecting us. SUL T could see the surprise in his eyes when he looked at me: valy just eighteen. but looking closer to 15. my uniform sagging on my slender frame. He gazedat the officers, then back at me, then at the officers again, as if trying to fire out whether be wis shout 10 approve something utterly crazy. But he had lire choice. Three convoys had to be dispatched within the next couple of hours. So fur, with me. he had a sum tofal of one guy fo lead them, “Fine,” he sank, and waved us oul. The column consisted of eight huge. American-made six-wheelers, each packed with ten tons of munitions and other supplies. 1 was in the lead ruck. “The driver was a reservist in his mid-30s. So were most of the men in the rest of the transport trucks. one driver and one soldier in each. A staff sergeant, in the second vehicle, was in theoretical command. But. surreal though it felt. [ was actually in charge, since 1 was the only person who might, concervibly, get us io the tight place. The platoon commander was right. The first part, on paved roads, was fairly easy. But just before sunset. we reached open desert. the beginning of more than three hours of picking and weaving, calibrating and recalibrating, our way across a wide expanse an sand and occasional serub bushes that, every mile or 52 50, would suddenly give way 10 a windswept series of dunes and wadis. The map and compass helped. But [ soon realized that it was almost impossible to get an accurate reading from inside the truck, Every few minutes, 1 waved the convoy 1 slop, ol aut, aud walked filly ov sity yards mio te sand and chimps al acacia trees and calibrated our progress from there. My Fallback was the stars. From them. I could at least make sure we were headed in broadly the right diteetion. But the need to navigate around the duncs meant we were never moving in a pertoctly straight line. The miles ticking by on the tuek’s odometer couldn’t tell me exactly how far we'd travelled. A couple of times, [ realized we were wandering oft line mot by a much, but enough to isk leaving us gither a mike or lwo south of where we were supposed 1 go or, worse, on the Ligyplian side of an unmarked desert frontier that, especially at night, would look pretty much the same on either side. Tinally, a few boues before dawn, 1 brought fhe convoy to a halt. I elimbed out, walked back 10 the stall sergeant and told him, with more confidence than T felt: “We're here.” [ had no way of knowing for sure. But I felt we were generally in the right place. Before we'd set of, 1 was briefed by the officer in charge of one of the operational APC baualions. Ie had been 10 the acca before, on training exercises. Because of the emergency call-up, he was too senior to Teas supply convoy. But he told me tht once we got there, we should stop and wait. Le would follow our tracks the next morning aud link up with us. Au hour after sunrise, we saw his jeep bobbing over the sand towards us. [le pulled to a stop. shook hands with the statt sergeant. and then he turned to me. “Unbelievable,” be said. “We're where we need 1o be.” Our role in the grand scheme of things, and certainly mine, was hardly decisive. But the rest of the border mobilization also went to plan. That, along with some Gatic diplomatic activity and s healthy commen sense on all sides, ensured that a new war with Tgypt was averted — at least fo a further half- dozen years, until 1967. By then, the lessen of Rotem would be learned: our need to Gnd a reliable wiry 10 Lp ino the bale plans of the hostile Arab states around us. And through another wholly unexpected turn of events starting just a few weeks afer the Rotem Crisis. I would turn out to play a personal role in making that happen. x oro 53 Under army regulations. raining recruits got a five-day leave every few months during rérunut. My first one came a bit later than usual, due to Rotem But in April 1960, shartly before the Passover haliday, | headed back to Mishima Hisshavon, Despite my minor iriwnph of desert mavigalion, {sill bid every teason 10 believe I'd be spending the next couple of years in an APC unit in the Negev, and can't pretend I was looking forward to it. Still. the idea of sewening home in my army uniform. at least a bit swronger and bulkier than before, did give me a sense of pride. Tt was on my thicd day back. when Twas in the dining hall with a half-dozen schoolmates-tumed-saldiers, that Avraham Ramon sat down and joined us. He was a yeled chuiiz, one of the “hoys from outside” who had joined our class when we were taken out of the regional high school. Tle, too, was now in the army, As we were finishing limeh, he asked me: “How’s ironur?™ “Tough.” 1 sand. “Boring,” Smiling, he said: “How would you feel abou juining saperer” The question took me by surprise. In Hebrew. saver meant “reconnaissance wit”. 1 wins the mame given lo special units that carried ont missions bem enemy lines, or under particularly exacting conditions. In the early 1960s, thece were only two of nate. One was Sigverer Gulani. attached ta the Golani Brigade near the northern border. The tenly elite one was Sayeret Pzankanim, the paraicuopers” sayeret 11 had been built from Company A of Battalion 890, where Yigal had served in the 1950s “Which sayerer?” asked “10s called Saveret Marka,” he replied. Td never heard of it. When asked what it did. he said: “I'm not allowed to say. But are you interested?” The air of mystery made it seem only more enticing, And na matter what it did, it had to be a step up from what lay ahead of me in the Negev. “Yeah. Sure,” replied. 1 heard nothing further in the days after I gor back to Beersheva. But a the end of the month, [was ordered to report fo a small hui in im army base near Tel Aviv. Itbelonged wo aka Fsser. the personne] depactment of militacy intelligence. I was preeted by owo men in their late 20s. One of them, shorter even than me, introduced himself us Sami Nachmias. The other was tall and slim and said in a surprisingly quiet voice: “I'm Shinil Ben-Zvi” They were two names which I, Tike most Isracli teenagers at the time, knew well. Ben-Zvi 54 had been an officer in Arik Sharon's original Unit 101, and Nachmias was ne af the carliest recruits to Company A. They shook my hand and motioned me into a Jeep, As we drove out of the base, they peppered me with questions about almost anyihing except the anny: the kibbutz, school, sparts. Then, Ben-Zai pulled the Jeep to the side of the road. turaed around Lo face me and asked: “Is it true you can pick locks?” Yes. 1 said. “Da you want me to show you?” He sand that wouldn't be nccessary. “Is it ue you can navigate? Read maps?” Nachuias asked. I said yes They drove me back to the base in silence. “OK,” Nachmias said. “You'll probably hear rom us.” Tdida’t, But as basic taining was winding down, T got a funher order: to report to an address in Trahal, neighborhaod in narth Tel Aviv where lot of military officers ved. IL wos a small house with a metal gate ouside. | was met at the door by a man bout 30 in shorts and a T-shirt who introduced himself as Avraham Arnan. Ile led me inside. le unfurled a map of Jerusalem and the surround hills. He pointed 10 w spot on the southwest of The city. He drew i wide, curving line through the bills 10 a second point. “You know how 10 ead a map?” he asked. When I nodded, he said: “I want you to describe to me — just as i you were walking on this line exactly whit you see, is you make yor wiy to the place | marked.” | used the elevation lines on the map as a uid, and the positioning of the hills aud woodland and villages on the map. and began describing how each stage would look. When [ was finished, his anly response was the hint of a smile. When he spoke, il wasn’t about the map. 11 was, again, about picking locks. “Tlow did you learn™ he asked. T explained how I'd cut into the locks. figured out how they worked and made a set of tools ta open them, “hank you,” he sid. “You can return to your unit.” Though he hada't said so, T pot a feeling this was the Sayecet Matkal equivalent of a final job interview. When I pot back to Beersheva. I dug around ws disercetly is possible Ror details abou Avrabim Aman. 1 keamed he hd served in 1948 in the hills around Jerusalem, so ie would have hoven first-hand the terrain he asked me to describe. That. I puessed, explained the half-smile. But | was entering my last week of firm, [still had na idea whether 1°d be spending lie next couple of years inside an APC — or in a sayeret whose function was a mystery. beyond the fact it seemed less interested in whether my boots were shined than whether | could pick a lock. 55 The day before the end of basic raining, T was told to return 10 Maka Esser. A Jeep was wailing. A soldier was at the wheel. Tle mumbled hello and drove me ta a sprawling military base about 15 minutes away, not too far from the oemational airport in Lod. 11 was built by the Bulish in the Sceomd World War for the RAL. Afer 1948, the main part had been converted into Jsael’s officer- training school. But at the far end, set back fiom a criss-cross of runways. was a pair of domed conerete sheliers which had been used by the British for Munitions storage. Five ents. 1wo field toilets. And a single-story brick structure with a tin roof. It contained offices for Avraham Aman, a couple of other officers and a secretary, a kitchenette and a room for storing weapons. I'his was the home uf Sayeret Matkal, although the first thing | was wld was that no one. outside 2 handful of senior officers in military headquarters, knew we existed. x owe The heart and soul of Sayeret Matkal was Avraham Aman, Fyen from my brief first encounter with him in bis living coom in Tzahala, I was stuck by his physical presence. with almost movie-star looks and a face made even more intriguing by the fact he hil dilterent-colured eyes, one brown smd one a picreing green. Bus what teally set him apa, as | got to know him aud come wader his spell in the sayeret, was his playful, almost bohemian disregard for the ‘normal strictures and structures, rules and regulations, of the armed forces. What mauered to him was what actually needed 10 get done, and how best lo accomplish it despite all the bureaucratic obstacles, and he made me and his other teenage recruits teel we were equal partners with him in getting there. Years luter, he confided tht if his life had not led him into the military, he would have probably chosen something in the acts or culture, maybe directing films. But he had volunteered for the Ilaganah at age 17, a year before the 1948 war. As Lhe losses monnied in Jerusalem, he found himself m the Pahnach’s crack Harel Brigade, under the command of a future Isracli chiel-of-stalT, Dado Clazar. His vision for Sayeret Matkal became [srael’s answer to the dangers identified by Rotem. But il bad ils origius in his experiences in the years afer 1948, when he joined a military intelligence proup running a loose network of Arab agents weross racks northern border. They provided oceasioual bits of 56 information. But in talking with his wartime [riends, he cealized this kind of low-level intelligence could never address the real need for Israel: Lo ensure we. had early warning if Syria ar 1 ebanon, Jordan ar Figypt, were preparing fo 20 to wa agg ns. Ie began loying with the idea of raining a small foree of 1svacli soldiers lo #0 an cross-border intelligence missions. The initial response from the firva mihtary headquarters m Tel Aviv was so frustrating that anyone else would have given up. None of the generals saw any reso lo believe his scheme would work. But the real obstacle was their continuing trauma over what had happened the last time Istucli soldiers crossed the border on an intelligence mission. 11 had happened in 1954, and il ended im a failure even more serious than Rotem. The target was the Golan [Teights. inside Syria. The special technology mit attached to military intelligence had developed u buggy device designed to be placed on a telephone pole on the Golan. The task of installing it was given o the most decorated. and respected, commando unit in the army: Company A in Sharon's paratroop battalion, led by its commander, Meir Har-Zion. Ou a spring night in 1954, Har-Zion led his team onto the Golan. They Tipgred the bugging unit to the telephone pale, buried the bulky transmitter and mide their way ick. And it worked. Israeli intelligence could hsten m fo military commuuications vn the Heights. The biteh as thal the baucrics had to be replaced every few weeks. Several more times, Meir and his men sneaked back mto Syria to keep the bug working, But as commander of Company A, Mir wis i key part of Israel's anti-fodaycen operations. The lst thing Moshe Dayan wanted to risk was seeing him captuced while trying 10 replace a few batteries. So he shifted the task to a regular unit from the Golani Brigade. In December 1954, u handover mission was organized. Three men from Company A, including one of Meir's sergeants, joined three from the Golani Brigade. But they didn’t even hold a joint exercise before setting oft, There was also it ack of clarity shout who was i charge, Though the Goli commander was nominally the senior wfficer, only the Company A men had any first-hand experience of this kind of mission. A half-mile onto the ITeights. they were intercepted by a Syrian soldiers, If this had been a Company A operation, the response would have been automatic. They would have wheeled, opened fie and attacked. But when the Syrians ordered the Golanis to drop their weapons, one af them did, and the Company A men followed suit, They were all taken to Damascus, held in solitary confinement, beaten and tortured. 57 Oue of the captured Golani soldiers was a 19-year-old named Uri Tlan, the son of a member of the Israeli Knesset whom Ben-Gurion and the whole of the government knew well, The soldiers” captivity drayred on until they were finally veturmed fo Israel in Murch 1956. By then, however, Uti lan had lunged himsell. [le managed Lo hide a note into his uniform. Iu was found when the body was being prepared for burial. It read: Lo bagadeti. Nekumah, “I did not betray anything. Revenge.” liver since the Uri Jan mission, there had been a de ficio ban on cross- border intelligence operations by Israeli soldiers. Ben-Gurion and his military commanders knew, of course, the mportance of getting early warning of an enemy sttck. Bul they decided the price of possible Grilue was simply too high. Sayeret Matkal was bom three vears later. Avraham was still part of the unit ming low-level agents m Syvia and | chamon, but his communder reluctantly agreed allow him to set up bis new intelligence group. Lis initial “headquarters” was a sparsely furnished Tel Aviv apartment. The first people he bronght in were veterans of the Palmiach’s Arab Pluoon, pre-state Fighters who trained themselves to pass as Arabs and gather intelligence. or stage raids, behind enemy lines. Next, he invited friends who had served in Unit 101 and Company A. Finally, he enlisted a core of them to help tri reernits fo ns new sayerel. He hoped the involvement of these commando veterans would also give the unit credibility inside the irya. One of them, Micha Kapusta, had been part of 101, us had Itzhak Gabli, who bud been a teenage Palmachnik in 1948, A third wis another Company A officer waned Aharon Eshel, known us Errol, in part for his undeniably Trcol Tlynn-like swagger, but also an actonya of his Hebrew name. But the crowing addition to the sroup liad the distinction of having led the last successful Tseeli bugging mission on the Golan, in addition 10 being the most respected commando in Tseael. a man who Dayan would Tater call the country’s greatest soldier. It was Meir 1lar-Zion lumself. owe 1 was part of the second group of recruits to Saverer Matial, in the early summer of 1960. The unit had been given its own base barely a year carlier. 3u ic hiad yet to carry out a single mission, and there was no sign of that happening. Avrabiam couldn't be sure when, or if the generals in the kirya might give hin 58 the go-ahead. Sul, he was convinced that if we could demonsieate a Loughoess, conumiument and competence which offered an obvious addition Lo [sracl’s intelligence capability, even they wauld recognize the folly of nat using it, He made every one of us feel a purt of making this possible. | was onc of ten new recruits, bringing the size of the sayeret 10 twenty. We were almost all teenagers. In fact, the oldest of our officers was 21. Most of the men were Sephiurdi Jews. For a unit like ours, with the wim of imdurtaking sceret missions in Arzh countvies, Avraham believed that a background in Avabic culuure and language was an important asset. [ was the sayeret's only lock-picker. But all of us had been recruited mn the much sume way that [ was, It was how the top Patmach units had been formed, and the way Sharon assembled Unit 101: friends recommending friends. in my case, my old yeled chniz schoolmate from the kibbutz, We trained in the whole range of commands skills. We nsed not only Usis, but Soviet-made Kalashnikovs and Gurivaoy machine guas. We worked with detonators and explosives, We staged raids on Israeli airfields. We conducted excrcisis using rubber dinghics 10 practice attacking from fhe sca. Bul mostly we walked. For hundreds of miles, altos always al night the length and breads of fhe country. We would study a map of each area, committing: every town or village, hilltap or dry creck bed, to memory before we set off, 1 can sill semember what Meir Haron told us: 10 be truly prepared, you useded to spend “an hour for an hour” — an equal time mastering the lay of the land tw the amount you'd need ta carry out an operation. [t was a gruelling regime designed fo push 1s 10 the very limits of endurance. On one series of excreises, we were limited Lo a single canteen of water as we trekked deep into the Negev Desert. It was gruelling, designed to push us ro the very limits of endurance. [ remember he first time Frrol sei eyes on me afer | joined the mil. He twmed lo Avraham, laughed, and said: “Are we taking high school kids now?” But before long, Iwas a “high school kid” no longer. Meir Ha=7aom sirely look a direel pat in our exereises. On his fing] Company A mission, a mouth before the 1956 war, he had been shot in his throat and arm. A medic saved his life by performing a tracheotomy. But his speceh was affected, und he snll bid almost no use of his right wm, Erol, Micha Kapista aud Yitzhak Gibli were more actively involved swith us. icy were there not only to help tain us, but to instill a commando attitude. a spirit of confidence bordering on bravada, 59 Kapusia was our guide on our punishing five-day treks through the Negev Though Avraham would see us oflat the start, he stayed back at the base. In a couple of the exercises, we relied on carrier pieans to keep in touch with the bse, ntl Kaepiasta begga killing them for dinner. Once, on a scavingly bot desert afternoon, hours fiom the nearest hospital. he spotted 4 poisonous snake. Tle used pieces of wood to pry its head up from the sand, erabbed its neck and strangled iL We also studied some Arabic, though most of the Sephardi recruits already spoke the language. My tutor was a Cairo-born Jew named Amin. In part because he enjoyed mathematics and played the violm, we hit it off inmmediiely. He was abso deal in one ve. Languages hive never been my forte Even in Tebrew, T have a slight lisp. That made mastering Arabic even harder. Sill, Amin would frequently compliment me on my accent, at which point the aters in the class would point out tha was lucky he was hard of heaving. A year in, we were given a classroom briefing ou what to do if we fll into enemy hands. The gist was to tell them only our name, rank and serial number. Bul we had a special session with Gibh, wha told ws about wh captivity was seally like. He had been shot and wounded during a cetaliation operation in 1954 and was captured by the Jordanians. Until his release. he was kept in solitary confinement and tortured, The details of ns imprisonment, the beatings and the cigarette burns, were lurid. Partly because we were developing a bil of commando self-confidence — but mostly to hide the discomfort of wondering how cach of us would react fo bem in enemy hands we heckled him over im account. hit seemed 0 gel more heroic with cach retelling. He wisely ignored us. Tle told us that survival would be down not just to physical strength. Tt required strength of mind, the kind of subtlety required to give yout captors something to keep therm at bay and 10 establish some fom of human bond, to but withhold anything of geouine value A few weeks later. the whole saveret held a four-day exercise in the Galilee. On the second might, at boul four in the moming, we shook off our backpucks and settled in for & few hours’ sleep. The first thing | heard was shouting in Arabic. T saw a guy hovering over ie, his face covered. Ile handcuiled me, pulled a burlap sick over my hed, yanked me to me fect and led me off, We were piled info the back of truck. From the whispered comments around me, | assumed all twenty of us had been taken. We drove for nearly four hours. Twice, | gol am slap across the fice, mare painful because of the burlap. 1 kept 60 HOUSE_OVERSIGHT_0115631 telling myself this fad 10 be part of our Leaining. IF it was for real, we'd have been more badly beaten, or killed. Still, 1 couldn't be completely sure. The truck lurched to a stop. We were led into a building, down a hallway and into a large room. The walls were bre except for a series of won vings. Our captors wre the sacks from our heads for a few moments, and tied our wrists to the manacles. For the first six or seven hours we were kept toether. arms shackled and raised. Then they took us way ane by on. 1 was the last fo be led out. | was taken 10 a room so small there was not even space for a col. It wasn’t ntl the last shaft of light disappeared trom the slit-like window near the top of wall that the first mterrogutor shawed up. He unlocked fae door, entered and snfolded meted elusic. He wanted answers: whit anil ws | Grom, what did our unit do. who were our commanders, what were our orders, and what was our desigmated role m the event of war, 1 tokd him my mame, rank and seal number. Aller each question, 1 repeated them, or shook my head in silence, “You will answer, sooner or later,” he shouted in heavily Arabic-accented Hebrew, hitting me across the face, “All of you wll.” For four days and nights, other interrogtors shouted aut the same questions. | was slapped dozens of times. Punched in the stomach. Que of the captors uncuffed me and bent my arm behind my back, wrenching it upward. Though | was determined not 0 cry out, | grmted in pain, Over and over, 1 told myself: “This is aot for real. They can hurt me. Bu they have limits. They can twist my arm. They can hurt me. But there's no way they can break my arm” Twas not allowed to sleep, 1 wis never lett alone for more than a half-hour, 171 was crouching on the ston Moor, | would be yanked to my feel sud punched or slapped. Twice a day. I was taken from my cell to a primitive toilet and piven minute fo relieve myself. There were only two changes ta the routine, On a Fow occisions, five or six of ws were brought buck imo the kgs room and fold wee wouldn't be lel go until we had given them more of what they wanted — the implication being that some of us had already faliced. And once or twice, the interrogators sent in a good cop. “Lean Aelp you,” he told me. “But you have to give me something But when it was over, none of us had talked. We didn’t fool ourselves jouw thinking that meant we could hold up m genuine captivity, There, they could bicuk your sun. They could burn your chest with eigarciles, vip out a Ggensil ora tooth. They could kill you. The main value iad been to ive us some sense of what we igh Face. We might still be afraid, but at least it would no longer be fear of the unknowa. 61 Challenging though our training was, T found every bit of it enthralling and, with cach new test passed, somehow empowering and exhilicating. This was all the mare remarkable because we hud still yet to carry aut u single operation, If anyone other thin Aveahim had been in charge, 1 ihink the wal might heve uncaveled. The fact that it dido't was mostly duc 10 of the eros he created, the feeling that we were a special breed with a cricically important common puspose, and that sooner or later we would be called un to do special things. When we were in uniform, it was camouflage dress. When we were on the base, we mostly ware sandals and shorts, We called each other by our first names. even the officers. Init frst Few years, the sayeret sometimes fel loss like en amy unit than a college fraternity. Every spring. we organized a feast in a cavernous hangar on the edge of aur compound. It was called Chug ha Pri. the Feast of the Fruit. For days shead of the event, we would mount night raids on kibbutzim, “liberating” erates of every kind of ruil imaginable, and chicken and lamb if we got lucky The only rule was that none of us would steal from our own kibbutzin,. Among the wets al the Fest of the Frail was an unsuspecting selection of senior alficers whom Aveaham know. A few of them got into the spiciL, like Dado Elazar, his Palmach commander fiom 1948. The Palmach had held similar foodfests, wilh delicacies urabbed from nearby kibbutm. Dado wis by this time commander of [sachs armored corps. Since dur sayeret was always short of gasoline for our exercises, he would divert surplus supplies to us. But other guests were less impressed with the pyramids of oranges and avocados and mangos and watermelons. 1 could almost hear a voice sexcaming inside them: these are Isracli soldiers. They're stealing this stuff. "A It was not until the autumn of 1961, nearly eighteen months after [ arrived. hit if seemed we might actually be given a real mission. This was higely due toa change at the top of the military. For much of the 1950s, when Dayan was chief-of:staf, his ripht-hand-man was a [laganah veteran named Meir Amit, In 1961, the term of Dayan's successor as chief of staff, Haim Laskov, was coming tan end and Amit was in the mix lo get the top job. Le wes already [lead of Operations. Tn practical terms. that made him the number-two man in the armed frees. Bul the job went 10 Tavi Tar, Luskoy’s deputy, Ami decided to aceep! 62 the post of Tlead of Military Intelligence. Tie knew the importance of intelligence, and the potential cost of Israel being taken by surprise in a future war, biving been part of the top military leadership during Rotem. He was energetic, bright, and exuded am infections sense of self-confidence and authority. le also had clout at headquarters. If he decided the Lime had come tw revive cross-border intelligence operations. there was every chance it would lappen Still, it was an agonizingly slow process. By the lime my period of military service was drawing: to an end, it hadn't happened. I did not seriusly think of leaving, Though my twa years in Sayeret Matkal had been the most physically demanding of my lif, they were also the most ful illing. 1 dic not want io forfeit the chance of being part of its finally becoming an operational unit. So T committed to it least a few mare years in the military. | joined my closest friend among the recruits, Uri Zakey, for six months in officers” school as we waited, ar hoped, for approval to zetually use the skills and qualities we had acquired in the saveret. And in the summer of 1962, shortly afler 1 retumed to the unit from offices school as a sceoud-licutenant, the green light finally came: 63 Chapter Foue AufisL, it was only “approval in principle. Is impossible to overstate the trepidation with which [srael’s military brass, and Ben-Gurion himself, approched the decision Finally 10 send Sayerel Markal int achion. 1 ws not just the Fact that we were a unit uiterly untested in the field. The stakes in the mission we were contemplating were enormous. Tor the first time since Uri Ty's deseperalc wet of suicide in a Damasens fail eell, Israch soldiers wonkd be crossing into Arab territory on an intelligence mission. Amid continuing tensions with the increasingly militant rulers of Egypt and Syria, there seemed little doubt that at some stage we would again have to fight to defend our sceurity, perhaps even our existence us & state. The Rotem debacle had highlighted the danger of a surprise attack, potentially leaving us in a scramble to call up reserve units as Syrian or Egyptian tanks advanced on our borders. Bul the memory of Uri llan remind 1 haunting veminder of the risks of failure. My tole, again, came down pacily to accident. The man initially chosen to lead the operation was someone ['d liked from my first days in the sayeret Yw'ukov Tal, known us Tubul, was # year older than me. He carne from Uiberias io the orth of [sracl. As a teenager, he'd worked for extra pocket money alongside shepherds in the hills above the Sea of Galilee, picking up a near- ent command of Arabic. He wis self-confident without a face of arrogance, with a natural talent for counceting with his soldiers. Tn my cose, tere was a further bond: a shared fascination with math and sciences. But Tubul had applied to the leading, technology institute in sracl, the Techion near Huila. As he began training his four-man team to cross onlo Sycia’s Golan Tleights, he received wood that he'd been accepted. The academic ear wouldn't begin until September, and it had been assumed at first that the aperation world happen before then. But even though Mer Amit wis pressing the rest of the military brass foc 2 final go-ahead. it still hadn't arrived by early August. Avraham decided he needed a fall-back plan. Ile called Tubul and me into his office. He sid be waned me to join the lcam’s tram as Tabul’s deputy, and Lo be ready to step in as commande if that proved necessary. When we next heard from Amit, a week later. it became clear the mission would not ‘happen in time for Tubul to lead it. We would be siting out from the northeast comer uf tsrac, @ patch of parkland near a kibbutz called Dan. only a mile or so trom where Uri llan’s group liad begun its mission. This tine, however, the target wis more 64 ambitious. We intended 1 bug the communications line cunning east from Banias, the Syrians” base in the nob of the Golan, toward Quaeitea, their main headquarters, That meant taking a langer route, beginning with @ climb onto a phatcan shout 200 feet high und crossing the Banas River foward the Syn base. We had nearly three weeks for our final preparations. After two years of sayeret teainmg, 1 was confident that, physically, we would be up to the task. Bul even wilhou te obvious jitters emanating from the kirva, | could nol help but be aware of the possibility, and the cost, of failure. Every evening, [ would stake out time to wo through everything that might concenvably wo wrong, Yeurs ater, when | went to do my graduste studies at Stanford, | wis exposed 10 words of wisdom Irom a non-kibbutznik — Benjamin Franklin — which probably ‘best summed up what drove my planning for the sayeret’s first operation, and the others that would follow. “Tailiog to prepare.” be wrote, “is to preparing foc failure.” Running into Syrian soldiers was, of course, top of the list of potenial pitfalls. Bul and mines were also u danger. 1 got a map of the arca from mibtary intelligence which, in theory at least, showed the location of mines all along the edge of the Golan. But it had been compiled over a period of nearly two decades on the buss of mformation from shepherds, smugglers and the occasional Arab aaenl. Whenever they reported seeing the telliale combination of feneing and yellow danger triangles, the place was marked. Once it was marked, no one in intelligence headquarters dared erase it. The result was that the map now showed an almost wbroken sireich of mines. And within the amount of time that we had to gel ready. there was no way of knowing which of the minefields was still there. The timmyg was chosen by the eyele of the noon, We wanted lo cross to Syria in as near 10 total darkness as possible. That meant the final days of September, Unlike Tubul, who had been commanding the team from the moment they bid joined the sayeret, 1°d been working with them for only couple of months. My deputy for the operation, Avi Telem, was also a newcomer. But ie was smart. steady and he had served in the Golani Brigade, $0 hie knew the tervam wong the border. Avuahuarn couled not hide his own nervousness as the apertion drow nerer. A week before we were due to set off, he asked whether we were planning a further, full-scale exreise. When | suid he tal na-through was sci. Gov the following night. in the Negev, he wld me he wanted Meir Uar-Zion Ww attend. 65 During the exercise, Meir said nothing at all. 1 couldn’ help wondering whether, despite our nearly daily exercises, and my nightly stock-taking, I'd somehow missed an obvious defail in our planning, When we got back fo the sayeret bisse, Avraham was waning for us. “Well?” he asked Meir, “1 hey don’t need me.” he said. “They know what they te doing.” [L was not just a source of reassurance for me, but a luge relief for Avrahara. The team I'd mherited from Tubul included three fled soldiers with different backgrounds, and difftreut skills. Molti Nagar was born in Cairo. He was short but solidly built. smart, level-headed and almost always smiling. Kuti Shara grew up ina Yemen family in an impoverished neighborhood in Tel Aviv. He liad a self-deprecating sense of humor, a quick mind and sometimes even quicker tongue, bul an extraordinary ability to focus oa the task at hand. The third member was a kibbutznik, His name was Moshe Flimelech, We called him Moshiko. Utterly self-contained. a man who spoke anly when absolutely necessary, he lso brought two different qualities to the mission. One was going tobe indispensable: an almost squirtel-like ability to climb trees. Or telephone poles. The other, of which [was i bil more leery, was a total, deeply imsional, abscace of fear Though none of us needed a further reminder of the weight being attached to our mission, the night before we headed north, Avraham got a call from the chief-ul- stalls ullice. Tevi Tour wanted 10 see me the next morming for personal briefing. T tried 10 get Avraham 10 say no. pointed out that if we didn’t get going by ten o'clock at the fates, we'd risk thrawny everything off schedule. Bul “no” was not an option. Afr some farther back-md-Rorth, il wis agreed that T would meet the commander of Tssael's armed occes at nine the next morning ar a gas station north of Tel Aviv and join him for the 20-minute drive along: the constal rond 10 1 speaking engl be had in Netanya 1 saw Avraham again before 1 set ofl, “We are beginning au extremely critical 24 hours for our unit, the intelli rence comps, in fact for the armed forces as a whole,” he told me. “1 don’t know what might happen, No one does, Jus! semernber two things. First, out there, in the field. vou are the ramatkal the chief of sta. TTe told me that only T and my ean: could judge and respond to what we encountered once the operation started, “And second, this mission hax in be accomplished.” Tel see the seal ramatkael. Before we began the drive to Netanya, he asked me fo unfold the mip 1d brought with me amd talk bin through, siep by sip, hove we planned to get onto the Golan, plant the bugging device, and got back 66 again. The more T talked, however, the move [sensed that the details weren't what General Teur really wanted wo know. [ think what he actually wanted to gauge was whether / felt confident. He wanted to reassure himself he wasn’t Tuking amy more Than he obvious risks in sending us, in Uri Tan's Goorsteps, back inwo Syria. loctunately, he didn’Lask whether | was suce we'd succeed. If he had, 1 would have said, yes, we were prepared. But there was no way we could be certain. Still, he must have got what he wanted. When we reached the edge of Netanya, be shook my hand, wished me luck and went on bis way The rest of the team was wailing at the crosscoads for me to join them. Two teams, m fact; mine, with whom 1d be crass inta Syma in less than 10 hours time, and or billatz, or back-up. A hillutz wis always a part of sayeret operations. The back-up group would stay on the Israeli side of the border. If we ot into rouble, they'd come in after us. Fven after my bricfing for the chic of staf, we had ane last stop lo make on the way noril. IL was al the headquarters of the army's northern command. It was in a Tegart fortress. one of dozens built by the British around the country, with watehtowers on cach corner of the outer walls. The northern commimder was an equally forbidding figure. Aveaban YofTe had served in the British artillery in the Second World War and the Golani Brigade in 1948. He used to joke with other officers that while they looked like a bunch of kids, he was the anly ane with the rue hearing of 2 general Tle must have been busy when we arrived, because we ended up hanging around in the courtyard for nearly 20 minutes, Just as | was beginning tw worry thet the timetable for what really mattered — our climb up onto he Golan — was being put at risk, I noticed that off to the side was a beautifully polished jeep. [ assumed it belonged to General Yofte, who was known to be an avid amter and would later become Ure head of Ismel's National Parks Amthority. 11 bad a padlocked metal grill on the back which held wo jerrycans of gasoline. Yori Cohen, the commander of the back-up team, and 1 spotted the fuel containers at fhe same time. We couldn't help smiling, Yes, we were about to embark on an poration which, assuming we didn't fail, would finally give Isracl real-time incelligence from across our border for the first time since the 1950s. But we were still Suyeret Matkal, snll chromeally short of gasalme for our field exercises. And | still hadu’t forgotten how fo pick a lock. As Yori stood guard, | broke into the grill and removed the jerrycans, one for each of us, and closed it again, Then, after briefing the general, we headed to our setfing-off point, Yofte himself left 10 join Avraham Aman and Meir Amit's intelligence deputy, 67 Alaleh Yaciv, in the command post for due mission, atop a bill on the Tscacli side of the northern border. The sun set at around seven, but we waited tor darkness. It was nearly eight when we sel ont, Twenly nannies later, we crossed the border. | led the way, with Moti Nagar, Moshiko, Kuti Sharabi and, finally, Avi Telem behind. We carried the bugging equipment and our tools in our backpacks. Avi and 1'had a pair of binoculars, Mine were bulkier, but offered a shihtly better view i the durkuress. Each of us had an Uzi and a pair of grenades. All our planning hud been aimed at petting on to the Golan, installing the bug and getting out again. If all went well, no one wauld even know we'd been there, Rut we had practiced what 10 do if things went wrong. [challenged or ambushed by i Syrian patrol we would operate by old Company A rules. We would open (ire The climb anto the plateau wasn't too wih, not nearly as hard as our sayeret fathimg treks, When we reached fhe op, there was no obvious sign of any Syrians. Still, we had lo move slowly. Liven with my binoculars, 1 could sce ‘barely 30 yards into the moonless night, and 1 had to scan the route ahead, back and forth, to make sire there were none of the fences or wiming sigs o keep the Syrians’ own suldicts, or unsuspecting shepherds. from a minefield. Soon, however, we found an obviously well-used footpath which 1 figured was very likely to be safe. When we had walked a few mines, we found ousselves going through a tangle of bushes and reeds, some of them up to two feet high, still dry and eruckly from the summer, Aside trom the riskc of tripping, [ knew the naise we were making might aire atiention. 1 old the rest of the team to hung back 20 yards behind me. I moved forward to make sure the route was clear before signaling them to follow. | had been slightly nervous on the clint up. not so muh because | expected ronble bil because there wits no way of knowing what 1 expect. Much as | tried 10 put the concerns of the geaerals from my mind, 1 also knew that this was no ordinary mission, But almost immediately, fhe nerves had gone, and [was now focused only an gelling ns through the next minute, the next 20 or 30 yards of the Golan. Bu as soon as we'd made it accoss the plateau. we ran into trouble. We needed fo crass the Banias River, On our map, I'd picked aut what looked fo be w shallow ford. Bul the water was much higher thin we expected. After spending 30 minutes scouting the bank for 150 yards in either direction. we sctlled om whit seemed 10 be the stisllowest pan. Yet we hadn't svnepied the need ww cross a river in full flow. Worse, we'd never tained to do it. Not had we 68 brought any special equipment. Unless we eould figure out a way 10 000ss — and quickly — we would be putting the timetable for the whole operation at risk. The only remotely useful tool 1 could find was two 25-foot lengths of prrchule wire, We spliced them Together. 1 took the lead end and wadsd in. { sunk up 10 above my chest, but managed to pet across. With Avi ‘Telem vn the other bank holding his end of the wire. the others used it to help them cross. so they stayed a bit drier. They also kept the micreept equipment dry, Finally, Avi followed. But both be and 1 were now souking wel. We were also behind schedule. We had covered less than half of the three-mile route to the telephone pole, Even if we did manage to install the bugging device, the delay meant we sight be spoticd on our way back To Ismael, We were under strict orders 1o um back by 1:1 in the morning even if that meant not getting the intercept in place And it was already past midnight, We begin elmbing into the hea of the Heights, plaming to go sound the southern edge of the Syrian base at Banias. The vegetation was sparser but vee still ran the risk of making noise from the stones and larger shards of rock as we weaved our way up. Within 10 minutes, {contd see the vague outhne of the army camp: several lacge buildings for several hundred Sytian troops, singed by trenches with security outposts and a barbed-wire fence on the perimeter. Far u half-hour or so, we moved forward in a kind of rubber-hand formation, {would advirnee ws quicily as | could, listen or signs of Syrian troops, sen the area ahead with my binoculars and wave the others to follow. But as [ prepared to move forward again, | suddenly felt a tug on my shoulder, 1t was Moshiko, and the very fact of his speaking was prooC of his alarm, “Ehud, "we've gol to go faster.” he said. “We won't get there in time." I said [ understood. But I told him to wait for the athers to catch up and stay behind with them as 1 scouted the way ahead. SHI by the tine the outer fence of the base came io view, the others had picked up theic pace. They were only 15 fect behind me. It was then 1 heard the sound of movement. I motioned the others down. Ac first, 1 thanght it was a wild animal. But then | noticed. 20 feet in front of us and a bit of our right on a slight rise. a group of three Syrian soldiers. They were Iying on rocky scrubland 40 yards outside the fence. One was tossing and fuming, Another wats snoring, | maneuvered my Uzi info firm position just in case. We wailed for a minute. Then wo. But it seemed clear they really were sleeping. 69 Then, from directly behind me, came another sound: the hiss of Avi’s bulky two-way radio. T was worried we'd end up waking the Syrians. But just as T wes figuring aut how to make sure we got past them before that happened, Avi drew up beside me. “Lhud,” he whispered. “11s 1:15. The command post ordered us w tun back.” “Turn off the radia.” | said, my hand on his elbow, reassuringly | hoped, as led him and the others back a full 100 feet from the Syrians. We ook a wider toute around the camp. We moved much more quickly on the final mile to the road that led toward Quneifea, We were now well clear of the camp, and [ felt it ws unlilcely wed rin nto a patrol. 1 wis also confident we'd hive un casicr rerurn trip. Tknew what had held us up on the way in: finding a path on the plateau clear of mines, figuring out how to crass the river, and the general wnfamifiarity of the terran. Nove of those apphed now. [fell we could gel the bugging job doe and still be beck befine dawn. As we gol carer the road, Avi asked me a couple of more times whether he should turn the radio back on. “No.” 1kept telling hm. “17s OK. Ul iefl yon when” 1 was thon two in the moming when we reached the road. We found i telephone pole set back on the edge of a field. Moshiko hoisted himself onto Kuti Shurabi’s shoulders, clambered up the pole and installed the bugging device. The entire opertion ook him less than 10 minaies. We moved nore quickly on the way back. By around 3:30, we had crossed the river. “You can tum on the radia now,” [told Avi, who was obviously relieved. He handed if to ne. Using our agreed code wouds, reported our loeation, and added the prise: for “mission accomplished.” When we began our final descent, it was starting: to get light, [ assumed we were ner enough to the border to make it inlikely we'd be shotat, Still, there was a danger we'd be spotted by a pateol, so T was relieved when we reached the mound of boulders, more than ten feet high. that served as a taal barrier outside Kibbutz Dan, When we stepped behind it, {sinw that nof anly Aveahm, but Meir Amit as well. were waiting. The Ulead of Military Intelligence said nothing, He didn’t have to. Ie just shook my hand, beaming. Avraham grabbed each of us, one by ane, in a bear hug, Then, drawing me aside, Avntham sawd tht 1 had only mnrowly missed landing in deep rouble. T assumed my transgression was shutting off the radio and disobeying the order fo retim. That was jist part of the problem, however. 70 Despite Genceal Yolle’s angry protests in the command post, Avraham had wold him what he'd told me back at the base: that once an upesation like this was underway, only the commander on the spot could make life-or-death decisions. Uw “the ramatkal in the Geld” But YorRe bud also discovered thi his jertyeans uf gasoline were missing. Tle insisted that if and when | returned safely from the Golan, I be handed over to the military police. 1 don’t know what | would hive told the general if he'd asked me dircetly whether 1 broke into his jecp. But in the mix of celebration and relief tat the Syrian operation had succeeded, 1 got away with what amounted to a plea- bargin, | promised bath Mer Amit and Avrabum at least one of whom helioved me = that i would not happen again 71 Chapter Five Almost no one in Israel knew what we had done. But the next morning, a package arrived at the Sayeret Matkal base fiom ane of the few people who did We opened it in Avraham’ office. 1 was u neark full carton of champagne: seal. Trench champagne, since it would be years before Tsracl’s embeyonio wine industry produced anything similar. Inside was a note from the chief of Staff. “For the success of the operation,” General Tzu had written. “Minus two bottles... 0 teach Ehud Brog not to shut off his field radio.” T assumed that his reprimand was tongue-in-cheek. for the same reason ['d escaped being locked up on General Yoffe's orders as a gasoline thief. Had we been captured on the Gola, the very future of Ue seyeret as an operational intelligence unit would have been put ac risk. Tzur, and Ben-Gurion as well. would ave faced a reopening of all the old wounds from the Uri Ilan mission. Bul not only had we managed to get in and onl of Syria iv one picee. We had taken at least a first step toward erasing the blind spot in our incellipeace capabilities shown up so dramatically by Rotem. A few days later, {received a letter fram the chief of staff informmy me that [was ta receive my first zafaxh, or operational decoratioa, in recognition of “a mission which contributed to the security of the state of Israel.” My own feelings were more mixed. [ was proud of what 1. and my team, had accomplished. On a personal level, too, [ felt 1d reached an important landmark on my ualikely journey from the winter mocning when I'd arrived as physically fail, awkward kibbutz teenager at APC boot camp in the Negev; through my years of sayeret training under the strict, sometimes sardonic, but always supportive gaze of Tscael's most storied commandos; to, now. having begun to make a real contribution to Avrabam’s vision of a new kind of Istaeli military unit, But while Avram, General Tzur und our other military and mtelhizenee chiefs celebrated our mission, T felt not so much triumph as relief. T didn’t kid myself: 1 knew that the operation could just as easily have pone wrong. In fact, it very nearly did, through ercars or omissions | had made. | made that point, in general lems, when we joined Avraham and the rest of the sayeret in a formal debriefing. Buc that very nigh, just as 1 had in the days before we set off. I wrote down in detail some of the oversights 1 knew 1'd have to correct if we were lo sneeced mld her nissions. Why hadn't] chosen a route that took us further away from the Syrian base at Buns How hid 1 let us arrive so unprepared. inirined and uncquipped for 72 crossing the swollen civer? Why bado’t [taken the time tw cheek the current several miles downsivec inside Israel? And couldn’t we have moved more quickly an the way in, even with the delay in crossing the river? | ws aware of, und grateful for, the confidence Avraham had shown m me. Ue bad taken a chance in choosing me lo lead the sayeret's first, critical operation. He must surely have had doubts about whether 1 could handle the task. Years later, 1 asked him abont it. He told me that he'd been relying on inition. Yes, he tealized I'd had no experience of a real cross-border mission. But that was true of everyone else in the unit as well. He was convinced that the tools needed for success were self-confidence, attention fo detail and an ability ta think and act in response to whist happend on the ground — all qualities which he was confident that T possessed. Now that we hud provided Israel access ta communications in the north of the Golam, there was a demand for us 10 do the sme m other parts of The Ucights. 1 was involved in nearly all of the missions we were asked undertake in the months that followed, either as commander of the main force or the hill, | was also soon training a new eam of weenats for fre operations. But perhaps tie most important sign of Aviahan’s conlidence was to involve me in early efforts ta broaden Sayeret Matkal's experience and reach beyond pure intelhgenee missions ta create a trie speciul forees unit that could fight as well. Tauly in 1963, we hosted a visit to the unit by Colonel Alben Merglen, a veterun of France's colonial wars in Indaching and Algeria, und commander of the mrhorne conmundo force known as the 11" Demi-hrigude Parchatisies de Choe. As the colonel looked on, I led a sayeret team on a live-fire raid in a training area not far from [od Aimart, We attacked a position protected by frenehes und conerele binriers and stonmed a two-story build, Eager 10 impress Mergelen, Aveaham even insisted on our wearing Ureuch-style berets in pluce of helmets. 1 assume it was the attack more than the berets that did the trick, But a couple of months later, Merglen proposed a series of exchanges, The first would involve an officer from Sayerel Matkal officer spending cight weeks on a counter-guerrilla commanders” course in the parachutistes” training headquarters, Avuahuann picked ic 10 go. The French base was in | Tih-centuy fortress near Mont Lois. in the Pyrenees along the Spanish border. I'd never been outside Isc, ut least legally. 1 had no passpon. 1 didn’t own a sil or ne. Bug within days. I wes kitted and fitted. boarded an Il Al fight to Paris and, on a 73 storm-tossed Caravelle, ew to Perpignan in southeastera Trance. There were eighteen “shock parachutists” on the course. Thad just wrned twenty-one. Not only were most of them ar least a decade older. They were the epitome of Touglmess. The guy who langhi us how w set booby-faps hd parched behind Geman lines in the Second World War. All of the men bad fought in Indochina and Algeria. One had operated behind Vietminh lines, surviving for a year-and-a-hall vn nuts, berries, ree bark and snakes. With the benefit of my sayeret aining. | was at least theic qual in fitness. 1 had also not spent years consuming; prodigious amounts of alcohol and smoking Giranes, But I'd never experienced anything nearly as demanding: as some of the training we were put though, With backpacks crammed with Alpine militery gear and lead weights as well, we hiked on to the peaks overlooking the fartress, They were covered with snow and iee from about 6,500 feet upward. We wudged for hours, shifting 10 snowshoes with cleats for the ice. We were Laught how to dig caves in the snow and to use ice axes ta keep from tumbling down the steeper inclines. We scaled CIT Tacs, without safely eubles ores. Our Ingining inside the fortress always included a break for lunch. Sinee the pacachiutistes de choe were, after all, French, it was a Paris-restaurant-standard meal with copious quantities of wine. [dida’t drmk al the time, but could hivdly abstain allogether. The first exercise after lunch was pistol markseanship. The instructors kept well clear when it was Duy turn. Yet however impressed, even at times awestruck, I was by the toughness of ihe French commandos, sud the obvious closeness they had bill during combat, [ began to sense a darker side in them as well. They did't talk much. Even if they had, my few words of French would not have been much help in deciphering what made them tick. But every few nights, | would aceomypny them when they walked into the small village down the road for a movie, ora few drinks. and the locals would Literally cross the street to aveid us. Later. [ discovered thal every one of my French comnades Bud been mvolved in the OAS. the far-right anti-De Gaulle opposition in the French army in the late 1950s. In Algeria. they had mounted free-lance attacks on the insurgents, and on civilians as well. Though Algeria had been granted independence the year before, these men were unreconciled Ww iL. In fact, & few months afier my lime in Mont Louis, the Demi-brigade was dismantled, when several of ics op officers were found ro be involved in an assassination plot against President De Gaulle, 74 Aller my retuen in June 1963, Aveaham asked me to share my experiences with the other sayeret officess. [ began with the positives. T singled out the sense of self-confidence, allied with individual strength and teamwork, that the French compimdos hid developed from expose io almost meredible exireres of danger. I believed that their success depended not ou climinating risk. We all knew that was impossible. It was about professionalism developed over a period af years by mea who bad served wgether in the toughest of circumstances. But | also mentioned their dacker side, which seemed w me a reminder of the danger of the misapplication of the very qualities which made them a formidable military torce. “The ethos of a unit like theirs, and like ours, is essential to making us strong.” | said. “But what | saw in liauce was an entice ceosysiem that these guys had created, extremely patriotic in their own minds, reinforced by one another. But dangerous for society as a whole.” ew Tt would be nearly a decade betare Saveret Matkal became not just a military intelligence unit, but a fighting force, and [ would un oul to have a central role in making that happen. But there was an almost equally daunting challenge we were called on to lack first a exilical one, i€ Ismael was going 10 be truly prepared in the case of a further war. Tor while our bugging missions on the Golan had reduced our vulnerability to a surprise attack in the north, the real challenge of Rotem had yet to be addressed. It was Fypt with its hundreds of battle tanks, and hundieds of thousands of men under arms — Lhat was by far our most powerful Arab enemy. President Nasser wasted no opportunity to flaunt his determination to fight, defeat and ultimately erase the state of Israel. But we still had no rehable, real-time mtellgence on his forces. Tixing that. if such an operation was even possible, would make oue bugging operations on the Golan look like mere boy-scout missions. We could not simply walk into Egypt with ous backpacks, fia a telephone pole on one of the few roads crossing the vast expanse of desert, and attach a bugging device. The idea was to tap into the main military communications cable in the Sinai. That meant using a vastly more powerful, and far bulkier, intercept apparatus, weighing more than halla ton. Lven getting it into Lgypt would be a problem We certainly couldi’t carry it our backpacks, of tow it across the sand. Tven if we Figured a way fo get it there, we wonld still have 1o duz up the Eizypuan 75 cable, install the machinery. cover our tracks and get back into Israel again undetected. Tven if we managed w avoid getting captured, without completely camoufluging what we'd dane, the Egyptians would discover what we had done, almos! certainly tipping off Syria as well To our bugging operations on the Golan Ileights. The difficulties with a Sinai operation weren't just theoretical. Almost a year before leading the first mission an the Golan, I'd actually been myolved in preliminary planning, and fairly detailed traiving., for such mission in the Sinai. We'd ended up abandoning the idea as obviously unworkable. But Meir Amit, not just our unit's overall commander in the kirve but Chief of Operations dum Role, recoumized thal geting inlelligence sceess lo Teypt was central to Israeli security. Tle was intent on reviving the plan to tap into Nasser's communications in the Sinai. So was Avraham Aman, He enlisted the haeking of an old friend, Un Yarom, whe wis now commander of the Ismael Air Voree and was cager 10 put ow (eet of recently acquired Sikorsky §-58 helicopters to operational use. When Avraham called me in to tell me what he ach mind, he begin by saying it wonld be “by fir the grestest challenge we've contemplated” — Lypically disarming candor, but also a challenge which I'm pretty sure he knew would only increase my determination to at least try. The flight in wonld be difficult enough, Ise! hud never before tried such 1 Teliborne mission. But he told me that wasn't my problem. “1 hat will be Uri's job.” The really testing part would be to carry out an mission, at night, deep inside Egypt, cover our tracks and get out agam in one piece, “Stull, ('m sure that we can suceced,” he said. “And | want you and your team tw do it” Liven now. move thao hall-a-century later, sone of the details of how we planned ta tap inta the Egyptians” communications remain classified. But once 1d chosen my team of sere! soldiers for The mission, we tnsined For arly nine months. We drafied in ecologists to identify arcas of the Negev similar to the terrain we’d tind in the Sinai. We developed a series of methods to prevent Firyptian soldiers or scouts From discovering lhl we'd been there assuming, of course, we managed 10 get in, attach the interecpt, and return safely. [Lwasa relentless process of tial... and error. One of the many reasons we'd abandoned the plan a couple of years earlier wass thal, in a nighttime exercise 10 see whether we could avoid detection by Israel's own crack desert scouts, we'd failed utterly. Now, after many weeks of teaming in the Negev, we diel, Ginlly, succeed — in a fest numiing for four 7% straight nights which replicated. as nearly as we could, what we intended to do across the border in the Sinai. 1 was as if we'd never been there at all Yet there were the errors, setbacks and frustrations as well. Many months into our planmng, we condueted # series of run-thronghs in which we simulated attaching the intercept to [sracl’s telephone network in the south, nol far from the camp where ["d done my riroawz. Though it all seemed to go as planned, the next moming in rained heavily, Within hours, the phone company was wetting sepocts (vom all around southern Israel of phones malfunctioning. Even allowing for the fact it rained less in the Sinai. we had to address the risk. [ went to see the people in Meir Amit’s technology unit, and they began developmyz a waterproofing sysiem (ov the equipment The main peoblent with the equipment, however, was its sheer weight. The helicopter could get us, und it, into Firypt, But we couldnt fly directly to the cable site i the Sma. We mht just as well fell the Egyplisns we were on ou way. At around 1,100 pounds. it was much too heavy for us carry. And if we were groin to to ahead with the mission, time was running shart, A date for the operation had been set by the irya: February 1964. 1 was not alone in beficving that, unless we eracked the problem of getting the equipment o the cable site, the operation was impossible, The solution came from a staff officer in military intelligence. Meir Amit visited our base once a month o he how the propurations were woing. With the date getting closer, he broughe along his entire staff. When I raised my concein about the weight problem, a colonel fram his personnel section said; “Why not build a lightweight rickshaw, small enough lo get in the door of the helicopter, but which can carry all or most of the equipment once you're on the ground?” Within days, they had a prototype, made of airline-standard tubing and designed 10 be pulled hy two men. We held an exercise in the Negev. But il was almost impossible foc Lwo men to pull through the sand. lL also lef deep zig-zag imprints in the sand, which would surely raise the suspicions of the Fyyptians. But prototype number-two wis « four-wheel, chrome alloy cart, The technology experts had made the axles telescopic, so the vehicle would get through the door of the chopper but could be expanded to the width of an Fuyptian army Jeep. They had borrowed nose wheels from a training jet. To complete their oeuvre, they ghied on veal fire ircd from one of the uyptian Jeeps we had captured in the 1956 war. 77 We were as ready as we were ever going Lo be. We got the final go-ahead from in mid-February. Our backpacks were crammed full with the whole array of equipment we'd designed, commandeered or purchused for the mission including mtal detector we gol from i hobby shop in Pemsylvani. All he cargo except our personal pear, out weapons and vue commuications equipment was loaded onto the cart. A comand post was set up in a few wooden buts ua Mount Keren in the Negev, complete with special antennas to receive the intercept transmissions if we succeeded. Not since the fiat Golan operation had the attention of the ky: been sa keen. or the stalkes so high, In addition to Meir Amit, and of course Avraham, also flying down to Mount Keron would be General Tus successor as armed forces chief of stall — a gruff Palmach veteran whom I'd met very briefly at the end of my officer's course but wha T would come to know well. and work closely with, in the years head: Yitzek Rubin. PE The helicopter lifted oat ahout six-thirty at night. Compared to special operations nowadays, the mission sill had a somewhat improvised feel about it. Certainly, tht wars tre of the equipment we were ferrying in. and the tools we'd devised Lo make sure we could get it installed and working. But the men in my team were soldiers I'd trained from the day they arrived in the sayeret, Achihud Madar was unfailingly surefooted, whether finding his way alone at night on unfamiliar ground or in a firefight inside & building. Uc also had natural dexterity. Tle and another of the soldiers who was also gifted with his hands, Nissim Jou'ari, would be performing, the most technically delicate part of the operation on the cable, The third member wis Oded Rabinovitch. Vall, thin and quiet, he was absolutely reliable in whatever part of an operation he was. given to execute. And as my deputy commander, I'd chosen a sayeret officer named Kobi Meran, who'd been with me on a number of Golan missions, Over six feet tall, he was probably the strongest man in the unit. quick-thinking and utcerly undlappable ‘When we landed, we telescoped out the axles on the cart, The roar of the departing chopper was replaced by silence. Under the soll light of hundreds of stars, 1 led the way deeper into the desert. It took nearly an hour to reach the saad lead to the cable site. Though maffie was light, {posted Oded and 78 Nissim as lookouts. Kobi and T began digging a trench. The Lop layee of sand was easy to remove. But then, just a few inches down, our shovels struck something hard, Maybe it was a sheet of rock, Maybe sand packed fight over the willeimia. Bul 1 wesisied all our steno break nongh. We had 10 find a way lo get far enough beneath the surface ww install the equipment. [ called back Oded and Nissim trom lookout duty. All four of us attacked the subsoil with every toof in aur backpicks that could conceivably help. 1 taok nealy three hours in all, Bu we finally managed 1o carve oul a trench that seemed as if it might just do the job. It wasn't as deep or as wide as we'd planed. But we were approaching a point where we would have fo give wp. We couldu’L isk any more time digging, snd sill leave time 10 uitach the ntereept unit, cover our tracks and make the rendezvous with the helicopter to take us back into Israel. Achibud and Nissim cramped themselves mio the hole and got lo work. like Surgeons i an operating theater, silent except for the Caint hum of the intercept equipment. Within a little less than an hour, they'd finished the main part of the work, During our feaming exereises, we'd factored in a fill-back plan, is way of ensuring we got the unit installed but without additional equipment 10 extend its battery life. Since we were still behind schedule, | was tempred to stop while we were ahead, But having come this far, and knowing the potential isles of a further mission 10 refresh the power unit and replace the batteries, 1 old then to Keep going, and also to fake the extra few minuies needed to make sure the equipment was fimctioning, We had 10 be ont of Egypt by first light, and we were now lel with more than an hour's less time than we had reckoned ou to make it back to the rendezvous point, There was anather problem, too, which [at first sensed mare thm sw. A bank of foge was closing in. [act come in patches at first, but was getting denser. We had the same radio we had taken on to the Golan. We'd worked out codewards for each part of the operation but otherwise agreed ta break silence anly iF ubsolitely necessary, Now, 1 hud no choice, 1f the fog continued to thicken, it would block any chanee of the helicopter getting in. | radioed the command post and said as calmly as I could: “The milk is coming.” Tt wasn't elegant, But “mlk” was our cadeword for fog, The chopper would now ry 0 bring us oul within 30 mines. Moving more quickly now that the cart was nearly empty, we made our way custwinrd. As conditions worsened, | radioed ugain wath w short senes of numbers: directions for a new pickup point. Even that seemed like it might aot 7 work. The fog now enveloped us completely. T brought ihe team to a sop. T stayed with the cart while the other four outlined a landing acea with kerossae flares in the hope that the pilot would see us, Tt was another five minutes when we heard the thump of chopper blades. Though we cones see more than i few Reet, I suddealy saw the outline of the landing gear and then the underbelly. Bul the helicopter did not seem in control. It was drifting towards where [ was standing with the eart. 1 was just seconds away from hitting me when its nose wrenched upward. It landed wilh a judder a dozen yards away. Later, | leacned the navigator had realized the craft was drifting and. just before impact, shouted awaming fo the pilot. We pied in, seeused the vart and took oft. Within minue, the murky blanket of fog was below us. As we swooped back into Tseael, T could see the first pink of sunrise. By the time we touched down at Tel Nof air force bse, southeast of Tel Aviv, the command post in the Negev was receiving the frst inteeepis A few days later. one of the sayeret soldiers gave me a first-hand insight into the mood in the commimd post in the final stages of the operation. Avsha Horas role had been to act as sceurity guard for the lop brass in Mount Keren. He occasionally took a peek inside. He described to me the atmosphere when 1 radioed my “milk is coming” message: solemn faces, hushed conversations between Avradiam ud Meir Amit. And oft1o the side, the recently elevated chief-of-staff. Rabin, chain-smoking and biting bis nails. Finally. the audible sighs of relief when the pilot radioed m with his final message from the chopper: “Out of the fog. Heading home.” With the rest of the team, | was invited 10 sce Yitzhak Rabin ten days later. We were being: given a further tzalash, This was the first time 1'd met him since leaving officers” school twa years carlicr, when, with u few terse words, the then-deputy chief of stall congratulated me aud several other cadets who graduated with top honors. Thad felt a bit overwhelmed in his presence. Now, 1 was struck by how shy he seemed. He greeted cach of us with a tentative Trandshake, und seemed uncomfortable in making eye contact. Ye once he began asking me abou the Sinai operation itsel. it was as if he was tanshrmed. He was hungry for every detail, anions lo know the way we'd had 80 to adapt on the around. And obviously pleased that we'd found a way to make the operation work The Sinai mission marked a transition not just for me, but for others in Sayeret Matkal as well, Aviaham Arman finally left the unit he'd imaged, created and buill. Le became the head of the teehuology unit in military intelligence. His deputy. Dovik Tamari, succeeded him, serving: the first in what would become two-year stints for eich of his successors as the sayeret’s commander. | wo. was given a wider role. Though [was still just @ young lieutenant, and too junior for the job. Dovik made me his de fucto deputy, with responsibility for operational oversight of our missians. | retumed to the Sin a year later, nol fu thal capacity but beesuse of my on-the-ground experience, Lo accompany a sayerel team which installed an intercept on a second Egyptian communications cable, Thongh the t7ahssh wis gratifying, what gave me more satisGaction, nd pride, was the importance of the Sinai operations themselves. | was confident that if we dif have to go to war again, the equipment we installed, alony with the bugs on the Galan, would give us wn essential edie. But in truth, 1 didn’t actually believe there would be another war. Sure, the tlieat was still there. Egypt. in particular. still seemed determined to find a way to hobble, and it possible eliminate, Israel, But especially since the 1956 war, the fedayeen witacks, and cross-bovder skimiishes, bad been subsiding. Not long afier the second Sinai intercept mission, T was chatting with other officers on ihe sayerel base and remember turning to one of them and saying | was sure tht by the tine | was married smd had 2 teenage ehild, we'd be able w take « skiing holiday in Lebanon. We didn't have peace yet. That might teke time. But T fell that things were getting more normal. 1 began thle what that would mean not just for Sayeret Matkal or Isuacl, but for my own future. By the autumn of 1964, I'd reached a decision: 1o end my active service in the unit that had been central to my lite since leaving the Kiblbutz, Dovile did persuade me to delay, for nearly a year. Bul at the end of the summer of 1965. 1 lef Sayeret Matkal. In fact, [left the anny eltogether. [weal fo study mathematics and physics at TTebrew University in Jerusalem. I would remain involved in the sayeret as a reservist, But | couldn’t see devoting my adult lite 10 military service in a country which, fisumately, seemed on a trajectory toward peace. T had spent five years in an extraordinaty unit. Tt had been more fascinatmg and fulfillmg than 1 could have dreamed of when I'd 81 (finished my tironut. Now I looked forward Lo pursuing a diffeccat path with equal eagerness and energy. There was also something else which colored my thinking, For the first time in my hfe, 1 had allen m love: 82 Chapter Six The French have an expression for love at first sight: coup de foudre. A thunderbolt. That was bow it felt when I'd sel eyes on mneieen-yeur-old Nili Sookin in mid-Uebruacy 1963. Tt was my first visit to the kirya in Tel Aviv. ['d been told to report to the administrative section, fo register my formal change of status from a mere draflee 10 a stall officer, something I'd managed w overlook amid the demands of our first sayeret operations on the Golan. Since I didn’t knew which office to wo fo, asked u girl site at a desk near the entrance. She looked up with a wide smile. When she directed me 10 the second floor, il wisn '| just her voice that swuek me: mulli-timbered, almost like a musical composition. TL was her eves. Bright, radiant, imeen, Full of playful, unapologetic self-confidence. In the weeks thal followed, [invented a series of exeuses lo ret to the Kitya. | introduced mysel Mo ber, with as much composure as | could muster, and on each further visit chatted to her a bit more. 1 told her about growing upin Mishima Hasharan. about math and music, sbout Israel, amd how, as a soldier in the past few years, I'd walked almost every inch of the land — in short, about everything except our still-secret sayeret and our nighttime forays across the border, She, too, opened up about her home and her family and her friends. Though there was another girl Ud been goiug oul with — the younger sister of my old kibbutz co-conspirator. Moshe — she was more a fiiend than a girlfriend. I'd never before felt anything Hie the comection [ sensed with Nii, nor anything like the race in my heartbeat ss | set oul 10 se her, I also found myself gripped by an unexpected, and wofamiliar, lack of self assurance. [ was now 23, three years older than Nili, | had the inbred confidence of a kibbuumik, Ue quiet sense of species which, at lest for unother dove ors0, would give the children of the kibbutzim a disproportionate place in Israels government and army, media and the arts. The same confidence which acl eonvineed mi as a raw reernil bisck m boot can that 1 could lead a supply convoy 10 the edge of the Sinai. Since then, Pd begun to make a mark in Sayer Matkal as well, leading its first clandestine operation and receiving a citation from the chicf-of-staff. Yet with Nili, | couldn’t help feeling unmoored, totally out of my depth. She was part of a different Isvacl. She was a 7el vivir, hom and raised in the largest and brashest city in our young state, a place which was everything the kibbutz was not. She ud graduated from Alliance. » high school 83 iin north Tel Aviv sel up with Trench backing and an accent on Trench language and eultuce. Unlike the gicls on the kibbutz — proud of their plain, utilitarian clothes and sensible shoes she wore make-up and perfume and, when she was ont of wi form, buight print dieses. She never nie io make me feel oul of place. Shill, it was sometimes hard not fo wonder whether she saw mie 2s a country bumipkin —a nice, interesting, bright county bumpkin, perhaps. but still an interloper or a curiosity in Tier would It wasn’t until April, the day before | was due lo leave for the French commando fortress in Mont Louis, that I plucked up the courage to ask her out. [ needn't have wormed, She smiled, In fet, she proposed that since | was about to leave the country, she should be the oue doing the asking. She invited me 10 diner thal evening at the apartment she shared with her paceats and younger sister, about a hal mile from the kine, 4 few blocks back from the Mediterranen, Dinner was less. awkward than 1 feared, but T still felt nervous, until the dishes were cleared and Nili and T went out to chat on the apadment balcony aad. just before I Tell, lo share a first kiss. We wrole cach other ahmost every diy while [was away in Frames. Once ( got back, we met whenever | wasa’l preparing for a sayerel operation. ‘This was the first girl 1'd known whom I could talk to. and listen to, on almost any subject with a feeling that it was nutural and somehow meant to be. But in the second halfol 1962, 1 was working almost non-stop on preparing for 3 sayerel operation. T still saw Nili when T could. sometimes at her apartment, but also occasionally going out to a movie, a meal ar a concert in Tel Aviv. Yet what | sos! wanted wis an acknowledgment that we were not just dating: 3 commitment that we intended the relationship 10 last. T didn’t say this to Nill. Years later, she would say this was down to pride. In fact, 1 was afraid she would sity no. And in the periods when we were apart, [couldn't help asking myself why she hadat caised the question of a deeper commitment. Tiven more frustrating, by the time I entered Tlebrew University in September 1965, onr relationship wis agam being conducted by mil. After her military service, she took a two-year posting al our coibassy iu Paris. [ could understand the attraction. not just because of her taste for all things French. She was working with the Mossad ta help Moroccan Jews skirt an official emigration ban and get fo Isracl. Still, it meant that charting our lure together, if we had one, was going 10 have to wait. 84 PE The intellectual experience at university everything 1 hoped. The challenge was finding a way to juggle my studies with my military reserve duty, In other units, most reservists could schedule their one month per year when classes weren't in session. To be of use to Sayeret Matkal, I'd have to report when [ was most needed, and four weeks was unlikely fo be enough. Near the end of my fist Lec, from late 1965 into the new year. [ was called to pasticipaie in vue latest mission into the Sinai. The next winter, and through early 1967, 1was called up for another mission and was away for nearly two manths. That operation was prompied by the fact the Fisyptiams had begim laying a new communications cable, parallel to the one where we'd put our intercepts. With the diggers petting closer to where 1'd led the first Sinai mission, the Kirvee was worried thal they might wiearth the sppratus we'd installed. In theory. at least, we'd planned for that. The bugging unit which we buried included a booby-trap explosive device. Still, nearly four years on, we couldn't be absolutely sure it would work. So The decision was laken lo send the suyerel back oa a fucther aight crossiog into the Sinai, defuse the explosives. aod bring the whole thing back to Israel. Since I was the one who'd installed it, T was given the job of removing it. 1 he officer in overall command of the mission was Necheniia Cohen. te was a good friend. and one of the finest officers in the unit. Before Tleft for university, I'd mentored him so that he could tale over my role as the effective number-two officer in the sayerel, in charge of ull our core operational activities. Tle, 100, was now aboul to leave, though not 10 for university. Tle was becoming depury commander of a paratroop company, under another former Suyeret Matkul, named Yeehiel Amsulem. 1 was meant 0 defuse the booby-teap remotely: with a 12-foot-long metal tool designed by the technology unit. Twas fairly confident I'd manage. But when Chicol: Stall Rabin heard about the operation, he simmoned me, wong with Eliezer Gon, the scientist working with us ou the phan to defuse the booby-iap. Rabin was with a half-dozen other officers when we arrived. Gonn haat brouzht along a mockeup of the explosive device, which he proceeded to place an Rabin’s office table. But as | wok out the extension tool and stared to explain how [ was going to defuse the device. Rabin tumed to Gona and asked: “Conld iL. blow tp spontincously?” 85 “Yes. iL could,” he said. “What?” Rabin barked. Conn replied marter-of-factly: “It is a physical device. [t obeys the laws of physics, When, for instance, there’s a thunderstorm in Turkey, a flash of lightning could discharge at precisely the frequency needed. or one of its lower harmonies. with enough energy to activate the fuse in the detonator.” 1 was far junior to everyone else in the room, But as a physics student, 1 was probably the valy one who could fully follow the argument he was making. Looking: at Rabin’s expression, it was clear that he was about to cancel the operation on the spot. “Excuse me, sir,” [ said. “Could I ask Doctor Gonn another question?” pointed al an unopened bolle of orange soda on Rabin’s desk. “Tell me.” T asked the physicist, “is it passible that the fluid in that horle is spontaneously lowing thromeh te wlass even as Pm speaking?” “Succ,” Gono said. “Iu might lake years before even a fraction of a centimeter of the soda goes missing. Bur glass is like a “frozen” liquid, and liquid water, or the molecules, are seeping info, and through, the more viscans “liquid” of the glass. U3 just physics.” Rabin looked at me, then at Gonn. Bur he had clearly pot the message. “The operation is confirmed,” he said, in the deen, gravelly voice | would become such nore Familiar with in the years uhead. “Good luck” The device didn’t explode. but I couldn't defuse ir either. I did manage to get the remote metal tool locked on the bolt on the booby trap. But it wouldn't budge — even when | waved back Nechamia and the others and tok oul au ordinary wrench. Though this was the first of my sayeret missions that ended in failure, that wasn’t what worried me as we boarded our helicopter back into Israel a couple of hours before dawn, 1t was the real possibility that the Eeyptians would inadvertently discover that we'd been intercepting their communications. Dovik Tamari. as sayeret commander, was especially upset. This was one of the last operations during his period in conmmand of the unit. He was about to hand over to a veteran paratroop officer, Uzi Yairi. Yet our aborted Sinai mission turned our not to mater. What saved our eavesdropping network was the very thing which 1 was confident would not happen when 1 left for university: another Arab-Israeli war. 86 CE Tension began building in the north in the spring of 1967, initially set off by Syrian efforts w divert water from the upper reaches of the Jordan River, an important water source for Israel was well. In a series of exchanges. Syrian oops on the Golan fired on Ismchi tractors in the demilitarized zone below, ind began shelling vue angiculiual settlements in the Galilee, while we responded with tank fire and then air power, scrambling our jets and shooting down six Syrian MiG-21s. The first indication that we might. be headed toward war came us [retuned to university for the spring term, and trouble began brewing in the south. Ben- Gurian had by now retired us prime minister, His successor wus the undeniably thoughtful, it fir less chirismatic, |ovi Eshkol. During lsnaels Independence Dey parade on May 15, he toceived word that Egypt had moved thousands of troops into the Sinai. nearer to the border with Israel. Then, with the Soviets warned Nise of what they said were Ismch plans for u preamplive sirike against Sytia, he went futher expelling the United Nations force put in place after the 1956 war. On May 23, he closed the Straits of Tiran, Israel's trading wleway 10 Ihe Red Se und the source of vivlnally all onr il fmpons. 1 was told 10 report 1 Sayeret Matkal the following day. as pant of the first aroup of reservists called up. When I reached the base, Uzi Yairi, who was now in charge of the unit, arganized us into four teams, He put me in commind of anc of them. We were told 10 propre ourselves Lo helicopter into the Sing, attack a series of Egyptian air bases and put the runways out of commission. My team’s target was the base at Gebel Libui, not far from where I'd placed, and secently Failed to defuse, our fins intelligence fntereepl. With cach passing day, war looked more likely, and there was no confidence we would win without a costly struggle. Tn 1948, Arab attacks had killed about 170 peapke in Tel Aviv. Now, word go out thal a park m fhe center of the cily Tiad been set aside wo allow for the burial of as many as 5,000. With Israel's ‘military commanders pressing Tshiol to take the initiative and launch a preemptive strike, he delivered a radio address at the end of May. intended to reassure the country the situation was under conwol. But duc w last-minute, handwritten changes to his typescript. be faltered while reading it. He sounded 87 anything but under control. Within days, he bowed to political pressure and brought back Moshe Dayan, now a member of the Knesset, as Defense Minister 1 still vividly remember a visitor to the sayeret the day after Fshkol's address. Colonel Kli Zein was head of the “collection department of the intelligence coups, the rough equivalent of America’s National Sceurity Agency. Formally, Sayeret Matkal was part of his deparament. He called together all the officers, He suid that there had so far been three periods in the Zionist project The first was from the carly setlements in Palestine at the end of the 19th century until the establishment of Israel in 1948. The second, from 1948 until the 1956 War, The tried from 1956 until naw. Then he suid: “There will soon he wwar. Three Arab counties will tke part. Within a week, we will defeat all of them. And anew chapter in the history of Zionism will begin” The Six-Day War begun on June 3, 1967, As Eli Zeira so confidently predicted, not just Egypt and Syria. bu Jordan, too, joined forees agmst ns. And il was indeed all over within a week. The final outcome — Israel's vietory — was sealed by noon an fhe first day, with wave atter wave of pre-emptive bombing surfics destroying the entire wir fore of all thse Arab countries. But the fighting which followed was brutal in places: especially around Jerusalem, but also in the south at the outset of the war, and later on the Golan Heights. The first effect back in Israel of aur air farce attacks was to make our sayeret helicopter missions into the Sai suddenly superfTuous. In fact i lef the entire aie at loose ends — especially veterans of reservists like me who had been parc of our nearly decade-long development into Iseael’s sole, dedicated cross-border inflation force. Al his point, we were still just im miclligence unl, nol an elite commando force like Briwin’s SAS. Avraham Aranan’s ultimate vision for the sayeret, The aim of our bugging missions into Syria and Fgypt was aot to fuzht. 11 was 10 gel m andl get onl, unseen and ideiceted. Bul we were nol only equipped 1 light if necessary. From the unit's cadlicst days under he sway of Meir Har-Zion, Kapusta and Gibli and Errol and the other grizzled vets from Unit 101 snd Company A. we had been stceped m the spit of commandos, Our training was the most rigorous in the Iscacli amicd forces, involving not just a punishing endurance régime but learning to assemble and disassemble, fire and detonate, everything from handguns to machine guns, makeshift explosives to arenades and landmines. The [rustration we felt on the first morning of the war was nol because we were tiehmg fo fight, for the hell of i. One hallmark of the suyerers ethos, especially onee the unit did start to evolve into a full-fledged commando ait, 88 wes always the principle of tacgeted force, Lhe idea that we would take ou targets, or defeat enemies, out of military necessity. But even on the fst day of the war, it was clear that it would be by far the most consequential conflict in aus countrys histary. There was no mission for Sayerel Marka, nor, it seemed, any prospect of vu playing any significant pact. The fact that my own role was slightly less peripheral was due to Avraham Aman. He phoned me almost as soon as we'd got news of the Israeli air victory, and 101d me he had been thd 10 lake a few men from the sayerel across the southern border. Our assignment was to complete our failed attempt ta defuse the booby-trap an the mtereept in the Sinai, 1 quickly drafied m two others from the unit. One was Danny Michiclson, a Griend Grom Hebrew University, where we had been lab periners. The other was Rafi Friedman. our paramedic, who had been with me on several of our missions on the Galan, Avualugma arrived a the base around noon. got i Jeep sd we set off. We crossed into Leypt around four o'clock in the aflcraoon and headed for the ficld headquarters of [srael Tal. Known as Talik, he was the commander of Israel's wmared comps, and Avraham knew him well. His wirime division consisted of the coniry’s premier tank unit, the Seventh Armored Brigade, and a reserve brigade. We accompanied them the next day to an abandoned Egyptian camp not fur from FI Arish, in the northern Sinai, At least, we'd assumed it wis uhandoned. As Talik and Avraham were talkivg in his command post, we heard a sudden burst of gunfire. which seemed to come from just a few dozen yards outside, As everyone inside the command post looked around, Avraham tumed 10 mic and said: “Ehud, don’t you think we ought to deal with #177 Then, to Talik: “Make sure none of your guys shoots him.” 1 got Danny and Raf]. We made our way toward an underground bunker, which seemed the most likely source of the gunfire. Hugging the wall as | led the way down a series of concrete steps, | clicked off the safety on my Uzi just in case. But with the main Fggyptian forces in obvious retreat. | figured that whoever was dog the shooting wonld hive ta be shellshocked, or insmely brave, put up a fight. There were eight men crouched inside, soldiers and several stall officers cradling Kalashaikovs. and an Tgyptian army general. Tn what wits obviously at least serviceable Arabic, [told them all to rase ther Tiands, | made a brie attempt lo interrogate the general, but quickly reached the limits of my linguistic proficiency. So we marched them away and handed them over to Talik’s intelligence officers 89 This interlude instantly confersed on us the desert equivalent of street ered The next morning, Talik agreed we could accompany the Seventh Brigade as it moved deeper into the Sin, and peel off when we got closer to Gebel 1.ibni to complete aur “ayes mission.” Given the early course of the Fighling, and our forces” rapid advances in the Sinai, [ couldn't help wondering whether there was any real need to defuse. much less remove, the bugging machinery. Bur che very fact that the Kirva, in the carly hours uf the war. had still wanted us to try wes a efleetion of the deep sense of apprehension in (sacl in the weeks before the war, Even now, it appeared, there was a concem that the Egyptians might recliim the parts of the Sinai which we had captured. When the armored column got close to Gebel Libni, {pulled our Jeep aside and headed for the streich of communications cable where we'd planted the intercept. For several hours, tried to accomplish in broad daylight what I'd failed to do in the desert darkness four months earlier. But it was 00 use. T finally told Avizham we'd be betlec off just blowing it up. T attached an explosive charge and set a two-minute delay. We watched from a couple of hundred yards way as the whole assembly dismicumied. Then we rejoined the Seventh Brigade Before sunset on the third day of the war, we reached the Egyptian air base af Bir Gufigata in the heart of the Sina, Even had the war ended then, we would have been in control of a kuge cual of the desert butler zone which Bea Gurion hiad hoped 10 retain aller the 1956 war. Buc now, more quickly than even the most optimistic planners in the kirva could have anticipated, Talk was poised 0 move on — werd the Suez Canal, and the main Towns and cities of Egypl. As the Seventh Brigade billeted down in Bir Galgak, Talik sent his reserve brigade westward, in the direction of the canal We went with hem. The bata hon was more manic thin a pore nk fore, but also more vulnerable: lightly armored Lrench AMX-13s and a collection of the halfiracks which [ dimly, unfondly. remembered from my irons. A few of the AMX led the way, then a line of hylfinucks, and more tanks at the rear, | nosed our Jeep into the middle, behind the battalion commander, a lieutenant colonel named Ze'es Titan. There were scattered groups of Tgyptian soldiers on either side of us, and they aimed un occasional burst of fire in our direction. But there seemed little point in shooting back. We didn't need to fight, snd it was clear that the Tgyptians didn’t really wan to. Shortly before dirk, 1iculenani-Colonel Extn brought our colin to hall. The road we were on cut thiough tall sanduncs on cither side. We know there 20 were still Egyptian soldiers around us. though [ doubt auy of us expected wouble. Still, there were well-established rules for selling up a defensible position when an armored force halts for the night, As Fitan briefed his officers, [stood a fow feet off to the side und hsiened. Suddenly, the commander of his AMX company interrupted. “Sic,” be said, “why ase we staying here — right on the main road? There are Egyptians still ou there. Behind us, for sure. And any force ahead of us will run stcaight into us. Why not a few hundred yards off to the side, in a place that gives us a view of any crienty movement, or allows us to ambush an approaching force?” [ could see that he was right. 1 expected Fitan to agree and alter the arrangements. But he didn’t. 1 think that, having ordered his wen Lo encamp on the road 20 minwes earlier, he was reluctant w gel his lanks and halftracks moving again. No doubt, some of the exhausted crews were already asleep. 1 parked oue Jeep a Few yards off the coud. We organized a series of watches: Avsaliam, then Rafi and Denny, with me taking the pre-dawn stretch. A low hours later. Rafi nudged me awake. “I heard something,” he said. pointing west toward the Suez Canal. “11 was fami. But 1 think so.” old him 10 keep listening. lio a while, everything seemed fine. Then, Dany woke me up. Tle said he was sure he heard a faint emer. as if from tanks or APCs. I pur my ear 10 the ground. 1 beard i1 100. 1 wkd lim 10 go 10 Kitn’s command halfirack, nist bie be woken up, and tell him. When he got back, Danny said: “1 told him™ “And?” “Don’t know,” he replied. “He said [contd go. ried lo grab a bit more sleep before my watch. But barely 15 minutes later, Danny jostled me awake again, “I'm sure now,” he said, “Whatever it is, it’s closer.” [ went oft ta find Filan. But before 1 gol there, i eolumm of Egypuim 1-55 lanks suddenly appeared on te road. 50 yards from the (ront of our column. hi sure they were every bit as surprised as we were to be face-to-face with enemy armor, But they knew what fo do. They opened fire. Hid we been deployed a few hundred yids fF the road, we'd have seen them coming. If the batalion commander had acted on Danny's warning, we'd have had an extr, 20 minutes to prepare, But the shells jolted our crews awake, Within 30 seconds, they were returning fire. But our tanks harcly dented the heavily armored T- 555. Nearly every one of theirs seemed to score a direct hit. Witkin minules, i nimber of ou hid racks, and one of our mks, were in Names. an Now thal we were in a fight -the single fiercest bate in Tscacl's advance across the Sinai — Liculenani-Colonel Gitan reacted swiftly. Standing tal anid the hellfire and the flames, he radioed for supporting fire, only 10 be told that none of ous artillery bitlerics was within range. Realizing we conldi’ penctrate the front armor of the Egyptian tanks, be ordered a platoon front the rear to leave the road and fire on the Tgyptians” from their flank. When one T-55 was hit and started w burn, hie ordered the rest of us to collet the dead and wounded and seta toward Bir Galea As we pulled back, we encountered a company of Centurion tanks from the Seventh Brigade, sent in fo relieve us, We pulled off the road to let them pass. The biti cuded up vaging for another hour. By the time it was over, the Eeyplian tank unit was nearly destroyed. Bul almost two dozen of Citan’s reservists had been Killed. A few days later, | learned that the commander of the Centurions had also been killed. Tis name was Shamai Kaplan. Though T didn't Law him personally, he was niaried 16 one of my kibbuLe “sisters” from Mishmar Iasharon. PEE The pace of the war, its miensity, und the transformative captive of fenitory across our 1948 borders had seeclerated dramatically sine we'd joined the reserve battalion's ill-fated advance toward the canal. Back at Bir Gafgala, we leamed that [sraeli troops had broken through in fierce fihting with the Jordanians and taken the whole of cost Jerusalem, including the O1d City and the site of the remains of the ancient temple. The news seal & shiver down my spine. 1 was still only 25, a kibbutznik raised on the assertively secular creed of Gord Zawmsm. But 1 was old enough to remember tie war of 1948, the bitter struggle for the ancient city in which Judaism had been born, the packages of food we had sent to try to help break the siege there, and the division of Jermsalemn au he end of the war, leaving ws with only 1s newer, westers hall, And while [ may not have read the Torah in the same way as a religiously observant Jew, the meaning of Jerusalem was no less powerful for me. It was part of our peaple’s history, of wha we were, where we’d came from and how wee had ended up in the place where 1°d been bora, where 1d grown up, and which I'd spent the early part of my adult life defending. This was no less true of the nblical sues of Judaca and Samaria the West Bank of the Jordun river, 92 Places like Bet Ti, Shiloh, or Tebron. They represented the historic wellspeing not just of the state we'd created, but of Jewish civilization, our heritage, our moral and ethical foundation, As [ drove buck to Tel Aviv with Avraham and the others on the moming of fourth day of the war, we head Iseach ground forces were consolidating thew hold there as well. After dropping Avraham at the kirya, we drove back to the sayeret base, but it was nearly empty. The main fighting was now with Syrian srmared units on the Golan Heights, and most of the meu in the unit had gone north iu the hope of joining what seemed likely to be the final stage of the war. Although the precise outcome wits not yet clear, there was 1 dawning certamty, almost wrseal, Ut Israel was gaining control of all the avcas across our 1948 borders from which the Arab states around us had shelled Israeli farming settlements, ar Tacilitated fedayeen attacks and ambushes aginst our citizens the very border areas where I'd led intelligence operations in Sayerct Matkal 1, too, drove north, Not far from Kibbutz Dan, the stagmy point for our first Golin operatian, 1 inked up with a group of other sayeret reservists, Tstaeh tanks had already broken the main resistance of the Syrians, bul fighting was continuing in a few parts of the Golan. In the western corner of the Heights which bardered | ehanon, several villages still lay bevond the Israeli udvance. We gan an order 1 soe 1 we could fike them. [1 took barely wn hour, against no nore resistance than I'd met in “capruring™ the Egyptians in the Sinai bunker. By the time we had made our way buck across the Golan to the now-abandoned Syrian beadquaricrs in Quncitry, i1 wis sunset. The war was drawing los close. 1 save my Jeep to a couple of paratroopers and hot-wired a more comfortable mode of wansport back home: a big, black Mercedes which had obviously belonged to a semior Syman officer. If only becanse of the license plates, | avoided the main road back into Israel. T found a dirt track running between Syrian positions on the southern edge of the Golan and descended toward the fruit groves of Kibbutz Ha'on, near the Sea of Galilee, 1 then headed for Givataim in nocth Tel Aviv, 10 a place Tkoew well. Tt was the home of Menachem Digli. He had been Avraham Aman's deputy in the sayeret when [ left far my stint in officers” school, Before | returned ta the unit, he hada motorcycle accident, badly damsging his lee. He'd been temporarily reassigned toa post in intelligence. 1 figured a Syrian Mercedes would make a nice gift Not wamtms fo swale im, [le a1 in font of his house. Sadly, he never got 1o use it. The next day a couple of military policemen knocked on his door and a3 asked what he knew about the car outside. “Nothing.” he said. “It's not mince.” They took it away. As insistently as [, and others in Sayeret Matkal, had wanted to play our part on the battlefields of the Six-Day War in the Sma, on the Golan, in the bitter battle 0 capture Jerusalem, or amid the olive-green hills and valleys of the West Bank we had to accept thar, at most. we'd been freelance support troops. Or mere spectators. But while it would be many years before this was openly acknowedled, we did play an important part in the uucome, Because Dayan had been called back as Defense Minister oaly days before the war. he had wisely decided not to alter the pln for fhe preemptive air strikes. But he did adjust onr ground advance. Just us with EshkoPs knowledge of the initial Eeyplian advance in the Sinai before the war, Dayan's judgements were informed by detailed, real-time intelligence on where enemy tanks and troops were located, what they were doing, and what how and when they were planning to advance. As speculation mounted after the war about how Israel seemed to know so much the Arab forces, Meir Amil’s successor ws Head of Military Intelligence, Allie Yariv. even engaged in some misdirection. 11 was anxious 1 avoid jeopardizing future sayeres bugging: operations. In a speech on how the war had been won, he included 1 reference to a “high-rankimie spy” in the Fgyptian army who, he inpliod, liad leaked critical information. The “spy” wes the series of intercepts we'd attached to the Tgyptians” main military communications network in the Sinai, and ta the telephone poles on the Goin Heights. On a deeply personal level, Too, the war lof its mark on Sayerel Matkal. Though che fighting had been brief. people did die. Thousands of Ceyptians. Syrians and Jordanians. And about 650 Israelis. Some of were not just people we knew. They included close frends. Keehemia Coben, the officer 1d joined m ous Tailed atiempt to defuse the booby-teap in the Sinai before the war, entered. Gaza on the first day in his new role as deputy commander of Amsalem’s puratroon unit. Amsaken was killed carly on, so Nechemia took command, He wees shot and killed ifleen minutes later. To this day. he and [share the distinction of being the most decorated soldiers in Israel's history. Tlad he lived. have no doubt that it s an honor he would have held alone. This wis the first close friend from the mit we'd lost. We did not moun him opealy. For young soldiers of my generation, especially but not only those raised with the additional kibbutz ethos of stolid self-conirol, there was sn embedded sense that such individual displays of emotion were an indulgence. and lusury 94 even, which the country we were building could not afford. Tn the carly years of the state, the model [srael mother or father were those who stood silent and strong as a saldier’s coffin was lowered into the ground, Nechermia®s death hut, of couse. | was friends not just with him, but his older brother, Eliczer. Known by his army vickname, Cheetah, he was in charge of the air forces main helicopter squadron. He had tlewn both me and Nechemia on saverel missions into the Sinai. Several days afer the war was over, before seturming Ww university, | drove up 10 Jerusalen to see his family. Cheeta was at the door when [ arrived. Neither of us spoke. But as we embraced. I could teel my eves dampen, and there were tears in his eyes as well “Our squadron was the one hist got the call 10 bring out the casualies.” he said. “They ordered the pilot who brought out Nechemia not to tell me he was dead... until the war was over.” “He was a wonderful man.” 1 suid. ““I'here was no one better.” «ss When I returned to Hebrew University, the countivy felt completely different. It was not just the sudden realization that, in military terms. Israel had eliminated any reuistic this lo is exasicnee, nportnt thongh thi was. The more profound change was physical. The country in which I'd grown up was a place which felt not just small, but pinched. especially in its “narrow waist” near Mishmar Hasharan, Pre-1967 Israel was about three-quarters the size of the stale of New Hampshire. Now, within tlie space of less than a week, the territory Israel controlled had more than wipled. It included the whole Sinai Desert, up to the ede of the Suez Canal. The entire Golan. The ancient lands of Judacis and Sumarie: the West Bink, And the reunited capital city of Jerusalem. Suddenly, we had a seose that we could breathe. Wander, exploce. Tew of ny classmates were religiously observant. But none of us could help feel the sense of connection us we walked Uromgh the Old City of Jenusakem, or parts of ihe West Bank whose place-names resonated from the Bible. I felt especially moved when I first visited the Old City with my friends, stopping and chatting and buying things at the colorful market stalls, And, religious ar not, when | stood in front of the surviving Western Wall of the ancient Jewish temple. 95 The personal Interactions we had with Palestinians in the weeks aller the war were without obvious tension, much less hostility. They were ofien friendly. T.ookiny back, Pm sure that was ane reason along with simple human nature, desire 10 enjoy Jsmael’s new sense of hoth seenrity and size hat none of us wes inlined to look toa deeply, or 100 far ahead. and contemplate the implications for our counry’s future. I was aware. of course. that the politeness we exchanged will the Palestinians of Jerusalem or the West Bank were superficial” a (ow words across a market stall or & rostausant counter. | did not pretend to myself that our Arab neighbors were now suddenly inclined fo be our friends. But 1 did fel that, having come fice-to-face with ow overs helsing military supremacy, the Arab states would, over Lime, grant Tscael simple acceptance. From there, 1 helieved that we could begin the process of building genuine, Tasting, human relationships and. eventually, peace. 1 here was a brief period alter the war when Lshkol cautioned his ministers about the implications of holding on to the vast new area we had conquered. The government formally agreed to treat most of it, with the exception of Jerusalenu, as & “deposit” 10 be traded for the opening uf peace talks. Yet within weeks, the emphasis in the Israeli political debate shifted to which parts we would keup: the Sman and the Golan almost certainly. as well as the Jordan Valley aud a number of areas of past Jewish settkement on the West Bank. The drift away from any serious talk of trading land for peace was accelerated by the Arab states” response 10 the war. Perhaps that, two, was simply a mater of human nature, a reluctence on their part to accept defiat. Bu they appeared no more ready than before to contemplate peace. Throughout the summer. there were clashes along our new “border” with Egypt: the Suez Canal. In Septertber, all the Arh states aopied t plaiform which became known a the “tne no's” They rejected not just the idea of peace, but peace talks, of recogaition of the Stare of Israel. And in October, Egyptian missile boats attacked and sunk Israel's ingest warship, the destroyer Eilat, killing nearly 50 peaple on hoard. Without this reviewed violence, petiaps. we in Issel might have beet able to consider more deeply the future implications of our victory in the Six-Day War. The gains on the battlefield, of conmse, were ele fo everyone. We were na louger a small, consiricicd country beset by a sense of vulnerability. We were not only much bigger. but also stronger than the combined asmies of the Arab states. Still, very few people asked themselves at the time what find of (srael this implied. We failed to grasp the potential complications in holding on to all 9% the land. and of controlling the daily lives, however beaiguly. of the bundreds of thousands of Arabs who lived there. Nor, crucially, did we poader the limitations of military strength, alone, in addressing these questions, We and 1, fo, #1 the Time — were 06 canghl up in 1 sense of post-war velicl, celebration and, as the months oF ostensible normalcy in this new Jseacl, complacency as well. But within only a few years, we would fice a dramaticslly different series of challenges. First, # campaign of Palestinian terror. hen, nother full-scale wer, which began with a surprise attack by Arab armies which we had assumed would not dare to fight us am, 97 Chapter Seven If you'd visited Tel Aviv in July 1967, vou would have sensed a new spirit af confidence, mol cockiness exactly, bil a sort of spring in the collective sep. This was nol just due 10 the Six-Day War. It was because the city, if nol yet the test of the country. had shed the economic austerity of Israels first two decades and was bginming lo experience ut least some of the consumer comforts which Western Liurope, or America, wok foc granted. Bu we were still a decade away fiom the first shopping malls, or the upscale cafés and restaurants which nowadays jive places like Dizenpoff Street, a tew blocks back from the seafront, the feel of London or Paris on a summer's day. Television had been introduced only a year before the war. Color TV was still nearly a decade away. Lcan’t say 1 was surprised fo learn. when the archives were opened a few years ago, that a commitice of mera arbiters in our Ministry of Edueation vetoed plans for the Beatles to perform in the city. “No intrinsic autistic value,” they pronounced. “And their concerts provoke mass hysteria,” Fen in Tel Aviv, and certainly the rest of Isruel, a kind of cultural austerity still prevailed. an emphasis on modesty and self-restraint. Tt was a kegacy of 1948, a reflection of the years of shared sacrifice. physical labor. and the life- and-dewth stongggkes which 1, like most Israchis al the lime, had experienced within our own lifelimes. That may belp explain why | can cemember uo one remarking on an aspect of my character which. once I rose to public praminence, would attract attention, frequent comment. and sometimes criticism as well: the fact that | scemed so self-contained, reluctant 10 cogage emotionally with people beyond a circle of close friends or confidants. My lack of smalltalk, and the kind of gladhanding and schmoozing that are the currency of political fife. At the time of the 1967 war, | was not yet a public figure. Yet to the extent those around me would have taken note — family, university classmates, sayeret comrades, or officers in the kya my slight emotional aloofness, my focus on simply getting things done, and the way 1 mtematized setbacks, even tragedies like the death of Nechentia Cohen, was not exceptional. Ir was, in many ways, simply Israeli. Yet as Israel, Israeli society and my place in them changed, it would be suggested Lo me more tan once — no always kindly, when it wag from eitics or rivals — that T had a “touch of Aspbergers” in me. a reference to those on the mare benign reaches of the afism spectrum wath a special ficility for mith, 98 abstract ideas, the theoretical scicoces and, often, music as well. [would always smile in response, suggesting thal sueh diagnoses were probably best lefl to the professionals. 1 couldn't pretend, however, that emotional engagement with new wequainianees, even wilh people 1 knew and liked but were not close friends, was something that came naturally. And it is also true that from my fist experience of the world of numbers as a child on the kibbutz. and as I tackled ever more elaborate pices on he piano, [ did become aware of what might be called the upside of “a Louch of Aspergers” — if that, indeed, is what it is. | was conscious of the case with which my brain translared the complexities info pictures in my mind. And the joy. at times, with which it allowed me to play wound with, and develop, what | saw. By the summer of 1967. Thad experienced that feeling again, in my ficst real encotmter with theoretic physics at Hebrew University. After the Six-Day War, T began seriously contemplating a future as a research scientist, of perhaps eventually a professor of physics. Two months after the was, enrolled in a sunimer program at the Weizmann Institute, Israel's preeminent postaraduace sescarch fcility. Snrmounded by some of the comntry’s, even the world’s, leading scientists, and by post-doctoral students determined to follow in their footsteps, was intellecrually enthralling. But if turned out to have another effect an me us well. As [lhonght mare and more shout the prospect of joining their Traternity once I'd completed my undereraduate degree, 1 also beard them describe the way in which pure science sometimes ot submerged in simple rautine, or. more discouragingly, in the politics and positioning: and backbiting of the academic world. T think what finally changed my mind, however, was a feeling, nurtured on the kibbutz but solidified by that many nights I'd spent leading saveret aperstions seross our borders, that | would find my true propose in ite trying 10 make some special contribution to the future course of Israel. [did aot for a moment contemplate politics at that point. Instead. I thought of going back inte the military. | vealized tht in order wo make iw signi fiemt mark, iCindeed | could, would require me to serve in the regular army, nol just an estaordinary unit like Sayeret Matkal. But 1 did hope that. at some stage. I'd be given the opportunity to finish my time in the sayeret as its commander. carrying on Avralian’s vision and. ideally. building and expanding on it as well. AL least i that part proved possible. T felt that, by comparison. a career in academia would be somehow blinkered, and surely less fulfilling personally. My sayeret experience had also taught me something else us well: that protecting Israel's security was not just a matter of muscle, or firepower. indispensible though they 99 sometime were. Tt called for meatal application, an ability to assess risks, to find answers under enormous pressure when, inevitably. {hings went wrong. It required not just brawn, but brains, A week before | began my final year at Hebrew University, went fo see Ef Zeira, the senivr intelligence officer who'd so brashly predicted the course of the Six-Day War, in hopes of sounding out my prospects of picking up my military career where Ud left off, Despite i vawnmg gap m rank and age Kli was nearly fifleen years older — 1 felt | could be open with him. Not ouly did | know him trom Saveret Matkal, which came under his purview in the kiya. He was a Scientist mangué and was caer, as soon as | umived in his office, to hear whout my physics studies. When [did masse wo tum the conversation to the army, T wld him T was thinking of retucning afler T graduated. Yet before finally deciding, [ wanted his honest opinion about my chances, at some point, of being given command of the sayeret. ITe began with a series of caveats. The choice of luture leaders of the sayerel was not be his to make. When the cucrent commander, Uzi Yairi, ended his term in roughly 18 months” time, I'd still be To young to have a realistic ehice. “Maybe even next ume around,” he said And in any case, T would first need to pet some experience in the regular amy. “But then.” he concluded, “my opinion is that you have a very good chance of becoming communder of the unit” That was more than enough. 1 Figured that whether il actually happened would now ultimately be down to me. My last year at university was the closest thing T would have 1 a normal student existence, [ was culled away only once, But it was for u battle which would lum ou 10 have s kasting impact on the course of our conflict with the Acabs, and on the prospects of eventually finding a way to make peace. Tt was Israels largest military action since the war, across our new de ficto border with Jordan. And it wars directed iti new enemy: a fledgling samy of Palestinian [edayeen, called Fatah. Tt was led by a man that I. like almost all Tsraclis, had never heard of at the time: Yasir Arafat. Born in Ceype, as a 19-year-old he had Tonght sgainst. the establishment of Israel in the 1948 war. Although Fath had nominally existed for nearly a decade, it was only now emerging as a political force, in large part because of the Arab armies” humiliating defeat in the Six- Day War. A Palestinian political leadership already existed, in the shape of the Palestine Liberation Ograuization. But il was based in Cairo. 1s chairman was, for all practical purposes, an adjunct of President Nasser's leadership role in the Arab world. Though Arafat had not yet explicitly challenged this state of affairs. his, and Futh’s, risc ufler the war carried a powerful, message for the existing Arab presidents and prime ministers: their brash promises of victory before the 100 1967 war had wend out to be hollow words. TL was time for a new generation, and a new, more direct, form of confiontation with the “Zionist enemy.” Aratut had set up camp with nearly @ thousand men just across the Jordan River, in a fown cilled Kavameh. From carly 1968, they bid been launehing hit- and-cun caids, not just on the West Bank but into the Negev. lishkol’s cabinet was initially divided on whether to attack his base in Jordan, in bath an act of retaliation and a signal to King Hussem tht of ns army didn’t rein in Arafiut’s men, [sacl would take whatever action necessary. But the deeisive moment came on the eighteenth of March. A school bus near Eilat, in the far south of Israel, hit a Fath landmime, killing the driver and a teacher, and injuring 10 of the children. 1 was called up the night before the Israeli attack, as part of a small Sayeret Matkal contingent which was supposed fo play a suppart role, An enormaus, pincer operation wits mounted sound the Fatah camp and Karameh itself: including a full infancy brigade, the Seventh Armored Brigade and the paratraapers” sayerer, But the resistance they met, both from Fatah and Jordanian troops, was much ficreer than expected. One of the paratroop commandos, Mookic Betzer, who would go un to join Sayeret Matkal, wid me how they landed by helicopter and immediately came under a hail of AK-47 fire, Within mmutes, several of ns men had been kalled, Mookie was wounded The tanks of the Seventh Brigade advanced from the south. Bailing the Jordanian army, they took losses as well. Amnon Lipkin, who would also later become a friend and colleague, in both the army and Israch politics, was in command of a nil of lightly armored French tanks called AML. They, 100, were hopelessly outgunned. Our sayeret assignment was to block the southern entrance to Karameh as the Israch armored fore advameed. Bul we got bogged down in mud as we made our way from the Jordan River. By the time we arrived, hundreds of Aratar’s men had already fled the area. Arafat, too, had escaped, on the back of a motorcycle. By the time the fighting was over, some wo buandsed Fatih fighters had been killed. But nearly 30) Israeli soldiers lost their Lives as well, and more than twice that number were wounded, Politically, the outcome was even mutkier, Most of sacl was shill basking in one victory in the Six-Day Wea. Now, we bid deployed many of the same units. only to fight to what looked like a costly draw. Arafat and Fatah could claim — and soon did — thi they had stood md fought, and inflicted losses on the victors of 1967. 101 «ss In retrospect, given all the interruptions, 1m a litle surprised that | managed 10 get through my university studics. My classmates helped. They were incredibly generous in going through wich me what I'd missed, and sharing their notes, whenever | relied for an extended stmt of reserve duty. ve seen interviews wilh wiiversity fiicads saying | was one of the top students in our class. But that is more generous than true. Tt would be fairer ta say [ was a good student. Working hard in the final year, did finish in the upper quarter of the chins, and several af my math and seicnee professors strongly urged mie Lo go on to graduate school But my mind was made up on returning to the anny. And as 1 balanced my stucics with plans For the fue during my fred months, | still hadn't given up hope that Nili would be there with me. When she returned liom Paris, we had started seeing each other again. Whenever I could, I would take the bus down ta Tel Aviv and spend the weekend wilh ber, Everything Pd loved ubout her since that fivst meeting in the kirva, everything 1 valued in our celatianship, was still there. Yet so. 00. were the doubts: whether she was ready to conic hetself © sharing our hves togethers and whether a kibbutz like me could ever truly i in 10 her 7el Avivi world. Shortly before Karameh, she'd invited me to a Friday night party with a group of her friends. It was the first time she was including me, as part of a couple, in her social circle. But almost from the moment we gat there, | felt out of place. For her, it was just another party, one of dozens she must have been to since she was a teenager. But T immediately felt out of place. [dida’r drink. 1 couldn't dance. 1 couldn't help feeling like a wallflower, or an alien presence. Now. T decided there was ao point in waiting aod wondering. T borrowed 2 Jeep from an army friend, with the idea that Nili and 1 could spend three or four days together, diving south from Jerusalem fata the Negev ind the Judin desert: 1 be alone, to talk, 10 see whether we actually had a future. T wrote her a note. took the bus to Tel Aviv while she was at work, and dropped it through the letterbox. “1 am going on this trip, inta the desert,” it said. “I'd love it if you could come with me. | think it's important for us.” 1 never heard back. I fekt crushed. though I tried hard to tell myself it was better to know where we stood. Years later. she told me the envelope had ended 102 up under a pile of mail. She bada'L seen it until a week aflerwands. She said that of course she would have come with me. She fel angry with herself, and with me tag, for not simply having phoned. But since 1 didn’t contact her in the weeks thal followed, she Figured Uns was just another ue of our fimes part. Or “3upid pride”. A few mouths later, | heard she was engaged to he married, to a young man she'd known since their high school days at the Alliance. had first met Nava Cohen, the woman [would go on to many, the previous year. IL was through another Cohen, though tiey were nol related: Neches, my sayeret friend who was killed in the 1967 war. He invited me to Tel Aviv far a party m the spring, on the Jewash holiday of Purim, and introduced us, Nisa wies just uinctoen, five yours younger thn me. | wis struck siot just by the fact she was aitcaciive, but by her poise, warm-heartedness, and her obvious intelligence, But she had her boyfriend with her, and [ sull saw myself and Nili as life partners. Now, she was beginning hee studies at Tebrew University as well and. ina way, it was again Nechemia Cohen who brought us together. Since his death. those of us who knew him from the suyerct had been looking for a filling way to member and to honor Rim. We finally decided Ww set up a living memorial in his name: a Moadon Sayarim, a center fo train young peaple from all over Jerusalem in scouting and mavigution, We spent six months grertmy it up und running, and Niwa pitched in with the work. Tt waso't until a few months alle T heard of Nili's engagement that T finally asked her on a date. We were in the university library, which had a space where you could lisien to apes through headphones. 1 would go 10 bear elassicsl music. Nava was studying Tnglish literature. and I'd sometimes see her there, engrossed in recordings of Shakespeare with the text of Hamlet or Macbeth in front of her. Smee Uwasn’t shackled by the need to follow the alacks and alasses. 1 ead the newspaper as the music washed over me. | tuned to the movie section. | circled three films, drew a question mark in the margin and passed it 1o her. She fooled puzzled for a seeond. Then she smiled and pat i checkmark next lo oue of them. While we came from different backgrounds, the gap was narrower than it had been with Nili, Her parental home was in Tiberias, Her parents were from ald Sephardi Gimilics, with a conturies-long history in Pakestine, and were also salid Ben-Gurion Labor supporters. Iler father had fought in the British army in the Sceond World Wir. He now vm the branch of Bank 1.cumi in Tiberias. Her mother ran a shop in what was then the city's best hotel. the Ginton. 103 We were married there, in the spring of 1969. My parents and brothers came with two busloads of (viends from the Kibbutz. Aveaham Amman was there, of course, But Ahraleh Yariv and Eli Zeira, two of the military intelligence heroes of the Six-Day Wir, also drove up for the wedding, which touched both Nava and me. not to mention her family and our guests. Years later, as | rose higher in the ranks of the military, I would sometimes be invited to weddings by officers wader my command. Remembering how much we appreciated Ahraleh's and Li Zeira's gesture. | always said yes Tt was only weeks aller our wedding that T formally returned to Sayerel Matkal, Roth Nava and [ were aware of the additional pressures my military commitments might plsce on our family Be. But she understood why I'd chosen 10 go back, and was supportive. As for me, 1 was, if anything, more certain that I'd made the right decision. Israel was clearly facing a whole new set of challenges to its seeurily. Given the decisiveness, md speed, of our vietoey in 1967, there seemed no immediate danger of Egypt's risking another full-scale war. In Israel, where Golda Meir had become Prime Minister after Eshikol’s death from i het attack, there wis also little appetite for selumme to the bateficld. Yet the post-war skirmishes with the Lgyptians along the Suce Canal had escalated into far more than that: what would become known as the War of Attrition. Nor could there be any doub, after Karameh, that Fatah's influcoee, militancy and determination would aly grow, not least because even more radical factions within the PLO were ready to step into the breach if Aratar falrered. Israel needed to find an answer for all these threats. Uzi Yairi’s term as Suyeret Matkal commander had by now ended, bit his successor was someone knew well. Menachem Digli was the oflicer on whom I'd bestowed my stolen Syrian Mercedes at the end of the war. [lis leg was now recovered from the motorceyels accident, and | vetumed To the sayeret al bis deputy. Ie delegated full responsibility to me for operational issues. 1 believed that the new kind of challenges we were confronting, particularly the prospect of intensified amacks from the new generation of Palestinian fedavecn, meant that the sayeret would sooner or later have to broaden its reach, moving beyond the kind of intelligence operations we'd done before the 1967 war to become the SAS-like special forces mil Avram ullinucly envisaged. But thal was not 104 going to happen soon, if only because the intelligence missions now required were guing to bea lot tougher. Tscael now had control of the <atire Sinai and the Golan, To tap inta enemy communications, we would have to push deeper inside Keypt und Syria. Soon after my relum, we began planing the sayerel's most ambitious mission so tar: targeting the main communications system berween Suez City, at the southern end of the canal, and Egyptian military headquarters m Cairo. We were obviously going 1 have Lo go in by helicopter, But we Giced not just the risk of being spotted on the way in. The buildup of Egyptian forces along, the canl now included Soviet-made anti-uireraft missile butteries, We might cusily got shot down The mission stcuck the penerals in the kivya as so risky as to border on the insane, But 1 was confident that we could make it work. [ began talking to the Tew senior air foree officers whe seemed more reeephive, as well as lo officers iin the helicopter units. Not only had I flown into the Sinai on carlicr missions. 1 now also had a physics degree. Together. we developed a plan using the desert termain, and driwing on the heheopters” muncoverability to ealeulatc w flight soute that could avoid detection by Lgyptian radar. As an xia fail-sale, | proposed using three helicopters, and three saveret teams. Two would fly sliuhtly higher, with the express iim of wetting spotted, but still cvadmu missile fire. They would land far away from the seal tavget of the operation. The main team. with me in command, would also stage a pair of diversionary attacks: planting explosives on a high-voltage electricaty cable, and on the main ml pipeline from Suez. City 10 Cairo. Still, for many weeks, the answer from the Aira was no. The man who had succeeded Rabin as chief-ot-statf atter the war, Chaim Bar-Lev, dismissed it as “ua pln brill om chicken legs.” In the und, whi got us fhe green light was i further escalation, on both sides, in the War of Attrition. In January 1970, Isracli warplanes bean a series of deep-penetration bombing: raids, far the first time striking largets dozens of miles, in some case hundreds of miles, back from the canal. The Iseacli bombing campaign reduced the chance we'd get shot down and provided cover for our operation. Our helicopters took off after sunset, nearly skimming the water and peeling off in sepaate directions on the far shore. The other two aircraft headed 120 miles to the south. [ led the main team of ten men. We set down a few miles south of the rou fram Suey City 10 Cairo. We unloaded i pane of Jeeps, drove off, and within an hour had placed ouc time-delay explosives on the electricity 105 tower and the pipeline. Bul when we reached the site of the underground communications cable, the mission literally ran into the ground. We dug for more than two hours, but still hadn't found the cable, and our mail-order metal detector siubbomty refused lo ching oul any sign of il. Just when 1'd decided w call the helicopter back in to get us, it finally peeped a taint signal. 1 still wasn't convinced, but as we manipulated it back and forth, it got lauder. SHI, my instinet was to abort, We'd pluced the explosives ant the electricity tower aud the pipeline. That would at least diver! aucution from our real mission, which meant we could return in a few months and have another attempt, After all, the part of the operation that bud been causing the ost concern in the kirya — our ability 10 gel deep inside Bgypt detected — had succeeded. We were nearly three hours behind schedule. Unless we worked a lat more quickly than planned, by the time we installed the communications intercept and covered our tracks, it would be daybreak. Digli and several other sayeret officers were following the mission from their command post in the Sinai. part of the intelligence base our military engincens had built wher the win into a 2,400-focl-high momtain ealled Gebel Uni-Haghiba, 20 miles back from the Suez Canal. When [radioed in to well him I'd decided to abandon the operation, 1 could hear the surprise in his voice, and what seemed reluctance as well, “IF that’s your judgement...” he said. Bot bot {could ply that, yes, | felt withdrawal was the wisest course, | beard him speaking to someone whose voice [ also recognized: Avsha Toran. Ile was the soldier on guard duty in the command post far our first mtercept operation in the Sinai, the one who'd 1old me of how Rabin was cham-smoking und biling his nails when it appeared we might be in touble. Now, he was a sayeret officer. Digli came back on the radio. “We can see more from here,” he said. Then, psusing, he udded: “Avsha says be thinks you cin still do it” 1 had grown wo respect Avsha’s judgement. And while Digli hadn't explained what “more” they saw from the command post, | assumed that, since they were also followin the other helicopter leas funher south, they were concemed that the Ligyptians had ligured out at least that Lsvacli units were involved. Both he and I'knew that it ultimately had to be my call. Whatever happened. I'd be responsible. Yet | realized that discussing it further would change nothing, and time was now whal matiered most. “We'll do it” | wld him, and signed off: We'd planned [or the cable work wo take something like five hours, which T Kaew we couldn’ afford. With all of us pitching in, swe drenching ous “Lpyptian” uniforms, we managed to Cnish in slightly less than four. But we 108 were still behind schedule. Daw was 25 minutes away. T cadioed the helicopter pilot with a new pickup pon, closer to where we'd installed the equipment though still far enough, | hoped, to avoid ving away what we'd done. Still, we burely made 1. The stm was rising ss the chopper began weaving among the dunes and wadis on the light back 10 [srel. Looking back, we could set flames leaping up from the ail pipeline in the dim. dawn light There could be no doubt the prize was worth it, By the time we retumed, the receiving equipment a Un-Hashibe was. for the first time, picking up seal-lime communications at the highest level of the Egyptian military. Wich the War of Attrition showing every sum of getting even fiercer, it was a eriticial intelligence advantage. When we landed. not ouly igh, but Alle Yariv were there to meet us. Digli, smiling broadly. handed me a small cloth insignia. “You've med it,” he said, adding that Rar] ev himself had endorsed my promotion from captain 1o major. PEE With the Cairo-Suez mission, and a series of vier operations helped run nearer to the canal, there now seemed every possibility that | wauld be chosen to succeed Digli as commander when his term expired. But that was still more than a year sway, in the spring of 1971. With his agreement, 1 decided to use the time to do what li Zeira had advised me before T made my decision t return: to get experience in the regular army. The War of Attetion had ereated a demend for qualificd officers who could command funk unis, since they were playing a key role against the Cayplians along the canal. Along with about a dozen other middle-ranking officers whe had volunteered to move into the mare cons, | embarked on 1 course covering every facet of lank warlre: how each system on aa individual tak worked. how to pilot one, load in the shells, and then calibrate ifs main gun. aim and fire. We smdied communications profocols, even tink mamicnamee. We were taught how to command an armored platoon — a group of three tanks — and then an armored company of eleven tanks and APCs. Finally. in July 1970, we were given command of actual companies, with the aim of deploying us against the Ligyplians. My company was part of Brigade 401, in the Sinai. It was one of the several armored forces Liat were votated. every three months, into action on the front 107 line. Tn a stroke of good fortune, the brigade commander was Dovik Tamar, Avraham Arnan’s (ist successor as commander of the sayerel. While we waited our forward deployment, due in September, he included me in his discussions with his senior officers on lacties und plang, “This inevitably included the care of our existing strategy: a line of fixed fortifications which we had built on our side of the canal after the war. They were known as the Bar-Lev Line, because the chief of stall ultimately had 10 sign off va them. But the main impetus liad eome from Avraham Ada. A former Palmachnik, known as Bren, he was the overall head of the armored comps. There were strong critics of the Bar-Lev line, bur few more vocal than Arik Shavon. The very qualitics that ad made him the porfoct choice 10 lead Unit 101 and its successor commando units — a naval instinct wo favor bold, preemptive attacks, allied with an absolute confidence in his own judgment and Title time for those wh challenged it — had stalled bis rise up the military ladder for a few years. But now he was head of Israel's southern command. le was convinced that in the event of another full-scale war with Tpypt. the Bar- Lev line would be worse tim nscless. We'd find ourselves forced lo defend a string of fortifications that could serve no real purpose in repelling a concerted Egyptian attempt to retake the Sinai. Arik’s preferred strategy was to let the Fuyplian froops cross the canal and then confront them on terms where Issel forces had a proven advantage: a mobile bale in the open desert When the debate came up in our brigade strategy discussions, said T believed Ank was right, From aur recent siyeret missions, 1 said there was no way the Bar-Lev fortifications coulel protcet us. 1 knew how casy it bad bien for us 1 operate unseen between Tigyplian positions across the canal, and they were only a tev hundred yards apart. On some parts of the Bar-Lev line, there were six or seven miles helween onlposts. A whole Egyptisn brigade conld pass theough Very few in tae firya, however, seemed ready to recalibrate our strategy against the Kyplians, Only later, when the damage had already been done, would it become clear that the navy was alone in acting on lessous learned from the fighting since the 1967 war. Tlaving lost its largest warship to a more mobile Firyptian missile boat at the outset of the War of Attrition, 1t hegan focusing on doplaying mobile missile boats of its own. Bul the air fore wis showing no sign of dealing with the implications of the Egyptians” increased anti-aircraft capability even hough we'd begun losing planes and pilots to the new surface-to-air missile batteries Nasser had received [rom the Soviets. And T 108 could sec that a similar myopia, or deaial, was affecting the armored corps. On patrol along the canal, T would sometimes see the hulk of an Tsracli tank which had been destroyed by Soviet-made AT-3s, Known as Suguers, they were portable, allowing a sel soldier fo fire wire-gnided missiles. Their vange wis nearly a mile-and-a-hall, which yes more than the main guns on our Lanks. Yet 10 ane appeared to have addressed the question of what would happen if the Ligyplians used Saggecs on an even greater scale in a future war. I remained in the Sinai throngh carly 1971, bt never led my tank company on combat operations. By the time we were due for our deployment, the War of Attrition was suddenly over, Neither we nor the Egyptians wanted a retum ta full-seale war. With Washington taking the lead a cease-fire was agreed. Both sides claimed victory. But both were exhausted. Certainly, most Tsraelis had ceased to see a compelling reason for the 1,000 days of fighting, We had lost about 900 dead: more than in the Six-Day War. But in oue respeel, the Ligyplians won. Under the terms of the truce, their anti-aircraft batteries were barred from a roughly 30-mile strip along: the canal Willin days of the truce, however, Nasser began moving his SAM batlerics forward. Before log, there were nearly 100 missile sites in the “prohibited” zone. giving: the Egyptians control of 20 miles or more of the airspace on our side of fhe canal. Golda was incensed. So was Buv-lev. Bul there was no way, and no will, w reopen the fighting and force Nasser lo move the missiles back The cease-fire wok eflect au midnight on August 7, 1970. Pve never had trouble recalling the date, because of a phone call almost exactly 24 hours later, [was from my mother-melaw. 10 tell me Nigvis bid gone into labor with our first child. Since I was due for deployment on the front line. we had agreed weeks earlier that the best thing would be for her to have the huby in Tiberias, so her parents could bee with her. Now, 1 gota Jeep and vaced novth. reached Tibenas the next morning. | opened the door to the hospital room and saw Nava, obviously tired but beaming, cradling our daughter Michal in her arms. | managed to stay with them for several days before returning to the Sinan With Nava aod Michal soon settled back into our apartment in the noth Tel Aviv neighborhood of Ramat Aviv, I made weekend visits home whenever 1 could. Sul, 1 suw nowhere near as much of our daughter’s first few months as wos! fathers. As Nuva sad 1 would discover even more janingly over the next few years. that was an inescapable part of being an anny officer. 109 But at least my next posting was closer to home. Tt was only 20 minutes rom our apartment, on a former RAF base ot fer from Lod airport. On the First of April 1971, Twas promoted from major to lieutenant-colonel, and iven the assigrment which, nore thus amy other, 1d hoped for when [retumed lo the army. Thecame the commander of Sayerer Matkal. 110 Chapter Light It was the same jumble of buildings in the same corner of the base where I'd reported a decade: earlier, is w 19-year-old fresh fom trom, when the siyeret was still a gleam in Avraham Aroan’s eye. Now, | was about to beconie the fist of his successors to have been chosen from within the unit irself. As [ called Together the officers thud First morning, [conldn’t be sire whether | would make 2 Success of my wo years in command. But | did know what 1 hoped that 1, and we, would accomplish: to complete Avraham’s vision. To forge a true special- forces unit, at a time when the threats facing Israel seemed increasingly to demand voe. Aveahan’s initial hopes and expectations for the unit had been more than met, Sayeret Maskal had played the key role im erasing the traumus of Uri lan and Rotem, und restoring he morale nd eectiveress of lsrach nifilary intelligence. Time and again, operations which we said we could do — dismissed as too dangerous, or impossible, by otliers — proved achievable. Yet as 1 now. told the team leaders and our other officers, this was no longer enough, Our intelligence operations still mattered. tu fact, we would have 10 “push further” across Arab borders, deeper into enemy communications systems. Our intercepts had given Israel an important edge in the Six-Day War. 1 assumed though naively. it would tum out = that they would be put to use in any fulure war. But if the sayeret was to reain its unique role, we had to become a fighting force as well. One reason, I didn’t even have to mention: we all remembered our frustration in 1967, when we'd been little more than bit players m the most important contliet sine the csiablistnent of the stare. But for me, the main argument for change was what had happened since the 1967 war: the fact that Israel was facing a new range of security challenges which other army units, tained 0 engage and defeat enemy oops on the balefiekd, were not equipped to meel. Tn the War of Attrition, we might nat have last a single inch of territory. But we hued lost tanks and planes, Jsrach soldiers and pilots were being held prisoner iin Ligypt and Syvia. Araft’s Fatah and the ther armed Palestinian groups might not present a conventional threar. Yet while I'd been with my tank company in the Sinai, they were fighting a full-scale civil war against King Hussem’s army in Jordan. The catalyst: a multiple hijacking in September 1970, a sign that they were turning to nom-copventiond wartare, and ro acts of terror. m “We're not starting from scratch,” T assured the sayeret officers, and 1 could see some of them nodding in agreement. We had a proven record of success, wader Avraham and the four other commanders before me. We would be able to sely on the qualities tha bud proved our doubters wrong in our first intelligence missions. “We have to stay ue to the spirit of Sayerct Matkal,” [ said. Every one of the officers knew what I meant: teamwork. the way we valued brains and creativity, mare than formal lines of authority, The rigor we applied ta training for, preparing for, and excouting cach mission. And, no kess importantly. to criticizing, and trying to fix. everything that had gone wrong: on an operation, or we'd failed to anticipate. Though | expected to be leading miny of the operations myself, [knew that we'd succeed or fail on the strengths of the oflicers around me. [ was incredibly fortunate on that score. Somme, I already knew well from my time as Digli's deputy. Smart, self-confident, self-sturiing officers hike Amiram Levin, the stocky kibbuvaik om the north with whom 1d worked most closely and mest often as deputy. Avshalom IToran — Avsha — who'd convinced me to risk completing the mission on the roud from Suez to Cairo, Gora Zorea, wha, like we, hel come up through the mit and wis one of our most experienced em leaders. And Danny Yatom. Bora not far from Mishmar Ilashavon, bul a city boy. from Netanya, he was smart, level-headed and a sure-handed organizer, and wath whom 1°d somehow held from time he arrived wm the sayerel. [made Rif my deputy for my fist year in command. There were two others as well. both related to Moshe Dayan, but with a self- assurance ull their own: Uzi Dayun, the son of Moshe’s brother, who had been Killed in the 1948 war when Uzi was only months old; and Mookie Betzer, who was married to Uzi’s cousin. I'm pol sure which of the two joined the sayerel first. Mookie, I believe. But their family ties, far from extraordinary. were part of how Sayeret Matkal had developed from the start. 1t had been friends bringing [riends. But also, not infrequently. a cousin bringing a cousin, or a brother bringing a brother. This was the case with two ather officers, whom | knew less well at first but who would become key members of my team. lu heir case, it was the younger one who joined first. Binyamin Netanyahu — Bibi, as everyone called him — had been a member of Amiram Levin's team when [ was Digli’s deputy. He'd also been i part of one of our several thankfully himless failures along the canal at the beginning of the War of Attrition. The plan was to cross in rubber boats held together hy nylon cord, with the assistance of Shavetet 13, lsrael's 12 equivalent of the American navy SEALs. But Bibi’s dinghy got tangled up, and he found himself in the canal, being tugged down by the eucrent. Only the SEALs, and Bibi’s mix of calm and endurance. averted disaster. When | retired ws commander, Bib bid gone through officers” school and was given a team of his own, making him one of half-a-dozen core, operational officers with whom I worked from the planning stages of every mission, through the training und the operation itself. Especislly with Bibi, since he was newest 1o the ral. He was smart, tough and, even by sayeret stundrds, supremely self-confident. Tt also was clear that he understood my determination to build the unit into a military strike force which was one reason why he unzed me to bring in his alder brother, Bibi wis 22 at the time, His brother Yonatan, or Yoni — was 25. Tle had led a company of paratroopers in the 1967 war, before poing off to university. He'd taken a bullet in the elbow while helping to rescue one af his soldiers behind Syriun lines on the Galan, “He wal fo ret lo the amy, and he’s exactly the kind of officer you wan,” Bibi said. 1 brought Yoni in for a chat. Over the next several years, [ would get to know him much better, becoming nol just fiends but neighbors, when he bought a flat a few floors up from ours. But even in this first meeting, 1 found him a contrast to his younger brother. Bibi was practical, detail-oriented. Yoni was a more complex character. He was interested in history, and philosophy, He wots poetry. He would sometimes feel the need 1© get of0 by bimsel(, and just think. Tle was a man of action, too. Taller and trimmer than Bibi, with a thick thatch of dark har swept back from a craggy face, he was the Central Casting image of a soldier. He also hid real, bauleficld expericuce. Nol auly did 1insile hin lo join Sayeret Matkal. T put him in chacge of our Lraining leams. When Danny Yatom left the following year to train as an armored officer. [ made Yoni my deputy. However dillirent in some ways, the Netanyahu brothers were elose. They seemed almost driven, Lo exeel and to succeed. As | got to know them both, | sensed thar the drive did not come merely from within. It came from their upbringing, their family background, ind in particular their father, Beneion Milickowslky, as he then was, siudicd at Hebrew University at the same lime as my father. in the early 1930s. and was an impassioned supporter of Ben- Gurion’s main right-wing Zionist rival, Ze"ev Jabotinsky. My father remembered him gathering bemused groups of students during breaks from classes, standing on an upturned wooden box. and proclaiming thai the Arabs would rever willingly weeept a Jewish state, Long before the 1948 war, and 13 nearly four decades before our caplure of the West Bank in 1967, he insisted that we needed 10 create a Jewish state in all of biblical Isvael: (rom the Mediterranean to the Jordan River. Iwas throngh Bibi snd Yom this 1 got fo know their father. Aller 1948, be had led a frustrating existence. A specialist in medieval Jewish history. hie could not find a place on the faculty ac ITebrew University. [le was convinced, perhips with some reason, tht his outspoken advocacy for Jubotinsky™s Zionism in a country defined by Ben-Gurion’s had frozen him oul. He leit to pursue his academic career in America, where both Yoni and Bibi spent much of their youth. He always remained bircer about what he felt were untair. politically inspired, roudblocks fo his academic advancement in Jerusalem, Though hie would eventually return Lo [sracl, he wes teaching at Coraell when his sons became officers under my command in Sayeret Matkal. So there was a physwal distance between father and sons. But what struck me was how large the father loomed in both of their lives. There was an almost adolescent admiration, bordering on worship. I remember once remarking to Nava that it was as if, despite all their physical self-confidence. Bibi and Yoni were tethered To their futher by some mental umbilical cord. They seemed weighted down by struggle to live up to his expectations, to right the “wrongs” done to him, and achieve the advancement and success which the young State of Israel had denicd him. In poignant postseript, decades Later when Bibi first was elected Prime Minister, Ben-Zion was asked by a journalist for his reaction. “He would make a very good Minister of Hasharah,” he replied, a ITebrew word which translates as something between public relations and propazanda, “Or Foreign Minister.” But how shoul Prime Minister. he reporter pressed. Ben-Zion replied: “Time will ell.” Tiven as we mounted intercept operations deeper into Egypt and Syria. I mide sure that we tamed as 1f we were already the broader stake foree 1 hoped Sayeret Matkal would become. We mapped oul plas for commands operations against the new kind of security challenges the country faced. We worked in detail an how we'd carry them out. We prepared rigorously to make sure we'd be ready. Yet no matter how proficient we got, there was no guarantee it would actually happen. A bit like Avraham in the unit's infancy, 1 had to deal with the 14 frustration of ying Lo convince the generals in the kirva to give us the go- ahead. Some of them agreed Israel needed u specially trained commando focoe. But not everyone felt Sayeret Matkal could, ar should, take on that rale, Rafael “Rafi” Filan wis perhaps the most sivident. He had Gought with the Paluch in 1948. Tle was an officer in Unit 101 and a commander of the pacachuists’ Battalion 890. Ile was now faizhur, in overall charge of all infantry and paraicuop focees. Le insisted thal such work required a real sayeret, by which Tie meant the paratroopers. Yet the need foc a special-forces unit was becoming increasingly hard to ignore, By the summer of 1971, w couple of months after 1 became sayeret commander, King Hussein's amy had defeated the insurgency of Fatal and a pair of even more militant partners, the Democratic Front and the Popular Front for the 1 iberation of Palestine, That meant a quieter easte frontier. Aut the Palestinian groups rebased across our northern border in Lebanon. When Tordenian Prime Minister Walsi al-Tal was assassinated, it proved to be the start of a series of killings and terror attacks by a new eroup within Fatah. called Black September. There was at least some potentially encouraging news from Leypl. When Nasser died in September 1970, he was succseded by a less flamboyandy militant vice-president, Anwar Sadat. Yet in both Teypt and Syria, a number of one sie force pilots were still being held prisoner. 1 fell an especially strong motivation to help bring the pilots home. They had sisked their lives for us. Tt seemed to me we owed them the same. One of the men being held in Syria, Pini Nachman, had i personal connection to many of ws in the unit. He had worked with us on siyeret missions. | came up with # plan that, while undeniably risky. seemed w me Lo have every chance of success. It was to abduct a uiber of Syrians from an officers” club on the western edge of Duss. Wee world lane in transport helicoplers Rew miles sway and unload a paic of armoced cars captured in 1967. But Raful's view prevailed. Teould not get the approval of the Airy. I did take heart from Avraham Arnan's support. He wis now Golds Meit's connler-taarorism adviser. Also from the fet that Chaim Bar-Lev’s suceessor as chil of stall was an old fricad of the sayeret: Dado Dlazar, Avraham’s Palimach comrade from 1948. Yet winning over the remaining doublers in the kirya was abviously going to fake time As so oflen duving my years in uniform, Jowever, Sayerel Miatkals bitth us a special-forces unit came by force of circumstance: not in an officers” club near Damascus. but a few miles iway from our base, on runway at |ad Airport, 15 PE Twas sitting: down to dinner with Nava a litcle before seven on May 8, 1972 when the phone ring, We'd just fed Michael, who was almost two, full of energy, and showed a0 sign of wanting to 20 to bed. “T's Manno,” said the voice on the line. Brigadier General Emanuel “Manno” Shalced was Dada’s chief of aperatians. “A plane has been hijacked,” he said. “It’s heading for 1 od. Twill land in about 30 minutes. They've got hostages. Gel to the airport. Dado and Dayan are on their way.” 1 called Danny Yatom and told him to et whoever was at the sayeret base to Lod as soon es possible. Bul must of Lhe men were on training exercises, including one team with Yoni deep in the Negev Desert. Ile immediately began calling them back. When I got to the airport, I found Dayan and Dada huddling in a soom below the control tower, unfurnished execpt For a small table iu the comer. Talik was there with them. Tle was now head of all military operations in the kiryu, Rechavam 7e”evi as well, the head of the central command area, which melded Tel Aviv, So was Ahrahle Yariv, who had succeeded Meir Amit as head of miliary intelligence, and nodded glumly as 1 joined them The plane had landed. A Sabena Boeing 707 bound from Brussels to Tel Aviv, it had been hijacked fier i stopover in Vieni All we knew al this point wees that the hijackers were Palestinians and that there were about a hundred passengers on board. Dado said that, while we figured out how to respond. we had to make sure, at all costs. the plane didn’t take off again. It would presumably go to an Arab country, where we'd be powerless to ac. Though only a handful of my men had arrived. T took the only officer who had. Shai Agmon, and an E1 Al engineer to see whether we could disable the hijacked jer. tt was parked well off fram the mam terminal arca, With the El Almian leading the way. we approached fiom the rear, crouching low, hoping the hijackers wouldn't spot us. The engines were still running, but at least the deatening noise kept amyone from hearing us us we ducked under the fuselage and the engineer removed a stabilizing pin from the font wheel. It was an eerie feeling, envisaging the captive crew and passengers, and the terrorists, a few feet above our heads but knowing we were powerless to do anything mare fo help. Manno hue called me not because 1°d won my argument to expand the role of the sayeret. It was the luck of the draw. With the growing threat of terrorism. the inva bid drawn up a list of installations which might be targeted. Next to 116 cach, they'd put the name of the military unit 10 be called up in an emergency We'd been allocated Lod Airport, because our base was just 15 minutes away. Sill, as | accompanied the engineer back fo the control tower, [ tried to work aut in my mind whether we could plan, prepare and iain quickly cuough to mou an operation 10 free the plane later that night. More than a dozen members of the unit had now arrived, and more were joing us every hali-hour or so. | areanged for EI Alto give us hangar and a 707 identical 10 the Sabena plane. Shai, Danny Yatom and 1 wok two airline technicians with us for a closer look ar the Boeing. We studied up on ic as quickly as we could, beginmimiz with the cockpit and the front door, which we saw was 100 high 10 reach without a large ladder. But making our way back, we realized the wings weee low enough to climb ou to. When, with the help of Danny, [elambered onto ane of them, 1 managed to get ane of the emergency. doors Lo open by banging hard on the top ead with my open fist T asked the technicians whether we could expect the Sabena doors 1 give way as well. Yes, he said. but he cautioned me that on some airlines. there were passenger seats next 10 1 least one of the hwo doors above cach wing. Walking up inw the cabin, {ried 10 work out how we might attack te hijackers before they were able to harm the passengers. or us. The risks were obvious, But | felt we had to be ready to uct, With the rest of the sayeret shill making its way 1 Lod, [ put Dauny in charge of briefing the new arrivals, familiarizing them with the 707 and preparing for the possibility of an assault operation. | alsa fold him to get hold of a couple of dozen small, 22-culiber, Beretta pistols. | eouldu’ see how we'd manage 10 make our way onto the plane with Uzis. We knew we'd have 0 get up Lo speed quickly on using the Berettas. None of us had trained on them. But many of the air marshals on hoard El Al Mighis were Suyeret Matkal reservists, and they did use Berets. [old Danny 10 cheek for any sayecel marshals acriviog on Tl Al Oights and get them 10 join us. As headed buck 10 see Dido, we were nowhere close to i detiiled plan on Tow 10 contront the hijackers. Nor did we have any orders. The people who would give them — Dado, Dayan and ultimately Prime Minister Meir — were still dearding how to respond. But when 1 reached the control tower, at about 9:30pm, the order came, if not 1o mount an operation, at least 10 make suse the sayeret was ready. “Talk to Talik.” Dado told me. “See what the options are to tuke aver the plane if that's the decision.” 1 sat down with Talk and ran through what I'd learned (com my brief look at the hijacked plane and the work we'd 17 been doing on the Israeli 707. told him I'd need another two hours 1 make sure my mien had practiced climbing up on the wings and forcing open the doors, and another hour for preparations and briefings far the teams who would he participating in the operation. “By about hall sn hone aller midmght, we'll be ready to deploy,” 1 said, though from his stoic, neacly silent response [ couldn’t be sure whether he was in favor of an assault. “By 0100, we'll be ready to act.” Both af us went back fo see Dado. He seemed encouraged, especially when 1 said we'd be ready W move by one in the morning. He told me the pilot of the plane had been in contact with the control tower. He was an RAF veteran and. though the terrorists seemed tmaware of this, he was ulso Jewish, The hijackers were demanding more than 300 Avab prisoners be released and flown tw Cairo. “And they seem quite nervous.” Returning to the hangar, [ sent Shai Agmon with tour soldiers to set up a Tookout ned sniper post about 70 yards lo the side of the Sabena jel. {old him not 10 open fire unless they were sure there had been shooting inside the plane and could positively identity an anmed hijacker, By now. we had three dozen soldiers and officers, melding Uzi Dayan and his full team. 1 ook all those whe were already bricfed and divided them into four groups, cach with an officer and five soldiers and assigned to deal with one of the wing doors. I left the others fo contmue training, When mricdnight vme, [sas far from certain we could meet the 12:30 um deployment target I'd given Talik. Incoming flights had stopped for the night. and we still hudn’t managed to bring in any aie marshals, | believed they would give us a crucial advange. They knew Berets. They also knew the inside ofa 707. But 1 was worried about losing Dado’s trust in a sayeret operation if we failed to meet the timeline. From Shais lookout post to the side of the plane, | lead that the front cabin door of the plane wis open. He suid he'd seen a couple of hijackers walking by iL. silhouctted by the dim cabin light But otherwise, there was no sign of activity inside, 1 called Talik and told him [ was fuking my ussault leams 1o the ares behmd the plane. About a half-hour lier, 1 contirmed we were ready to begin the operation. Although the planc’s engines were off now, our approach had been masked by the drone of the generator brought in to supply power to the cabm, We were lying face-down on the tarmac, directly hehind the tail of the plane but well back. 1 wo rows of 12 men, plus me and a soldier in charge of the communications. We'd brought along. four small adders ta help us nto the wings, “We want ta exploit the darkness, and the sound of the generator, to cover us.” I said in ny final briefing before 18 we'd le the hangar. “I they realize we're there, we pet into the cabin as quickly as possible, any way we can. The first five seconds will ne critical. Act decisively,” | told the men, “Assume that everyone else will be doing the same, Trust your instincts. You arc trained for ts. But more than an hour passed as we wailed for the green light to storm the plane. My main concern wasn't that the hijackers would see us. There seemed little rensan fo beheve ane of them would suddenly decide to take a walk in the idle of the night. But sunrise was around five in the moming, and there was no way [ could see mounting our assault in broad daylight. If we didn’t get the go-ahead soon, the chince would be lost, 1 culled Talik several times, making he point that it we were going to do it, we needed to nse darkness is an ally The sayeret was a breed of night animals. Other people, even terrorists, would be less alert and effective af night, But he kept saying he needed more time. Finally, an hour before sunrise, he called bck. “The big boss 1s on bis way,” he said. [lef the others and crept back to meet fhe Defense Minister, a good eighty yards from the plane. Dayan greeted me with a whispered hello. Ina way, his wrraval reminded me of my firs! opecatian in the sayeret when, before leading north w the Golan, I'd been summoned w brief Uzvi Uzur, the chief of staff. Tzur had seemed less interested in the details than in contirming that / was confident the mission would work. Dayan, of course, had ss much operations | knowledge and experience as anyone in Israel. Yel it seemed wo me that he, oo, wanted to satisfy himsell"that T honestly felt we were in a posilion to succeed. Especially, though he never so much as hmted at ths, because two of the officers [wonld be taking in with me, Uzi sud Mookie Betzer, were members of his family. “Tow do you plan to do it?” he asked. [ explained how we would get into the phic sinuluncously, in Four isms, and confront Ure hijackers. | said [was conlident we'd succeed, especially since darkness save us an clement of surprise. and the terrorists were bound to be tiring. “We can do it,” I said. “Better now than in daytime.” Dayan merely nodded. He staod there, silent, for another few moments, “Ill et you know,” he said. the shook my band and requrned to the control tower. But fifteen minutes later he sent his reply, via Talik. It was brief and explicit: “Not tonight.” Far the first but not fhe last time in imiform, 1 felt the frustration of finding my preparation and judgement eumped, without explanation, by a decision from above, When [ got back to the control tower, | made no attempt to hide my view we should have moved against the hijackers while we had the ehance. Bul 19 Dado sat me down and filled me in on whal was obviously a hanging situation Tle said the terrorists had allowed the pilot, Reginald Levy, to come see Dayan and press their demands. He had brought with him a slab of Tight-yellow mnterial fo demonstrate the serionsness of the risk of saying no. When tested, ii turned out lo be exaelly what the hijackers said it was: plastic explosive. The pilot said there were four terrorists: two men with pistols and two women with explosives and grenades. There were 95 passengers and seven crew. He'd also confined that none of the exits above the wings was blocked by a passenger seat. He'd returned to the plane without any clear answer from Dayan on the prisoner release, But before leaving, he revealed tht his own wife wees among the passengers. He asked Daya fo promise that Israel wonld help care for their daughter if the hijack caded tragically By the next moming, that was looking mare and mare likely, Though the Iiickens were still in contact with the tower, the only visible movement wis the arcival of a wepresentative of the Red Cross. The lead hijacker, who called himself Captain Rifa’at. was making increasingly forceful demands for the prisoner release. Our negatiatmy team did its best a buy me by giving the appearance we were considering Lhe demand. 1 was Dayan who carne up with the idea of going further. He told Rechavam Ze'evi. as the head of the central command arc, to begin rounding up hundreds of young (srachi reserve solders. He wanted them dressed them in prison uniforms. aud then bused Lo the aispor, within sight of the hijacked jet. Dayan also acranged for another Boeing 707. ostensibly to take the “freed prisoners” an to Cai, “What then?” Ze'ev asked Dayan. “We're not sally going to put them on a plane and take off!” [twas after he'd had no real reply that he in effect answered his own question, inadvertently leading us to the idea of attempt a daytime attack after zll. Talking to Dado and me. he said: “Since we re going to such lengths to deceive them. why not just add another layer? Why can’t Ehud’s people take the roll of the uimort mechanics?” | ooking af euch other, Dado and | realized it was a stroke of brilliance. Dado went to share the plan with Dayan, confident that he would be no less enthusiastic, which he was. 1 remained with Ze'evi and is deputy to work our the details, We agreed they would take care of the pantomime with the prisoners, is well arranging for kl Al to gel us the ladder trucks that airline maintenance crews used, which would allow us access to the Sabena jets front and ver doors is well. That lefl me free fo concentrate on preparation and training. 120 We had just a few hours to adapt the original plas. Alliough we'd trained in close-quarters fighting for my plan to attack the officers’ club near Damasous, wed never had to use that skill in a live mission, Nor had we ever used the Herel. While we'd disguised ourselves is cremy soldiers ov miliary police an our intelligence operations. this would be the first time we were taking on the persona of civilian engineers. with the need to fool armed terrorists on the lookout Coc any sign of danger or betrayal. And for the first time in amv of our major operations, we would be operating in daytime Now that nearly all our soldiers and officers had artived, 1 began arranging the final line-up of attack teams, We would need six rather than four, since the now pln would give 1s access to the front and sear doors. Damy now also told me that a couple of the [1 Al techaicians liad shown him a way of climbing up from imside the nose wheel info the cockpit, One of the foughest und strangest of our soldiers, Ui Koren, had tried it successfully on the EI Al 707. 1 wld Denny, Uri and another officer that they would be assigned to attack thcough the front door and the nose wheel. I puc Uzi Dayan in charge of the tail door. The emergency doors above the wings, however, sill give us the quickest way in. 1 planned w command the operation fiom the left of the airerafl, because both the front and tail doors also faced that way. I entrusted Bibi Netanyahu and his team with breaking m through the main wing door on the fav sade of the plane. By noon, we got a further boost. With the resumption of incoming flights. we began collecting air marshals. One in particular raised my confidence. T knew Mordechar Rachamim well from the sayeret, He was a Yemeni Jew from Elyakhiin, the moshay near Mishmar Hisharon where Baddura and the other Yemeni workers lived. Tle was tall, strong and athletic, nawcally agile and quick to respond in situations of danger. He was also no ordinary air marshal. In 1969. hed heen posted on an EI AI Might From Amsterdam lo Tel Aviv. On a siopover inn Zurich, four gunmen from Fatah's main sadicel rivel in the PLO, the Popular Front for the Liberation of Palestine, leapt out of a car, opened fire with AK-47s and begin throwing grenades. The PEP assanlt mired fon of he crew and Killed the co-pilot. Armed with his Beretta, Mordechai custied to the cockpit window and returned fire. Seeing the attackers were oo far away, he slid down the emerzency chute. Once on the tarmac, he shot one of the ferorists in the head and kept the rest of them al bay. As additional air marshals arrived, T slotted cach of them into an assault team in place of ane of our sayeret soldiers. The next fo amive was Viareo Ashkenazi, a Cairo-born veteran with whom I'd worked on a mission inside Teypt. T put 121 Mordechai on the main lefi-side wing, door, critical for the apening momeots of the assault, and added Masco to Bibi's team on the other side of the airerafl It was then that Yoni arrived back trom Negev. He insisted on being added 10 one of the assiult teams. I one respect, that made sense. He had more battlefield experience than almost everyone in the unit. But there was an unwritten sayeret rule never to place two brothers together in the line of fire. Es 100 late,” [old him, with in arm an his shonlder, “Bibi has already been training his tam.” He went off 10 find Bibi. [ thought there was little chance of Bibi sanding down, but didn’t feel 1 could stap Yoni from trying, Five minutes later, they came to tall to me, Bibi said: “Yoni wants fo replace me, We want you to decide.” | nssumed both of them knew what ['d say. **Fodkay., it’s Bibi,” seplied. “But Youi, this is not ouc last operation. T will make sure you are there the next time.” The last marshal to join us was i tall, thin redhead we always called Zur. Led had only 15 minutes w begin taining when | got word that Dado — along with Ze’evi and Ahrahle Yariv were on their way to see a run-through. As they filed mio the hangar, 1 quickly explamed the operations] plan, 1 showed hem how we would push in the wing doors in, and then ushered them inside the 707. Two minutes later, the emerirency-daor teams climbed on to the wings. When | give the agreed bwo-fimgzer whistle, they stormed the plane, “OK, gentlemen,” Dado old the team leaders when it was over, "We've seen what we needed.” Before returning to the control tower. however, he took me aside. “You know they have explosives, night!” he sand. When 1 said yes, his tone soflencd. “You don’t have much ume, Ehud” be said. “Don’t wasie i. Bellarzlakha.” Good luck. We still had to outfit ourselves in mechanics’ overalls, and swap the sayerets paralraap-sty le red bats for black ones. | dieoted al the men lo canceal the Beretias on a waist-bell inside their overalls, We got acquainted with our mechanics” toolboxes, Finally we organized our maintenance matarcade: four electronic buggies in front, towing four ladders, two short ones Tor the wings and taller ones for the front aud rear doors. Waiting lov the veder fo move. I'said a final few words. Secing the determination and nervous anticipation on the faces of the men around me, 1 began by reiterating that the first five seconds would be critical. “We all kuow that nothing ever happens exactly according to plan. Gach and every one of us has to focus on speed, ‘momentum and precision, No ene can wart far anyone else fo act, From the moment T give the signal, or if we come under fire, each am has 1 act as if 122 they have to accomplish this all on their own. AH of us must assume that. Keep cool. Stay focused. Rely on your instincts. We're ready for this mission. And we are going to achieve it,” One mnie after four in the aficmoon, we gol the word 10 go. [was m the lead buggy. consciously trying to look like a civilian, not a soldier. It was about amile-and-a-half to the aircraft. 1 glanced back at the others. Like me. many of them had been awake for 30 hours or more, in some cases neirly 48 hours, The air marshals had been plucked off long-haul Mights on which relaxation, much less sleep. was not an option. As before any mission, [ knew everyone would be thinly about whit was about fo happen, They also realized that if we failed, the passengers trapped inside the plane would be at the merey of errovisis armed with AK-17s and explosives. But I was confident thal any apprehension would be overtaken by adrenalm when us the assault began, As we got closer, Shai Agmon radioed me. He sand two or three people, nol ihe terrovisis, had come out of the plane. One seemed Ww be the Red Cross man. They were about 120 yards away trom the aircratr. As soon as he'd signed off, 1 got word from the commind post in the control ower thal 11 was indeed the Red Crass representative, along with two of the ight crew. They'd heen chosen by the terrorists to do security checks on the “maintenance” men. [brought the convoy to « halt, The Red Cross man gave each of us a fairly cursory body seinch before waving us on. Then, ie gol w Bibi. Though | hd somehow failed to notice, he had left on his red saveret boots. In [srael, that was the equivalent of a neon sign saying: “1 am a paratrooper.” Although the Red Crass man noticed the boots, he al first made no comment. Then, rolling up the pants leg of Bibi’s overalls, he saw his Beretta — not inside his waistbelt, but inside the boat. The next thing 1 heard was an angry spurt of French as the man culled the control wer. For a moment, | feared the mission was aver, wilh potentially fatal copereussions for the hostages. But whatever explanation the Red Cross man was given presumably by Dayan himself, who would not have held back in conveying whit was at stuke it dissuaded him from fuking funber action. As we were Ieturing 10 the buggies. the Red Cross man told me that “Captain Rifa"at”™ hud ordered us to pull up to the generitor on the side of the plane. Eich of us would then have wo walk forward and open the front of our overalls so he could make sure we weren't armed. 1 passed back four orders to the rest of the men. Fist, with no exceptions, move your pistol fo the ack of your belt. Second: 11] be the first 0 ga through the inspection. Third: watch 123 what T do and do the same. Tinally, if our cover is broken, or il you hear uafice, we all storm the plane. [ tel as | always did as an operation was about to begin. Along with the tension, I had a keen swarcness of cverylhing happening around me, almost is if was watehing things iu slow motion, in high resolution. When our motorcade approached the generator, Rifa’ar leaned out from the co-pilor’s window. He wits pointing a pistol at us. He seemed to be in his late 205 or carly 308. He had dark hair and a moustache and the hint of 2 stubbly beard. We stopped beside the generator. 1 got out and walked toward the cockpit, halting about 10 feet away, Looky up the hijucker, [ made a conscious effort fo appear curious rather than worried. His eyes seemed a mix of intense focus and tension. Topened the front of my overalls. Because of the heal, T was wearing nothing else on ron, He nodded his head ro sigmal he wus satisfied. | refastened the overalls and moved off. One by vue, the other men passed inspection. Then we went back and brought the two smaller ladders to the side of cach wing. and the “mechanics” set down to work. I delayed bringing in the large ladders so as to sive any visk of arousing (he terrorists” snspicions. “The fie that at least so far they seemed Lo suspeet nothing was in large part down to Dayan’s misdirection plan. As we began working on the plane, the “Pylestmian” prisoners were disembarking from buses about 300 yards awiy. As Rili'at watched, several hundred men formed long rows, A few of them waved in his direction. The Boeing which was theoretically going to take them on to Cairo, to be followed by the Sabena jet mus the hostages. was being Towed ino position. One by one, our assault teams were moving into place. All that remained was for me to give a short, sharp whistle and the attack would begin. Yet just as 1 was raising my fingers to my mouth, [saw Bibi coming toward me from wider the fuselage. Le motioned 10 me 10 wait. Zur, the last of our air marshals, had a prablem. Having spent 10 hours in the air on the way back to Israel, before being mediately plugged into wn ussuul lea, he had something to attend to, “Ue has 10 lake a shit,” Bibi said. Can’yit wait. | asked. No. was the auswer. So Tsaid OK. leading to the most surreal “operational” moment T would witness duringz ull my years in the miliary, The “prisoner release” was now in full low. Dozens of military vehicles, and a small army of fire engines and ambulances, had also pulled to the far end al the tmway, ou of sight of the njackers, in cise our attack on tie Sabena jel went weong. Tel Aviv hospitals were on ake. And Zur was crouching and 124 selieviog himself. Te nodded in gratiwde when he'd finished. and returied to Bibi's eam on the far wing. 1 gave him a full minute to be certain be was in plice. Then [ whistled. From my fuitial position beside the plane, | saw Damy Yatom and his team begin to move onc of the tall ladders toward the front dour. Shifting my eyes toward the wing doors as the “crucial first five seconds™ ticked by, | saw both the ones on my side of the plane were still shut, 1 elimbed wp on the wing. When 1 got to the smaller, rear door | saw the main one cave inwerd and Mordechai Rachamim rush in. Bur the soldier on the other door was trembling und frozen m place, 1 slapped him, hurd, on the back, “Move!” 1 shouted. Instantly, he pushed the door in and rushed inside. 1 then noticed Uz and his team had still not entered from the reac. T jumped fom the wing and ran toveurd the ladder at the back, but by the time | got there, they had made it inside, and I followed them in. Liverything was over within 90 seconds. As I'd expected, the planning and training fumed out to matter less than instinct and initiative. Within seconds. Uri Koren managed lo get info the nose-wheel assembly. Though he couldn't dislodac a metal-mesh panel separating it from the cockpit, he spotted the outline of a man’s foot above him, fired, and wounded Captain Rifa’at. The other members of Dany’ feam in front were less lucky, With the ladder, they had vo trouble getting to the passenger door, but they struggled to fore if open. When they did nudge it open a crack, one of the hijackers opened fire, slightly wounding one of the men and forcing them to abandon the attempt, Mordechar went in shooting, bul immediately drew fire and had 10 retreal. But Omer Wachman, another air marshal I'd posted on the far wing. was ina couple of seconds later. Coming face-to-face with one of the hijackers, he shot Him in the head. That ullowed Mordechis 10 gel bck side. He quickly exchanged fire with the hobbled Captain Rifa’at, hitting the hijacker in the side As Mordechai ducked down to reload his pistol, Rita’at managed to lock himself inside one of the toilets nei fhe cockpit. Mordecha rim aller hin, He fired through the bathroont dour, then kicked it open and confirmed that he was. dead. Rushing back toward the center of plane, he spotted the main woman hijucker, wearing a bulky explosive vest. Grabbing her hands, he reached mide the vest and yanked oul the batlery pack. With two of the lijackers aleady dead, Mordechai had now subdued the third. But knowing that there was still another woman unaccounted for, he handed her aver to Bibi und Marco Ashkenazi. Bibi grabbed her by the back of her hair, but it ued out to be a 125 wig. which came ofT in his hand. As she began sercaming, Marco instinctively struck her across the face, but be used the hand in which he bad his Bereua. The gun went off, and the bullet grazed Bibi im his upper arm. When Uzi Dayan had finally gol in thiongh the rear door, he'd run up against a stocky, suntauned ma blocking in his way, and fired — thank fully, only into his midsection. He rumed out to be one of the passengers, a film- muker from Austria, SHI, there was the other woman hijacker to deal with, Several of the passengers pointed w the Moor just shead of Uz, where she lay curled up. holding a grenade with the pin out. Ordering her loudly, stemly, not to move, Uza wrapped his hand over hers, extricted the grenade from her mis finger by finger, weplaced the pin, and bid one of his men lod ber out of the: plane and down the stairs. All the hijackers had been either killed or captured. Tragically, in the initial crossfire, u 22-year-old passenger named Miriam Tlolizberg. had been hit. Although the man whom Uzi had mistakenly shot recovered, she did not, Yet all of the remaining passengers and crew were now free and safe, ahve and unbiamed. lela mix of emotions when it was over: pride. a sease of achievement against all the odds. And huge relief at having succeeded in ending the ordeal of the captives. Without my saying so. everyone in the um understood that ny inaugural comments as commande, abou our need to become a fill special- forces unit, were no longer a distant wish. Still. T kuew this was only one step. and 1 wanted to make sure we kept our feet on the ground. The day after the Subena reseie, Israch newspapers devoted ieres of newsprnt (0 how the operation had succeeded. Since Sayeret Matkal's existence was still an official secret. the headline writers called us, variously, a “special” unit. a “select” unit and even m one cise, becanse of our KI Al coveralls, “angels in white,” We did, briefly, celebrate hack al the suyerel base. But is with every other operation, we went through a self-critical assessment of what we could have done better. Tow, if we hud to do anather hostae-rescue operation, could we make sure none of the passengers was haned? How could we improve co-ordination umong he assault leas? And mininiize the risk of shooting each other. Why had I, as commander of the operation. had to wait for someone ¢fse to suggest the idea of disguising ourselves as airerafl Ieelmicians? And why had we Fiked 10 rin with Bereuas and other pistols as well as Ukzis? 126 They were nol just academic issues. Tven if we were never again called upon to fee a hijacked airplane, [assumed we would fice other operations which were equally urgent, without the weeks or even months of preparation we'd always insasted on in the pst orn Aller the Sabena operation, [emphasized the need for us 10 be proactive. It wouldn't be up to us to decide which operations to do. But it 1sas up to us to tuke the initiative m identifymy and onderstunding specific threats and framing watys in which we cond provide « response, Fven before Sabena, barely two weeks had gone by when [ didn’t go to Eli Zeira, who was in charge of the operations department of military intelligence, with a mission which 1 felt contin we were teudy lo vey out. Sever] of the most complex eontered on the new threat posed by Palestinian groups in Lebanon. Before the civil wer in Jordan. King Ilussein had accused Facah, the PFLP and the equally militant Democratic Front for the 1.iberation of Palestine of frymy to create “a state. within a state” and deliberately weakening bis government. Now, they were doing nruch the same in Lebanon. Their headquarters buildings in southern Beirut were spawning hijackings or terror attacks. From bases in southern Lebanon, the Palestinians wore also firing Katyusha rockets into Israel One of the operations T planned targeted Arafat. From our intelligence intercepts. we knew that a day or two after a particularly intense clash with Israeli artillery units on the Lebanese border, he would four the urea sud meet with his commanders. Tf we were going to go aller him, however, we needed to know exactly when he was coming. Formunarely, the Lebanese authorities feacked Arafal’s motoresde on these “review the oops” excursions, reporting hove many cars were involved, which oe lie was in, and their progress. Thanks to previous sayeret missions. we could listen in. In order to ensure the operation would be on aur terms, [ propased that a couple of days before we planned to move, Lsracli artillery target a Fatah rocket site in an isolated acca about tea miles from the border, where there was just a single road in from Beirut. 1 prapased landing several teams by helicopter the night before. We would lie in wait mt] the Lebimese army checkpoints reported thal the Falah convoy wis on its way. Tsraeli helicopters and T-1 jets would then cut off the road on both. sides, and we wonld ambush Arafat's veel. 127 When T wok the plan to Eli Zeire, he was reading an issuc of the Freach newsmagazine | Zixpress and snacking on salted almonds from a dish on his desk, As 1 can through the reason we'd come up with the plan the boureoning power of Arafat and Fauah in Lebanon — he peered al me over his reading glasses and nodded. As [set out the details of the attack plan, he listened, with 10 abvious sign of approval or rejection. But after I'd finished, he dismissed ic out of hand. Ie said that Arafat was no longer the battlefield commander whose forces had fought Israel in Karameh, “116° fat 116s political > be said. “Lie is not a target for this kind of operation,” After the Sabena hostage-rescue, Dado and the other senior officers in the Kirva did seem more receplive Lo on ying lo initiate operations, especially the plan to seize Syrian officers and trade them for the Tscaeli pilots. But such a ‘mission required not just military or intelligence upproval. Dayan, and possibly Golda as well, would have 10 sign off. and there was litle immediate sign of that. But, once again, events on the ground would fosee the issue. Early on the morning of June 9. cur intelligence intercepts gave us notice that the next day, a ronp of senior Syrian officers was omy fo make an inspection visit io he eastern part of the Lebanese border arca with Iseacl. We would have to move quickly. Within the space of 12 hours, we'd need to plan the attack, organize, caquip snd brief the assault leans, mike the three-andei-tiali-honr drive north, and ecoss into Lebanon. Still, T was determined 1o ry. which marked the start of twa of my most frustrating weeks as Sayeret Viatkal commander. The place where we planned to abduet the Syrians was an arca knew personally: the sparsely scitled strip of land where Lebanon, Syria and Tsrael met, not fac from where I'd helped “capture” several Syrian villages on the final day of the 1967 war. With the convoy expected to pass through the nest moming, we crossed the border a Hite before midnight on June 9. We lay in ambush in dense vegetation a few meters off a curve in the road. further reducing the time tae Syrians would have to react ance they sw us. [stationed two other sayerct leas a ew hundred yards sway in cither dircetion, so they could cut off the road onee we attacked. But as the convoy was approaching, T was suddenly contacted by the sayeret officer we'd stationed in the command post back in [sracl, He relayed n message from Motta Gur, the head of the northern command. Jis intelligence unit suid there was a Lebanese Army checkpoint a quarter-mile from the ambush site. Mota lrimsel (was m the south, wiih Dado, watching a tink exercise. So | had no way of talking to him. 1 replied through the officer in the command post. 128 “Tell Mola we know about it.” [said. “We've planned for it. 1's not a problem” 1 figured there were at most four or five Lebanese soldiers manning the checkpoint, The las thing they'd want to do is et invalved in a firefight between us ind the Syrisms. But Motia’s reply was unequivocal. The mission was off. When we'd climbed through a bramble-filled ravine back into Israel. Tlefta messige for Motta. [found it hard to chsguise my frustration, and my anger, at being ordered w ehort the aitack. specially iter my assurances that the Lebanese roadblock was not a problem. Yet when we got back to the sayeret base, | realized there was more to his veto than I'd thought, He and Dado had recived intelligence saying te Syrians wore likely to make w serics of further inspection tours of the border area, so this would not be our last chance. The next day, we received word they’d be touring the western part of the border an June 13. On the Lebanese side. it was koown as Ras Nagoura. on ours as Rosh Tlanirkea, where the Mediterranean coastline rose dramatically w a ridge and. once ino Istael. sloped steeply down apain toward Ilaifa. Ltook m two mein assault teams, one led by Mookie, the other by Uzi Dayan. We hid in a tangle of bushes about halfway along the road which climbed up toward the border ridge. 1 stationed Bibi and his team at the bottom of the rod. equipped with Uris and rocket-propelled grenade kumehers, We waited, knowing that we'd be abl 10 see the convoy as it twisted its way up toward us. Again. [ had no direct link to Motta. Yet both he and Dado were following the mission from a commind past m northern Iseael. We were m nearly real-fime contact through a sayeret officer, named Amit Ben-Hom, right across the border. A first vehicle appeared at around 10:30 in the morning. Bibi radioed us. It wats a | ehanese amy armored ei with a smh machine-gun, 1 drove pst snd Talted 130 eet on, at the point where ie road began ww climb. The two guys inside took out a small table and a couple of chairs and began brewing up cotfes on the side of the road. “All OK. | said when | radioed Amit to fell him, “Pre- deployment.” The couvoy arrived twa hours later and began Lo climb. “We're taking it.” T radioed Amit. “Wait.” he replied. And us | kept pressing him for the final go-ahead, another 30 seconds passed. “Nat approved,” he finally barked back at me, clearly wanting to make sure I got the messiige. 129 “What the hell is going on?" T replied, in a mix of a shout and a whisper, since [ knew the convoy was geting closer. But within a minute, we spotied the lead 1.and Rover, which was soon past us on the way up to the ridge. It was followed by tor large Amica cans, with the Syrian officers, and then i tailing security vehicle. IL was 100 Jae. was fuming. The convoy had passed within a couple of yards of us, moving slowly because of the incline. But, segaining my composure, [realized we'd get another upportunity, when the alficers returned from ther inspection visit. We now kuew exactly how the convoy was deployed, and with any Tuck, the security men would be less alert by the end of the day, Even better, it would be beginning; to yet dark, perfect conditions for the ambush. But as we were wailing, Amit radioed me with a question [rom Irom Dado and Motta. “Where's the armared ear?” It's still there, at the bottom of the road, Tiold them. “But theres nothing it ean do.” Bibi and bis team had it in theic sights. T considered aot telling Amit what happened a few minutes later: a Lebanese shepherd, with a halt dozen sheep. stumbled on us. One of Uzi's men, fern fn Arabic, ed the startled man’s arms behind his back, seaticred the sheep. and told him: “11's fine. Another hour or so, we'll be gone, and we'll let You go.” It turned out to be less than an hour. Forty-five minutes. During which. not one bul twice, Amit fold us that Dado snd Mott were wormed: shoul the armored car aud now about the shepherd. 1 assured hin everything was fine. We'd do the operation. The guys in the armored car would be helpless. If all went well, they might not even know we'd intercepted the convay. The shepherd, like us, was just waiting for iL 10 be over so we could all go homme. Minutes later. Amit called again. ITe told us the convoy was on its way down. But barely 60 seconds later. hie said: “Its off. Don’t do it. Dada told me to repeat i twice $0 you'd understand: do nor do the operation,” When we got back to the command post. not only were Dado and Motta there. Since Motea was within days of leaving to become Israels military attaché fn Washington, they'd been joined by his successor as head of the noctheen command, Yitzhak of. Three times, [suggested 1o Dado that we speak without my officers present. 1 did not feel it was right to have Uzi. Mookie and Bibi hear me the generals how | felt. But Dado insisted there was 20 reason for them w leave: “This is a serious issue.” I said. trying to keep my emotions in check. “What happened out there is uniceeptable. An effective specia-forces unit cannot operate this way. For the second Lime ina week, you've made us stop an 130 aperation. Both limes. it was a0 operation that we, the ones who have to do it, Kaew could succeed. Au operation on which the fate of three Iscacli pilots depends. One of whom we know personally, and have worked with, Now, agin, with no veal reason, you've stopped is. | sec this is o brech of rs,” When acither Dado nor Mola replied, [went on: “1 have to tell you openly. You can't possibly judge the situation on the ground. Only we can. And you're behaving as if you Anew. You can’t know from here. There was no reason for us not lo grab those officers. [ don’t want to reach a point when [have to start thinking about what to report back, or not report, just to make sure we're free fo complete a mission that you ordered, after agreeing it was necessary for [srael.” Noone said anything for a ow momen. | coukd see thal Uz, Mookic and Bibi were shocked au having heard me speak in this way 10 three of the top. communders of the armed forces. But { meant every ward, If Sayeret Matkal wes to function as a special-lorces uni. il needed to have the trust of those who'd authorized an opecation in the first place. Tt was Dado who finally replied. Sort of. Trying to defuse the teasion, he told us a joke from his Palmach days. “There are two bulls who come info a field full of cows. A young one wd ald one. The young one says to the old guy: lets sun aver thee to the far end of the field. where the prettiest cow is. and we can fuck her. The old bull replies: “Nomeed to rush. |et’s go slowly, and fuck them all.” guess we were meant Lo be the young bulls T doubt Dado knew whether we'd get a third chance at the Syrian officers. though I'm sure he haped so. A weel later, we got word there would be a final inspection visit, lo the central sector of the border area. Oudinarily, {would live led the operation. Novw. I made an exception. To Dado’s abvicus surprise, I decided to remain behind, in the command post. “A commander has ta be in the host phice fo ensure a mission is sncecssfilly compleled.” 1 old him. “ve come 1 the conclusion the only way J can do that is 10 be here with you Because the real bottleneck isn't out there in the field. It's here,” [placed Yoni, who had just become my deputy, m overall command of the two main teams: Uzi Dayan’s and another led by one of our most impressive young officers. a kibbuezaik named Danny Bronaer. lle reminded me a lot of Nechemia Cohen: he spoke little, and softly, but ance an operation began was calm, clear minded and ble anticipate and ivoid trouble befor it materialized. Two other teams. one led by Mookie Betzer and the other by Shai Agmon, would act as blocking sits, concealed halemike on either sue, ane the main foree intercepted the convoy. We chose a spot across [rom the Isrecli 131 moshay of Za'acit. We equipped Yoni's force with a pair of Land Rovers in Lebanese army eolors and had them hide overnight in the moshay’s orchards, a hundred yards from the road on the I ¢hanese side of the frontier, The next snormng, when swe got confimustion the convoy was on ils way, they crossed and stationed themselves on the road. lifted the hood of voe of’ the vehicles and nade as if they were trying to repair engine trouble. Both the blocking forces were in hal tracks with heavy machine-guns in case the convoy chose to stand and fight ‘What we didn’t count on was a Lebanese driver. ina VW Beedle as I recall, pustermyz along the roud shortly after Yoni’s teum crossed, The man waved at them. Quite rightly, Yomi let him dvive on. Along with the other obvious reasons not 10 fire on a civilian VW, he didn’t waa to alert the Syrians and theic busts there was danger ahead. But the .ebanese motorist, as well as a group of nearby farmers, were suspicious enough to deliver a warning that there were a couple ol stalled Laud Rovers on the side of the road. The convoy halied shortly aller passing Mookies farce, hidden in a field a few dozen vards away. Had 1 mot been in the command post, Fim pretty sure whit would have Tappened next. The mission would have been called off. This time, 1 was the one in direct contact with all three teams. Even betore [ gave the order, Yoni had anticipated at, He and Uzi med west fo confront the convoy, In a brief: initial exchange of gunfire, one of Us men was wounded, not seriously, in the leg. But with Mookie's team [iring {rom behind and Youi's and Uzi’s mea in front, the convoy was trapped, and the Syrians captured. The safest way back into Ismael would have been the way the force isd entered. But Yoni and Uzi realized the main imperative was to get the Syrians out as quickly us possible. At a not-inconsiderable cost to a pair of American Imonsines, Uz drove cach of them, with a total of five Syrian officers, throngh a boulder-strewn field across the border. The Syrians included three senior members of the Operations Department of the General Stuff, and two from Aur Farce intelligence. Israel mude an immediate ofTer to swap them for our pilots, though how enthusiastically T'm not sure. With this kind of leverage on our side, it seemed unlikely the Syrians would da further harm to our pilots. Our intelligence officers were keen fo get every bil of formation they conld before sending the Syrians home. I would be a year later before the exchange was done. Youi received a well-deserved izalash Tor his wle in the mission. 132 woe Rarely two months after the umbush operation in south 1 ebanon, Black September seized and murdered members of the Israeli lam at the 1972 Olympics in Munich. As soon as the news broke on the moming of September 5, | phoned Arable Yagiy as head of military intelligence. “You need to send us” 1 said. Cried 1o persuade him that if it came down to an operation to free our hostages, Sayeret Matkal offered the best hope that it would nat end m a bloodbath, We hid the. sings, the background, the ining and now the experience, | also kaew the German militacy had no specizl-forces unit. I'd have been even more worried il [had known that Germun law barred the army from operating in peacetime, That meant any nse of force would be left lo the police. Almahle told me it was too carly 10 say what involvement, il any, Tsrael might have. Tle'd get back in touch with a decision when it came. 1 called my officers together 10 begm planning, {decided 1o use the men who Tad been with me for the Sabena mission, including Mordechai Rachamim. We collated information from the stream of media reporcs from Munich and assembled i rough dea of the layout of the buslding the ferrarists had attacked. As for the anlackers, [said we had to assume there were al least hal -a-dozen, that they had not just AK-175 but grenades or other explosives. And that like the Sabena hijackers, they would be prepared ta die but hoping to live, All of that fumed out 10 be trie. Nome of il, however, could alter the reply got from Alrable a couple of hours later. “We decided wo send Zvika,” he said. Zvika Zamir was the head of Mossad. and he would be going only as an observer. Any apertion agans! he tervorisis wonld still he in The hands of German units. The German polices bungled attempt lo end the ordeal was especially painful because it was so predictable, 1 believe that if we sud been there, at least some of the eleven Israelis lafled might not have lost their lives. The Germans. launched an ambush at a NATO airfield outside Munich, when the terrorists and hostages were ostensibly on their way to board a flight for Cairo. We know now thst there was no properly co-ordinated plan. Toa few police were deployed for the operation ‘Tey were insufficiently armed. aud they licked relevant (raining or experience. The result: a bloodbath. As a final insult to the memory of the murdered Tracts, although the three surviving lermarists were jailed, the 133 German goveenment released them wo meet the demands of the hijackers of a Lufthansa airliner the following mouth. Added to Israeli public's shock over the massacre, there was anger at having 10 watch the murderers go free. In the weeks afierwards, | got occasional hints that a sustained Isuacli response was underway, though | didn’t know the details. [was not aware that it was Ahrahle, at the direction of Golda herself. who was co-ovdmating it. Nor tht a special Mossid team was at the center of the aporstion. Yet from news reports of series of atlacks on suspected leaders of Black September, I, and most Israelis, assumed we were determined to convey a ‘message which the Germans had not: that terror killings of the sort perpetrated in Munich would not go wanswered. [1 was not until late 1972 that | knew the [ull seale of the operation. We had no formal ties with the Massad, but our intelligence work occasionally overlapped. tn mid-December, the sayerer’s intelligence hason was approached with a “theoretical question” by a couple of guys from the Mossad. Did we have the capability to attack three separate flats in a pair of apartment buildings in Beirut. sent back my preliminary answer a few dys biter. | sand it was possible. But there was no way | could say for sure without more information. Would the people in the apartments be armed? Were there guards outside? Was there a caretaker or concierge? Was there only or way in to the buildings, or also rear entrances? Would we be able to got # plan of the interior of the apariments? In another manth, they came up with most af the answers, The buildings were fairly new. with ghassedein lobby areas wd concierges. The Mossad men also gave us a fairly detailed layout of two of the three apartments. They did not know whether there were back entrances, They thought it was likely there were bodyguards, or at least some scourity dela! posted ouside. As for fhe people living in the partments, all of them were likely 1 have at least small arms. Over the next week or so, we raised a series of other questions. Mainly, I wanted to know whether they were sure the people we'd be looking for would be au home. The Mossad officers said they were working on that, but were confident of being able ro confirm this betore any operation happened. Though they didn't identify the people fhey were targeting, [ had now leamed, through Ahrabile aud others, what hid been prety obvious since the Mossid’s initial approach. They were Palestinian leaders with ties to Black September. “I think its possible,” 1 finally kd tien. “We'll piu. u plan in place. We can fhe the arcangements if you come back and say you want us to do it” 134 Nothing happened for several months. By the early spring of 1973, with my two-year term as sayerel commander winding dowa, I assunied the operation had been vetoed. | could understand why, As we warked on aur plan, it had become clear that gelling ino the hen of the | chimese capiial, billing the apartments and getting out again without starting a minor wav would be by far the most difficult mission we had atrempted. T did not doubt chat Sayeret Matkal alfered the best ehance of success. But it wouldu’t be casy. | figured that whosser was making the decision had come 10 the same conclusion. Twas on a weekend away with Nava and Michal in the Red Sea resort of ilat when this suddenly began to move, At around noon on Saturday. | ot call from Valil’s deputy in the Riva. “hud” he seid, “we need you back here 2s 5000 as possible.” When T asked why, he said: “You remember how you were approached by someone with same questions, «nd you went buck to them with a list of other questions for them to answer?” Ltold Nava Id been summoned 10 a meeting at the chief-of-stafl™s oflice — the kind of call of dury that both of us were now used to and grabbed the first commercial flight north. It got the the kirva carly in the evemng, and joined 4 meeting that wes already well underway. Dado was in his usual seat on te right-hand side of the table he used for staf discussions, flanked by Talik Across from them was Manna Shaked, the officer who had phoned me fo tell me about the Sabena hijacking and who had now succeeded Raful Litan as katchor, overall chief of the infantry and paratroopers. Beside him were the two Mossad officers with whom ['d bad mast of my dealings about Beirut, They were all saring at an werial photo of the Lebanese capital, with mn arca marked in blue pen around a street called Rue Verdun Tentered and took one of the remaining chairs. Gesauring toward the image of Barut, Dado fumed to me. “Do you know this place?” he asked. Yes, [suid I'd seen the photo. Nodding toward the Mossad men, said: “These two ofTicers showed if to me.” “10 you hve an idea how fo do fais operation” 1 told him that we didn’t have a fully detailed operational plan. But 1 said we’d looked into the problems we'd face. “We believe we can da it.” When he asked how, I outlined the approach we'd settled on: a small force, thirteen men, plus two from Mossad fo ct as drivers. We would need the Mossad men lo go lo Bei ahead of ws, and tent a pair of nice American cars, the kind typical tourists would use. We'd land an the waterfront, well south of the most bili-up parts of the eity coastline, wd meet up with the rental cars. When we reached the apartment blocks, three 135 aroups of three nien each would take care of the apartments. Four more would remain outside to deal with ie coneierges or security guards oe any other interference, and © command and co-ordinate, We'd leave the same way we came in, by sci. Dado nodded. | found out later that he'd asked the same question of Mano, who had proposed a classic regular-army raid. They would block the road with ten armed paritroopers on each end with the wim of holding off resistance, while another Iwo dozen went in to the apartments and auacked. | could only assume Dada concluded tha this almost certainly wouldn't work, at least not without mitjor trouble. 1t would certainly forfeit any chance of surprise. “The mission is yonrs.” he said. “Manno will be in overall command, offshore. Because we re also planning to hit several other targers.” The reason for the urgent summons was that the Mossad had confirmed all thee Palestinians would he iu their spartments in 10 days” time. Everyone involved realized that — given its complexity, the obvious risks, and the inevitable unknowns fhe operation could well go wrong, In fact, one reason far Dado’s “other targets” was to ensure that if it did, there would be successes elsewhere 10 provide a credible justification for having seat Israeli forces into Beirut. As we received further intelligence, new obstacles had to be factored in. “The main ane was the presence of u gendarmerie, a | ehanese police post, at the bottom end of the street, only S00 Reet or so from the partments. And we would be operating in a crowded. up-market residential area. We could only hope that at the hour we struck, most people would be in bed. Or out partying, This was, wiler all, pre-eivil war Beil, the “Paris of the Middle Fast”. In the years since, an extraordinary array of stories has grown up around the sayeret’s final and best-known mission during my term as commander, culminating in the drematic version in Stephen Spiclberg’s movie Munich. | remember reading in one earlier book. otherwise surprisingly accurate, about our five weeks of intensive taining. Even the full 10 days which 1 thought we'd been given would have been a banus. In fret, we had half that as a full team, since our Mossad drivers, Curopean-born Tscaelis. had to make their way through Paris to Beirut as tourists, rent the cars and scout out our route from the seashore ta Rue Verdun There were four ther operations plamed alongside ours: three hy paratoon nits and one by the Shayerer 13 SEALS. against a series of Fatah and Democratic Fron! mstalltions. Though all of them, hike ours, would need help 136 from the SEALS in petting ashoce, only on cequired dircel co-ordination with us. This was an attack va a DILP building a mile or 30 away in southern Beirut, led by Amnon 1.ipkin, the friend whose unit had faced ane of the toughest Fauitlos ul Kanunich. Ananon’s paramoop force would and with ns and also pile ino Mossad rental cars. Our auachs would begin at the same time, with the ‘maximum prospect of retaining the advantage of surprise. When and if we both completed the operations and got away safely, we would meet up again on the seaffont. From ou first meeting, the morning after Dada pave me the go-ahead. T realized | would have to male at least one change to the plan to rely an fhe core Sabon ten. Thre was no way, after his excision from the hijack rescue mission, that T could refuse Yoni when be pressed to be included. T added him to Moakie Betzer’s force, | put the other two utrack teams under a pair of young officers named Amitai Nachmani and Zvika Gilad. Both were self-confident. natural leaders. Both had other qualities T also knew we'd need: focus, and cali. [ would take charee on the street outside the targeted apartments, along with Amini 1evin, With us would be Dov Bar, a Shavetet 13 officer, und ow medic, Shae! Kate. In the hangar at the sayeret hase, we made mock-ups of the layout of the apartments, using bedshects for the walls and adjustmg the dimensions as further bits of intelligence came in from Mossad. But the real work involved simulating the whole operation, fom the moment of our landing on jet-black Tubber dinghies pilated by the SEALs. We found new building development in north Tel Aviv with a pair of apstment blocks wnder construction. For wo nights. we ran through the whole thing: setting ofTin the dinghies from a missile boat off the Israeli coast before midnight, meeting up with our Mossad drivers on shore, making our way through the center of Tel Aviv 10 the apamment complexes and simulating the attack. T wanted w ensue we could pull off the whole thing without anyone raising an alarm. The one problem came during the sceond run-throngh. A poheemsn drove by as we were “alackig? the apartments. Dado managed to convinee him that reporting us to his superiors would not be an especially good idea In our debriefing discussions after that exercise, Dado identitied 2 major problem Ud overlooked. We would be entering Beirut diessed as civilians. Once we gol 10 the top end of Rue Verdun, we planned to approach the apartments as if we were party-goers returning from a night on the town, “It doesn’t look sight,” Dado said. “More than a dozen party people walking, all men?” Mookie 137 came up with Lhe solution, one that would have the unintended effect of elevating vue mission fucther in [saci lore. The three least burly-looking of us would ia in as women: boyish looking guy named I.onny Rafael, Amiram Levan, and me. Sill, there was another, potentially deeper concern that had yet w be addressed. [n all sayeret missions, since the beginning, we knew we might end up having to fight, shoot and, if necessary, kill. Yet now we would be going m with the expectation of killing thie specific men. We had black-and-white photos: Mohammed Youssef al-Najar, or Abu Youssef, an operations officer in Black September; Kamal Adwan, ane of Arafat’s top military planners; and Kamal Nasscr, a member of his leadership civele and his spokesmun. Nominally. it wes understood we would seize them and bring them back to Israel if possible. 1 had us exercise haw we'd da fhat. But none of us really believed that once our teams made it jlo he apartments. the Palestinians would surrender. We assumed we would have ao option but to kill them. The killing was not the main issue. After all. Thad draven up a plan a year cartier 10 target Arafat himself. Though no ane in the siyeret ook ny pleasure iin having to take a life. at the cud of the day we were a part of the amy. Black September, and Arafat's Fatah more broadly. were not only at war with the existence of Israel, They were behind a campaign of terror, Certainly there was no significant public opposition, afer the horror of Munich, 1 going afer those who wete deemed 10 be part of the operational or political direction of Black September, Our uneasiness mside the unit, however, revolved around what I'd extolled as ils “spirit” when | became commander. Beyond all the specific qualities we needed w succeed in our operations, our image of ousselves was as thinting, soldiers. We might sometimes find it necessary ta kill, but we were not killers. As | explained to cach of the men 1'd be leading on the operation, the Mossad, Dado, and ultimately Golda had concluded that these three men were appropriate largets in the wake of Munich, As i battshon-level commander, | did not feel {was in 2 position to challenge their judgement, wafess we had heen ordered to carry cut an attack that was clearly improper or immoral. In that case, would have rio besttation in refusing. [sid 1 viewed what we were being asked lo do in Bein not as an act of revenge, but a deterrent. H was a way of leaving no doubt in the minds of potential future terrorists that massacres like Munich carmied a heavy price. 138 The more difficult question for some in the wail was how we were delivering that message: breaking into apartments in the middle of the night. Yes, cach of he men was almost sure 10 be armed, But these flats were their homes, Very Hilly, mienbirs of thei Gambics would be Lese. IF he operation went as planned, it was hard to imagine how aay of the men would have a chance of surviving. My answer was that ideally we would face them on a battlefield. Yet given the nature of Black September, (hat was nol going to happen. Mossad was sight to conclude this was the valy way to isolate and attack them. Tor Amitai Nachman, who would be leading the attack ou one of the apartments, my words were nof enough, Twice, he came to see me. 11 was nat hat he didn’y ust or respect me as his commande, he said But befor kading his team into Beirut, he needed to satisfy himsell that the people we weee attacking, and the way we were attacking them, bad been properly thought through by the people giving the orders. T told him T understood. T did not tel him that T was ectually proud of him for asking — which, although I'm sure he sensed if, was an omission I regretted when he lost his life in the Sinai Desert a Rew months later. Bi | did po sce Dado. 1 old im what Amitai had said. He needed no evavincing when [urged him to address the entire Beirut team and answer their questions at our final planning meeting. Ie did so, explaining how and why the decison to large! these three Palestinians bid been reached, to the satisfaetion of Amitai aud the others. We set offby missile boat from Thaifa on the afternoon of Apel ninth. To my reef, since 1 suffer from scasickness, the Mediterrancan was calm as we headed west lowards Cyprus, before circling back in the direction of the Lebanese coast alter aightfall. Tran through the plan a final time with cach member of the team and then joined Amiram and Lonay in wansforming ourselves ws best we could into credible dates for the evening. 1'd vetoed dresses. or high heels, in Favor of fared slacks and flats. We used standard-issu army sacks to pad out our bras. The Mossad had recruited a volunteer fiom a Tel Aviv beauty parlor 10 help us with on hpstick, blue eyeliner and eye shadow. The final touch was our wigs. Amicam and Lonny were blondes. I wenl as stylish brunette. I'm reluctant to take issue with the Spielberg version of events, if only because hie had my part played by someone undeniably belle looking tha | was, even as a 31-year-old. But in Munich, we ace shown zooming into a crowded harbor area on Ine of motor boats, chnging mto drag only ance we've sprinted ashore, opening fie on a dockside kiosk and shooting our way 139 iio town like something out of the wild west. [Tad any of that happened, we would have started a small-scale wae, not ww mention run the very real risk of not getting out alive, In fet, we lei the missile boat, Mamas offshore command post, in motor dinghies out of carshot of Beivut and cut the engines as we got closer to the shore. All of us, including the “women”, were wrapped in ponchos to avoid showmy up on Rue Verdun sonking wet, After gottmg out of the dinghies, we were earied ashore by the SEALS to make sure we stayed dry. All of us had Ioose-fiting jackets. The attack teams used them ro conceal Uzis, explosive charges fo blow the locks on the partment doors if they couldn't be forced apn, & hind grenade or two nd Mashlights for the dash up the stairs. One ‘member of each loam had 2 lacge plastic bag, with orders 10 Lake away any easily accessible documents for Mossad analysts back home. As the mather of ihe brood. Tals had a large purse, in which I carried our radio lo communicate with the team leaders and with Manno on the missile boat if necessary. Our SEAT pilots steered us well away from the more built-up part of the seafront towards the Coral Beach, ong of the private elubs on the southern end of the shoreline. our tented station wagons were wailing, two of ten for us and two for Amnon’s squad. Amnon set off toward the DFLP target. We headed north towards the center of town, In the Spielberg film, my speaking role consistod of two words, my use, as | introduced mysell lo my driver. In fact, we had already met: during the run-through exercises in Tel Aviv. Alter we got into the cars, | asked him how his scouting of the route had gone. He said Basically OK. bul that he’d noticed a couple of cops pairolliug near the lop of Verdun on oue of his deive-bys. T assured hint it would be fine. There would be 1 reason for a policeman to suspect what we were up to, or who ye were. Still, Teonld tell he wis nervous. “What's wrong?” Lasked. He hesitated before replying. “T've never been in a place where there's live fire?” he said. Told him not 10 worry. [le sei wouldn't be. “You're going 10 be parked around the comer, unl it's over. Then, its just hou! gelmg home.” When we reached the top of Verdun, it was aboul en minutes afier one in the morning. Our cars pulled over. T wok Mookie's arm as we began walking the 150 feet or so to the first of the apartment buildmgs. The others followed in Knots of twa or three. Buth Mookie and | saw a policeman approaching on the sidewalk. “Ignore him,” I whispered. We weaved a few inches to the side to let him pass. The butldings were us we'd expected, with their lobbies set buck from a covered terrace in fronu As the other teams made their way Lo the second 140 building, T stayed with Mookie. [Tis job. along with Yoai in his expanded team, wes 0 deal with Abu Youssef, the Black September operations officer. The concierge must have been on i cotfee break, The Tobby was empty, The door wars unlocked, so they sprinted wird the micrior staircase snd inade their way up. Advan, the Fatah military man, and Kamal Nasser lived next door. Adwan, Amitai’s target, was on the second floor, Nasser wis on the third, As the teams raced inno the other building, Amiram and | posted ourselves near ove of the terrace pillars, occasionally exchanging a tew words of what we hoped would pass as gir talk, ‘The SEAL officer and Dr Katz were near the top end of the street as lookouts. We seemed seconds away from what bid all the makings of the operation we'd rehearsed back in Tel Aviv. The one major problem I'd expected security guards posted outside hadn’t materialized. We'd been told by the Mossad to look out for a grey Mercedes, but it wasn't there. I'he next stage was for cach team leader Lo press the wansmit bution three times on his radio. When I'd heard from all of them, 1 would send a signal back. Then, it the count of five, cach of them was supposed to sturt fhe stuck. Mookic’s signal came first. Yel before cither of the other two teams checked in, the trouble began. Suddenly, the door of a red Renault tlew open almost directly across the street from where Amirum and | were standin, A full, sturdy, dark- Tired man climbed ow. He looked across al us. He opened his leather jacket. Tle pulled out a pistol and started to approach us. “Zin breirah,” T whispered wo Amram, “No chore.” Ta this diy, | remember the shock on the man’s fice us he watched us — a pair of 30sometbing women — open our jackets sud pall out Usis. Fortunately for him. we'd had to make allowances for concealment in choosing our weapons. We'd left the Uzis” stabilizing shoulder braces behind. As ow inst shots hil, he bud hal-tumed 1o run. Though wounded, be somehow got back in Lhe car. We kept shooting bul he managed wo drag himself out of the far door and roll behind a waist-high wall on the other side of the street. One of our shots obviously hil the electrical imands of the Renault, because the car horn began blaring full-blast, as if someone had sel off a modern-day car alacm. So mich for the element of surprise. I saw three sets of lights suddenly come on in the otherwise dark apartment buildings. They were in the [ats that Mossad had identified. Al least thal par of the plan was intact. These were the Palestinians we were after, and it seemed they were at home. Seconds lufer, [ heard un explasion. [t was fram Abu 141 Youssel's apaciment, the one Mookie and Yoni had been assigned. Then, bursts of gunfire (com the other building. A Land Rover was approaching from the gendarmerie at the bottom of the road. We waited mil it was abont 50 feel sway. Amirem and [opened fire, then Dov and Slmuel Katz ag well. The driver lst contol and erashed into the side of the Renault. There were at least four policemen inside. They, tao, rolled behind the wall on the far side of the street. Usmy the terrace columns for cover, we kept shooting. Within w minute or so, only a couple of the cops fired back. Though the three Palestinians could not know the reason for the punfire and the wailing of the car horn, they were now on their guard, When Mookie had Blown open the doar to Abu Yousser"s flat — and he, Yoni and the other two members of his team ran into the apartment — he saw the Black September man peering aut from the bedroom. Mookie raised his Uzi but the Palestinian ducked insicle nel shut the door. All four of them fired through through the door. When they went in, they found not only Abu Youssel but his wile, both dead. When Zvika’s team burst in on Kamal Nasser, he. too, was ready, Crouching behind a desk, hi raised an automatic pistol and fired, grazing one of the team on the leg Bul in a burst of Uzi bullets, he, wo, was killed. I suspect that Amitai’s face-to-face meeting with Dado may have saved his life, When hie and his team comered Kamal Adwan, he bad an AK-47 raised and seudy 10 fire. Withow even a split second’s umeonscious hesitation, Anita fired first. 1fis only regret afterwards was thar Adwan’s wife and children saw it happen, and that when they'd blasted open the apartment door, the force blew apn the door of a nearby Ma, Killing sn elderly Hakan worn. She bid been one of the Mossads sources of information on the Beirut apartments. Mookie's team came down first. They joined us, crouching behind the columns, as sporadic shots continued fram one of the policemen behmd the wall across the street. When a second police Land Rover approached, T at first signaled the others to let it pass. But when it suddenly accelerated toward us, we opened fire, It swerved, crashing inta the rear bumper of the offer one, The other teams were back down now. I shouted for Dov 10 have the drivers bring the station wagons from around the corner. When we began to pull away, athind palice Land Rover appeared. It sped up behind us. Mookie tossed back a grenade. The last thing | saw as we made it 10 the end of the block and headed toward the seafront was the front end of the vehicle exploding. We dropped hollow, needle-sharp spikes onl the window of the ear as we left, so | knew that 142 any other pursuing vehicl would be in no shape to follow for very long. Bul we still had to avoid trouble on our wey back out. T knew it would be a risk to go buck ta the Coral Beach, so we ook the shartest route to the sea, straight out to the Cormier, the city’s min avenue slong the Mediteruncan. As we pol closer, we could hear gunfire. Obviously. the police, and the Palestinian militias, realized something was not right. The advantage we had was that they would lave uo idea what liad happened on Rue Verdun, who we were, or where we were going. No sooner had we joined the Corniche than T saw another police Land Rover about 200 yards ahead of us, This one hud a spotlight on the roof, panning both sides of the roud. Cold the driver to slow down. About 100 vars or so laler, seaching the place where we’d arranged for the SEAL to meet us, he and the other statin wagon pulled over ta the side of the road. The 1.and Rover kept driving. We slid down a steep embankment nearly 30 feet 1 the sea. Two of the three assaul teams had bags (ull of documents as well. We swam out io the dinghies. When we had hoisted ourselves in. we headed out at first by paddle, then tnder engine power, to the missile boat. he whole operation had taken about a half a0 hour, ouly 10 minutes on Rue Verdun. I radioed Manno on the way to the missile boat. A half-dozen words: the agreed code phrase for “mission accomplished, trgets achieved,” 1 could hear selief in his voice when le replied. Al firs, 1 assumed thal was because they hadn't heard from us during the operation. Our radio link t the missile boat had gone down when we entered the built-up area around the partment blocks. Genuinely, despite Manno’s suspicion thal 1°d cut the connection. Yet he had ather reasons Lo exhale when he heard we had got out safely. Amnon’s team had hiad a much tougher time. They met resistance from the moment they arrived at the DFLE building. wo of his men were killed, another wounded. They set ofl thei explosive charges. but had to fight their way out. They valy barely managed to escape, carrying their fallen comrades with them and linking up with another eum of SEAL nea the Coral Beach. wea a liule before six in the moving when | got home. | was careful nol wake Nava. I'd changed out of my slacks and flats and surrendered my wig on the missile baat. But 1 didn’t have the encrigy to deal with my makeup. The next hing {remember was my wife standing by our hed us {stirred awake around noon the next day. She looked at my eve makeup and lipstick, shook her head. and smiled. She didn’t need to ask where 1°d been. Iscacl radio had been full of news about a major operation in Beicul 143 PEE A fen weeks later, my term us commander ended. The handover to my successor. Giora Zorea, Lured but 10 be more elaboras than my acrival, though not at my instigation. With both Talik and Avraham in attendance, Dado presented me with my fiih izafash. 1 was not for Beir. Nol for the operation against the Syrian officers, or the unprecedented access our intelligence missions were providing info Egypt's military communications. Dado said it was for all of the abave. And not just for leading the unit of which 1'd been a part almost from the start. 1 was for my pert in bringing it Ww maturity. When | replied. Tam suce everyone knew [ was speaking from the heart in saying that my every moment with Sayeret Marka had been a privilege. And that this latest commendation was an award for the achievements the whole sayerel Dado did me another good turn. As my stint as commander drew 10 an cod, T Kaew what I hoped to do next in the army: to use my tuk training to work my way up The conmuund chin in the amore comps. Bul like pest sayeret comianders. it was assunied | would ficst spend Lime at the US Marine Cops staff college in Quantico, Virginia. Thad other ideas. I wanted to exercise other parts of my mind, by doing postgrduile work a § normal Ameen imiversily. Dado agreed Tstill had to get accepted. The first step was to take the post-graduate entry exam, the GRE. There were two parts to it, The first involved mathematics and abstract thinking. the second English bnguage. 17 my fae had rested on my English grade, I'd have ended up at Quantico. T finished in the 28” percentile. But in the other pare, 1 was in the 99.6" percentile. 1 applied to four universities Hevird, Yale, MIT and Sum ford. Amazangly, | got accepted by ull of them. | chose Stanford, mainly because it allowed a far greater latitude in choosing my program of study. Also, the weather. In carly August 1973, Navi and [joined my parents and hers on a simny. allemoon in Mishmar Hasharon to celebrate Michal's third bisthdsy and say goodbye. We were heading to Palo Alto. California. with every expectation of two years of mtellectual sumulation, new fiends, new experiences and something approximating a more wormal Gamily life. My “other” family, the [smaeli army. also had reason to believe a period of new possibilities lay ahead. The threat of terror remained, of course. There had also been 4 brief bow of 144 nerves over military maneuvers by Anwar Sadat few weeks earlier. But that had come to nothing. Tn ao small part due to the success of Lhe raid on Rue Verdun, Israel’ generals believed the balince of strength and security was on our side und that, wt feast for a while, Tsmuel could breathe a bit more easily. Bul we were all about to be proven spectacularly wrong. 145 Chapter Nine “The phone rang in our apartment in Pala Allo at 4:30 wm the morning, We bid been in the US for barely six weeks. Tt was the Sixth of October 1973: Yom Kippur, the holiest date on the Jewish calendar. Iwas still a bit groggy trom the night before. We hid been aut ut a geteto-knawsyou event for some of the several dozen Tsraelis, and several hundred American Jewish students, at Stanford. While I only vaguely recognized the vaice on the other end of the line, her wards instantly jolted me wake; “The boss is busy,” she suid. “But he wants you lo kuow. A wir has stavicd back home.” ler boss was Matta Gur, who was by now Israel's military attaché in Washingran and was my nominal commander for my period in the United States, “1 need Lo talk to Mott,” | said. She passed him the phone. “1 want you to know I'm going back.” 1 told him. Motta’s reply took my mind back 15 months, to our on-ageain-off-again mission to abduct the Syrian officers, with Motta ind Dado in the command post, inlent an reining in the “young bulls” of the sayeret. “Ehud,” he said. “from whar I'm hearing, 1 don’t think we are missing a major war.” “What's this we?” [suid Motta was a general, at the upper reaches of the armed forces, officially posted lo Washington. 1 was a young officer, just starting to work my way up the chain of field command. “I can’t atford to miss even a nor-major war,” | said, “Ill check in with you when [ et to New York * “Major” would Lum out Lo be, if anything, au understatement. Yet all { knew, as Tkissed Nava and Michel goodbye and got a cab to San Francisco airport, wis hit bore wars agin at war, Ry the time | jomed the swarm of Iseaclis wound the El Al desk at Kennedy cight hours luler, the pietire was clearer, and more worrying with each new report from back home. Surprise attacks by Syria and Egypt armies we'd not just defeated, but humiliated, six vears earlier had pinned down ind pushed bik our forces on the Golan Heights and in The Sinai. Without any advance call-up. many reservists were only now reaching the front lines. As hundreds of people pressed for sears an the F1 Al flight, 1 was fortunate to receive a boost up the pecking order from another mau in line. Since the Sabena operation, the existence of Sayeret Matkal had become a bit less secret. Still. the identity of the sayeret commander was known 10 just a few people outside the nit. So skittish were the army security people that before I'd left for Stanford. 146 they even insisted T change my name. Twas no longer Ehud Brog. I'd Tebraicized it: to Barak, which seemed near enough 1o the ariginal. Among the few dozen outside the unit who did know about my Tale, however, were praraiioupens who'd jomed ws on virions missions. One of Them now old the El Al people who 1 was. Not only was [ given a seat on the first ovecaight plane back to Tel Aviv. I found myself helping the airline establish a priority for assiguing seats Lo others: first, active officers in fighting units: armor. infantry, the air Force. Then, reservists, with the cphasis on those who'd seen active service most recently. As we were waiting to board. I phoned Lizi Dayan and asked him to meet me wi Lod the next moming. Then | called Motta again. “Ehud” he suid, with no trace of irony, “il is an extremely serious war. Syrian tanks ace getting close Ww the auter fences of Nafakh™ aur main command post on the Golan, “Good Tuck. Usd was waiting for me when we landed. Walking to bis ear, we ran iow two reserve armored officers who had also just arrived home. They expected to be sent noth, to help beat back the Syrian advance. When they asked me where | thought ['d be going. 1 said, truthfully, {had no idea. “Wherever | ean help,” [ said. Uzi drove us to the Aur, the bunker built two tloors underground in the kirya. Usually, it functioned us the day-to-day operations ecnier. Bul it was where the commanders of the wed forces operated dusing times of war. Atoflicers” school. we'd heard and read about the imponaace of throwing the enemy “otf balance”, Now, we were the ones oft bulance, The taces [ saw around me were gray and drawn. There were dead looks in the eyes of the commanders and their staff. Some 30 hours after the surprise atack. all the self- confidence we'd felt since 1967 seemed to have evaporated. | looked info several of the roms where, months carlicr, 1d rn through operational plans as sayeret commender. luside each. a large wall map waced the course of the fighting. [sracli forces were marked in blue, the Syrians and Eyzyptians in red, with a timestamp for cach position report scribbled al the side in black magi marker. But | saw that the latest addition was from at kast twelve hours earlier Tt wes as if we'd lost track of what was happening, or were simply overwhelmed by the pace of events, spoke brietly with Talik as be walked along the corridor. He looked 10 years older than when I'd last seen him. Then I spotied Abrahle Yariv, who had been called back fio miliny fntelligence ut the star of the war. §Laoking surprised to see me beck in Israel, he pulled me close to him. “It's importaol 147 that you came back.” he said. “We'll need cach and every one of you to pet the job dane.” Then be bugged me again. It was as if, knowing IT would soon be ‘heading for the frant line, he wondered whether we'd see each other again, nade my way 10 the office that the chief of staff used i the bunker ind asked Dad's secretary if T could see him. As she was deciding whether w let me in, he emerged. Though obviously aware of the seriousness of the situation, Dado raduated his usual calm and confidence. For the first time, 1 felt a bit more hopetul. “Me mishma. hud? be asked, in Israclis’ everyday greeting. “What's up?” I told him 1'd just come trom the airport. “I can help in special forces infantry, armor, Whichever 1s most needed.” “Leading a tank unit.” he said. “They've suffered heavy losses. Go see Tzipori.” Motke Tzipori was in charge of organizing the armored units. Ile sent me ta Julis, the training base berween Tel Aviv and Beersheva, where tanks from maintenance wits vou the country were being brought. Once they were seasonably operational, and as more reservists arived from abroad. | would lead a makeshift bartalion ta help reinforce our badly depleted forces in the Sinai. aww 1 was just one of dozens of officers, in command of thousands of tireless and courageous troops called om 16 iry to Lum the tide. Most were reservists. Many, like me, had rushed home in the knowledge thar for the first time since 1948. there was the real risk Israel would be defeated. By the time | got my battle anders — October 14, the ninth day of the war — Israeli forces on the Golan, al enormous cost. had managed to turn back the Syrian attack. In this war. the men from Suyeret Matlal were not bystanders. Most of the unit joined tae fightback in the north, where, inder Yoni Netunyahu's commun, they took on amd defeated a Syrian eommandu force in the heart of the Golan. Yoni himself risked his life to rescue a wounded officer from another unit behind enemy lines, In the Sinai, however, the sitnarion remained dire. An initial comnteratiack, launched while 1 was on my way to Julis, ended up in tatters, with whole battalions ull but destroyed, as our tanks came under fire from rocket-propelled gromades and, above all, the wire-gnided Suggers. Ismel's main advantage in 1967 our command of the skies was all but gone. By maving their surfuce- 148 to-air missiles to the baok of the Suez Canal afler the truce in the War of Attrition, the Leyptians had ereated an effective no-fly zone a dozen miles into he Sinai. After the failed comnter-attack., with the commander of the air force waning thal we wee neming our mim “red fine” nmber of fighter jets, Golda contacted the Americans Lo propose & cease-fise in the south. But haviog retaken the Suez Canal and pushed inco the Sinai, President Sadat was in rio mood to call a halt to the fighting. [he only way we were goiug to end the war wes 10 retake the canal and defeat the even lacger Ligyptian forces on the uther side. To the extent tat my parc in war was different from other junior officers, it ws because of my history iu Suyerel Matkal. Other Itachi sayereis were attached to specific fighting lorees. Sayeret Golan. for instance, was part of the Golan infantry brigade in the north: Sayeret Jzanhanum, was part of the paratroopers. But “matkal” is the Tlebrew word for the peneral stall, since il was the generals in military headquarters who had allowed Avraham Acnan to eecate the unit. From the start, we had answered directly to the Ava, which ultimately hal 10 approve aur operations. When | rushed buck from Stanford a the start of the war, 1 was still just a 31-year-old licutcuani-colonel. T had spent two years in command of the equivalent of an infantry battalion. But 1 knew. and in many cases bad worked with, the en al the very top of the sed forces, meludmg Dado, the chic of stall. So while other young reservists were seporting to their former units for assignment. my first port of call was the command bunker, where Dado himself. aware that 1'd dane intensive tank training before taking: command of the sayeret, ensured that 1 would play my part in eying 1 usa back the Tgyptian advances. T also kuew, or at least had met, many of the generals plotting the counteroffensive in the command bunker in the south: Shmuel Gonen, known ws “Gorodish”, who was head of the southem command: Arik Sharon, who had left the same job for politics a few months earlier, but was now commanding a division near the canal; and Chaim Bar-Lev, the former chicf-af-staff whom Goldy had called back into emergency service. | even knew the buaker. Tt was Urn-TTashiba, the command and intelligence post from which we had run Sayeret Matkal operations into Egypt after 1967 So during fhe last, decisive 10 days of the war, [ would witness first-hand the tension among our top commanders in the Sinai. especially betsveen Sharon aad Gorodish. since Arik wasted few opportuaities to suggest. rightly but aot always helpfully, that his successor was woefully out of his depth. [ would lead my company bick cross the canal with on of fhe other min armored brigades m the Sinai: take out Egyptian missile sites and help restore our jets” command of 149 the skies: strike out alone at night, with sayeret-issuc night gogeles, to bring, back the sweviving soldiers aller we realized we'd lost one of our APCs ina battle with Fyzyptians; and even, becuuse 1’d been there betare on sayeret sissies, leuing a joint armored force seross the Kyprian desert fo complele the encirclement of Sadat's Thind Army and effectively end the war. Still. the memory which has stayed with me longest — summoning back all the miscues and misjudgements of some of Israel's top commanders, and the terrible price paid by the men on the ground Ww ur things around — was the fight tor an experimental agricultural facility located just a few miles back from our side of the Suez Canal, ve On Isruch mhiary maps, it was called the Chinese Fam, Tn fact, 11 wis Japanese experts who helped set it up in the then-Lgyptian Sinai before the Six- Day War, When we captured it in 1967, deciphering the characters on the equipment had evidently proven beyond our linguistic cupabilitios. Thus, Chinese Farm. Now, it was back in Ligyptian hands. | he sprawling complex, with its web of large irrigation ditches, controlled the main transport corridor from the Sin to the bank of the canal. Before dawn on October 16, onc of the bittulions in Arik Sharon’s brigade. under a veteran paratroop commander named Danny Marr, had managed to cross the canal on rubber tufts with an advance force of some 750 men and a Few dozen Tanks. Bul il wis a precarions beachhead, vuherable 1o Kgyplian air strikes, artillery and Sagger fire. Tlopes for any large-scale Israeli counterattack rested on moving forward an enormous raller bride, and hundreds more tanks, To complete The crossing impossible wilhon! eialing the Chines Farm. Ihe first [knew of the scale of Bayptian resistance there was about four in the morning on the seventeenth. 1 got a radio call ordering me to get my battalion ready to move, ASAP, We were wttiched the other main armored force, along with Acik’s, assigned to lead the crossing. Tt was under the command of Avraham “Bren” Adnan, the former overall commander of Israeli funk forces. “You're going north of Tirtur 42,” Bren's operations officer told we. Even without eliecking unr coded map, | knew it was the wad runing along the upper edge of the Chinese Farm, He told me that the paruchutists of 150 Battalion 890. under Yitehik Mordechai, weee in trouble. “Go. Find them. Telp get them out.™ 1 knew Yitzhik personally, trom his years in the paratroopers” elite Battalion $90. | knew the man who wis now m overall command of the paratroopers even better: Uzi Yairi, who was in charge of Sayeret Matkal during my final years ot’ reserve dury at Hebrew University. Helicoptered into the Sinai just hours earlier, the paratroopers hid been sent to the Chmese Fann shortly before midnight. As | would soon leam, they had no more idea than 1 did boul what they were about to face. They were told they were going in simply to clear out bunds of “tank-hunters”, They werent fold of repeated attempts by same of Arik’s top tank, paatroop snd reconnaissance units 1o tke the fiom over the previous 36 hours — attacks which had not only failed, but had cost dozens of tanks und humdreds ot men, Without artillery, armor or air support, they immediately came under rifle, machine-gun, mortar and heavy artillery fire. Our job was w gel them out. Ordering my men to gel ready for our first combat mission of the war. 1 found myself face-to-face with a distraught and determined frend from mihtry tel hgence, Yishii Ezhar had amived at Bren’s headquarters the day before. When he saw mie, he'd asked w join my battalion. He was a brilliant electronics engineer and was about to assume command of the technology unit in military intethizenee. [told him we already had our complement of tank ercws, and | knew he'd never had any armored triving. So T found him a place in one of our APCs. But before joining military intelligence, he'd been a company commander in Battalion 890, Hearing that we were going 10 restue his old unit, he insisted on joining me on the lead unk. | tied sever] times wo refuse, but be said Thad no moral authority to stash him in an APC when we were poing in to rescue his friends and comrades. Aware that each wasted minute might cost more of the panstroopers” lives, | relented. 1 old Yishai ied be sitting aceoss (com me on Lhe tired. eight above Yasha Kedmi, another friend who, having served under me in my first tank company in the War of Aurition, hid asked 10 join back al Julis. Yisha was our loader und sadio-operator. [le got Yishai a machine gun, extra magazines foc bis Uzi and a box of grenades. We moved out through wave-like dunes in total darkness. After the first few miles, the terrain leveled out a bit. Still, the sand was deep and the going slow. When we got within a couple of miles of where I assumed Yitzhik and his mea would be, 1 radiced him. His voice was chilling, “Theyre very close to us, shooting,” he said “T've got many wounded. Get here as quick as you can.” 151 As we got closer, T could stil see na sign of them. Ag dawa was about break, Tradived Yitzhik to suggest he fire olV a face, but he thought that would put them at even greater mercy of the Fyyptians. Instead, he tossed out a smoke arene. We spoed it, more thins hall-wmike sway. slightly below us und lo our right. 1 ordered us forward, leaving my second tank company behind for covering fire. 1 led Company A, which included ty most experienced tank commander, Moshe Sukenik. Immediately behind us were our APCs, including two careying our medical team. My ain was 10 engage the Ligplian fire while starting to evacuate Yitzhik’s men to one of the long. dry, inigation ditches, 600 yards behind vs. We moved forward in a broad line with my command tank in the center. We held our fire until we got closer. T still couldn't see exactly whee the men of! Battalion 890 were and didn’t want to risk hitting them, Only when we ot within about 70 yards did T spot the first of the paratroopers. They were in groups of three or four in a thin line stretching 200 or 300 yards oa either side of us. They were lying behind whatever cover they could find: a bush. a clump of debris, a small vise m the sind. Some were firing. Others were wounded, From just a few yards away, Egyplian infanteymen were caking them with vifle and machine-gun fire. They were now shooting at us as well, and we returned fire. But the Rgyplins, far outnonbering Yitzhil's men, were spread out mi network of foxhole, in some places connected by trenches. As we moved forward. T ordered my APC commander to start evacuating the paratroopers back to the irrigation ditch, with the support of a further group of courageous reservists rom another nearby APC unit A shell suddenly exploded 20 yards ahead of me. Others ained in asound our tanks. The source of the fire was straight ahead, about 1,300 yards away thee SU-100s, Soviel-mude World War Two “unk destroyers”. [indned the main gun of my tank on one of the SU-100s and ordered the gunner Lo fire. T used the batalion-wide radio frequency so the others would hear the order. But when the dust and smoke bad eleared, the SC-100s were still there. 1 ordered sight correction and said, again: “Tire”. Sill, we missed. t was only thea thet realized why. Almost none of the tanks brought brought into Julis fiom the maintenance units hud included their “commander’s notebook™ with their checklists for calibrating and firing — a major problem, since many of the reservists had last been in a tank years before. T ordered the gunners to use their telescopes. parallel to the main gun. instead. 152 We were being hit by small-arms and RPG (ice fom all sides. On the turrel of our tank, Yishai and [ were firing back. our Uzis on awomatic, and throwing grenades, 1 could hear bullets pinging off the turret and the body of the tank, Then, from onr far right Mank, came the shouleler-mounted Sawgers, homing in with their ceric bluc-red glow, juddering towards us as the Egyptian soldiers corrected thei trajectories. One of the missiles barely missed us, and the silky wise fiom its puidance mechanism wes tangled over our Lures. | tied using my binoculass to identify where they were coming from, but it wag no use. To my right, T could see that the APCs had completed their first evacuation rum and were comm bck for mare of Yitzhik’s men, There was a raggedness whout it ull: onc APC, then # couple of others. then i gap, then another one or two. They were doing whatever they could, whenever they could, as the Fyyptian fire continued ta intensify. A few of Yitzhik’s men, whether desperate or dazed, simply stwod up and starting walking west, toward the canal, valy to be cut down by Egyptian gunfire. I directed Moshe Sukenik to take half the company and head toward the Sager to ry 10 take them out, even though we both knew thi he'd ive to sisk heavy five before they got elose enough. Le had two-inch mortars on his turret, but their range was anly 500 yards, far less than the Saggers. Every 45 seconds or $0, 2 salva of Sages zeroed in on our tanks and APCs, Within i couple of minuies, two of the tanks were hit. One was on fire. The SU-100 tank- destroyers were still there as well. Egyptian infantcymen were spraying us with small arms fire, The whole ure wis swathed in grayish smoke. Every minute or twa, another lank or APC took a dived hit. There was a smell, wo, which, once experienced, never leaves your memory: the scent of burol human flesh. The fire from the foxholes was getting worse. “Run over them,” 1 ordered my lank diver. “Start with the foxhole m front of us.” He jerked us forward and we plowed over the fist Lgyplian position. “Reverse, get the one Lo the right,” | said. As he backed up. | was shocked to see a surviving Egyptian soldier, shrugging off a hick blanket of sand from his shoulders, raise im RPG lumcher at us from just 15 feel away. We were close enough to look into cach other's eyes. I raised my Uzi and shot him before he could fire. Rifle and grenade fire continued from aon the fine of foxholes. A second lenizth of the Sarers silk= likes guidance wire angled over ous min pun, Yishai was firing at the Egyptians from the other side of the tank. We both tossed grenades in the direction of the worst of the gunfire, 153 Tt wes then, suddenly. that Tsaw Yishai had taken a bullet in the side of his neck. Blood was spurting [rom the wound. [is face was contorted in pain. [le Tooked at me, raising his hands upward, ws if fo say: “1 did my best. (€'s over nove.” [pressed bird on he wound, Inying lo stem the flow. Bil he shipped onl al my grasp and collapsed into Yasha Kedmi’s ars. Yasha propped him up and kept trying to staunch the bleeding. T turned toward the Egyprian soldier who liad shot Yishai. less than 20 feet to my lel. Keeping mysellas low as possible above the turset, 1 fred into his chest. Le tumbled iow the foxhole. As 1 kept shoating, Yasha told me Yishai was dead. “Are you sure?” 1 asked. When he said yes, | ordered the driver to back up, We drove a few doen feet, to where a group of the pasatioopers was taking cover. With theiv bielp, we lowered his body from the tank. and then returned to the battle. Barely ten minutes had passed since it began. Twa SU-1005 were now spewing smoke and out of action. The thicd bad withdrawn. But the Lypliens were still ling. Uive of vue tanks had been hit, Two were on fire. One APC was smoldering, its commander severely wounded. 1 knew that if we stayed nich longer, we would end up like other trmored units during Israels firs, filed counteratiack in the carly days of the war. We would risk being wiped out. As far as I could cell. al the surviving paratroopers had been brought out or had msnaged fo hobble to the irrigation dich. 1 ordered Sulenil lo shandon hus attempt 10 take out the Saggers, and we withdrew behind the irrigation ditch. Tt was only then that T realized that alongside two of our crippled Laks there was still a group of a dozen men: six crew members from my battalion and six af Yitzhik’s meu. Il wok nearly wo hours 1 gel them oul. We used our lank uas Lo try 10 reduce the intensity of the fire [rom the Egyptians around them. T ordered one of our APCs to 20 pet them. I rounded up all our smoke grenades. und the APC crew used them lo exeute # smokescreen, the only way 1 could think of 10 reduce the danger of being Lacgeted by the Saggers. Tt worked, bul it required incredible guts for the men in the APC to pull ir off. “The battle hud required guts of every man in the battalion. They had fomd a wey 10 conquer the {est and most powerful cnemy on a bastlefihd: fear. 1 Rol it, too. But it's easier for a commander. When you're leading people into combat, you don't have time to be afraid, You have fo assess and evaluate, second by second, everything going on around yon You have to make instant decisions and ensure they re being carried out. The people under your comniand are waiting to hear your voice, ind watching your actions, foo. (F you lose control at any point, not only is your life at stake. Theirs are 100. 154 Cady that evening, we were ordered to rejoin Bren's division to be ready foe the crossing. When [reported that these of my soldiers were still missing, 1 was ordered to inform the commander of the battalion replacing us to find the missing mn. The ght for the Chinese Fam was still not over. 10 would be another 12 hours before, in a co-ordinated push by a strengihened armor and infantry force, Israeli forces finally drove most of the Tigyptians out. What tenuous gains we'd made until then lied come at an enous price. OF Yithik's 300 men, nearly 40 were killed. and many others wounded. 1d led around 130 people into battle. More than 35 were injured. leven were dead, including Yishai Izhar and Motti Ben-Dror, our medical officer, killed while eating the wounded. One of our missing soldices was found alive. The other two could only be broughc home for burial As I began to hear the derails of the previous days” fighting. I became more astonished. and angry. Tscael’s tactics in the bale foc the Chinese Tar had involved a series of piecemeal strikes by units obviously too small, and inadequately supported or co-ordinated, to succeed. The problem wasn't the choice of units. No one could doubl the record of Buttulion 890, or of the men Arik had sent in before Yitzhik arvived. But there was no way they were going to take the area on their own. I couldn't understand why there wasn't an attempt fo assemble a force hil might uchualy have been strong enough: parachutisis, tanks, artillery. 1 BILL knew at least part of the answer from the two nights | had spent in the Un-ITzshiba command post before joining Bren’s division. By dawn an Octaber 16, the first of Arik’s men had crossed the canal. By the allernoon, although the big roller-bridge was sill not ready. a smaller pontoon bridge was available. Everyone knew we needed to get control of the Chinese Farm. But all the field commanders were focused the real task, and the real prize: crossing the canal und defizing the Egyptians an the other side Now, at least, the main erossing was underway. Bren had chanced the fact that, with Yitzhik pinned down at the Chinese Farm and the Egyptians concentrating their re on his men and min, he could get the pontoon bridge through. From late afieraoon on October 17, his first units began cross. On the morning of October 18. my battalion joined them. There was still fighting head, and we were part of it: taking out the SAM sites, engaging units of the Third Army aud, vith Sadar vow pressing the Americans fora ccase-fire and ‘many Tgyptian units clearly losing the will to fight on, racing against the clock to encircle and defeat it five days later. 155 When the guns finally fell sileat, had lime to give full rein to my thoughts. There were obviously fundamental questions about how the war had happened, starting with why we hadn't lawn ahead of time that two neighboring states were about To attsck ns — despite sayeret intercepts thal could have ven us time to call up all our reserves. Disentangling the details would take months. But we already knew the human cost of those failures. ITundreds of Israeli soldiers had been killed. ‘The final sumber would be around 2,800. nearly four times our losses in 1967. Thousands were wounded, some crippled for life Many of the dead were men whom 1'd grown up with or served with, including more than 20 in my own battalion. Same of the dead in other units were close [riends. T felt exhausted. [also realized that Nava, thousands of miles away in Pelo Alto, and my parents on the kibbutz could still not be sure | had escaped the fate of so many others. T leaned later that my parents had been making daily calls w Digli, who was working in intelligence in the dirva. Though he had no way of knowing where I was, le kept assuring them that he iad checked with my communders snd that [was ahve and well. Nava had been lying on American ews reports and the relayed assurances fom my parents, which she was seasoned enough as an army wife to treat with skepticism. missed her bdly, und hitle Michal, 1 felt the need to hear their voices, { drove lo one of the brigade communications wits. here was a long line iu front of the radio telephone. But within a hal(-hour. [ managed to pet a crackly connection to California. Nava burst into tears when she beard my voice, | told Ter 1 was fine, aud that | couldn’t wail w see her und our Bille girl. Then, my awit eyes dampening, [ reeled off the names of friends who bad died. Tn addition to the brave men 1'd lost in my own battalion, there were more than a doen others | uleady knew of. A pair of brothers Gom Mishmar Hasbiron, a couple of years younger than me. in separate units, but killed within hours of each other. Another childhood friend. from a nearby moshav, named Rafi Milzafon. And Shaul Shilev, a gified philosophy posterduaic and a brave tank commander whom ['d become ftiends with au olficers” school. Te'd rescued three dozen troops fiom one of the Bar-Lev fortifications in the first hours of the war, only fo be killed trying ta set ta a tank crew who had taken refuge a few miles back from the canal. T'd lost two wonderful sayeret comrades, wo: Amit Ben-Tlorn, the soldier who'd relayed the order from Motta fo abort our second attempt to abduct fhe Syrian ollicers in Lebanon, and Amitai Nachmani. the officer who had 156 demanded a meeting with Dado before ouc attack jn Rue Verdun. Amit died in the fighting near Ismailia, at the northern end of the canal, as Arik Shacon’s units pushed on after the crossing, The day before the end of the war, both Amitai and Amram Levin were part of an operation lo tke over the Fagid Ai Base across the canal, Whea an Layptian RPG hit thei Jeep, Amica was wounded. Amitai was killed thought, toa, of Yishar [zur the friend struck down beside me, wha 17d exudled in auy arms on the op of my tank, trying 10 stop the bleeding. “Oh Chod." Nava said. “It's like 1967 all over again.” “No.” 1 said. “Worse. Much worse,” A few wocks later, © was caning out of the kirya when | ran into another friend. whom I'd first met at Tlebrew University. Like me. he had been a junior officer in 1967, His name was Ron Ben-lshai. He would go on to became a top jourmaist, covering the military for Ismel’s best-selling newspaper, Yediol Achronar. To the early autumn of 1967, we were still transfixed by the idea of being able to visit areas of biblical Israel, which for years had been under Jordanian vile. With a Few other friends who were young officers, mine of us in all, Ron and 1 embarked on a trek from the southern edge of Jerusalem, weaving our way through the Judaean Desert toward Kumeran, on the Dead Sea. Now a very driferent war hud come and gone, 1°d fought in at, Ran, as whl is now called an embedded journalist, bad been with Danny Mall's paratoopens when they'd crossed the canal. ITe was alongside another of Arik’s units fighting our of the bridgehead on the far bank of the canal, That both of us had sem lerible suffering over the past fow woeks did mo! need saying. But Ron said he wanted lo show me something. Tishing into his wallet, he took ow a carefully folded photograph. Ee had taken it in 1967, just six years earlier, to srk our Judean ivek. There we were. All nine of us. Young. Full of opiimism And probably a bit full of ourselves as well. Ron and I were the only two left alive. wa ‘We had won the war, and not just because our forces were now within 601 miles of Cairo, und only 25 from Damasens. We isd been aacked by two huge 157 armies: voe-and-a-half million soldiers. Thousands of tanks. Tlundseds of fighter jets. Other, much larger nations had endured mouths, even years, of hell before prevailing in such circumstances: the Soviet Union, for instance, with its huge stategic depth, or Franee, reseed by ls American-led allies, during World War Iwo. But any pride in having prevailed was outweighed by simple relief Tsrael had survived. Even that wis nothing compared fo the sadness felt aver friends lost, and the resentment and sense of betsayal toward the generals and political leaders who had failed to prepare the country for the surprise attacks, or the ininal confusion und dissension in some of our commanders” response to the curly seibicks on the ground. Dozens of meetings were held in military units after the war to talk about what had gone wrong. Twas not the only young officer to notice that the higher up the command cham they went, the more wnedilying they became. ARer we'd heard one too many senior officer fine tuning his zceount with cach retelling, minimizing his share for the huge losses. a new phrase entered Israeli army slang. Sipurer fravot — “battle stories” — were the words sully wsed fo describe 8 normal debmeling process. Thal expression was now amended, 1o shiparer kava. Battle improvements Iwas assigned to convert my makeshitt force into a regular armored training unit: Bartation 532, und that shihtly delayed my reunion with Nuva und Mikbul. Bul in their absence. | found us # larger apartment in the Tel Aviv suburb of Ramat TTasharon. Nava and T agreed that at the first opportunity, I'd return to California and we'd fly back together, [went at the end of the year. We bought w refrigerator und 8 washing machine for the new Nat — better models, and cheaper, than those available in Israel — and came home. Those (ew December days in Palo Alto were a jumble of emotions. Happiness, at being back together. Bul also a sobering sense, now th | was outside Isc] for the fimst ime since the wa, of the enormity of the threat we'd faced and the [rusteation and feac Nava must have felt as we'd fought to defeat it. The year-end news setrospoctives we waiched on Amerie TV were Gull of film clips Grom the fst hours of the war, when it looked very possible we would lose. | remember being struck by the thoughe that. if we hud lost, if Israel had ceased to exist, ceremonies of memorial and mourning would have been held across America, probably in Stanford. But that once the shock and sadness had passed, Isiael’s disappearance would not have impinged on a single NIL Sunday. or delayed a single family shopping visit to J. C. Penny. 158 My command of Battalion 532 lasted only a few more moadhs. On Api |, 1974, an oficial commission of inquiry published its initial report vn the war. Tt was scathing in its assessment of aur intelligence failings, for which it placed the mam blue the officer who hid been promoted the year before ws head of militacy intelligence: Lli Zeira, the man who had addressed us on the sayeret base before the the 1967 and so confidently predicted the outcome. It also took aim al two other commanders. Gorodish, as head of the southern command, was ane. The other was Dado. As chiel-of-sialf, he was held ultimately responsible for the intelligence failings and for not having ordered at least a partial call-up of our reserves, In Els ase, [recognized the very fel of our being caught by surprise made his position untenable. Tn fact, as [ leaned more details about what had happened, 1 realized the commission had, if anythmg, understated the seriousness of his errors. Tn dhe cun-up to the war, Cli had resisted multiple sequests from other intelligence offiears to activate what the commission called our “special sources” of intellipence: the communications intercepts we'd planted decp mside Feypl. Worse, hie had indicated 10 the Few generals who were aware of theie existence that he had activated them, implying that his lack of concern about the possibility of an Egyptian was based on our intercepts. Because Dada was one of the people misled, hus Ball struck me as profoundly unfair, He had devoted bis whole adult life w the detense of our country. Afier the inquiry report, he was never again the same person. Tle developed an obsession with fimess and exercise. Psychologists might have called it displacement activity. | wondered whether it was a kind of sol -punishment. Either way. it may well have killed him. ALage 50. Jess than three yeaes after the war, he died of a heart attack after a day of running and swimming, Almost every level of command wis thrown info flux afer the inquiry sepuet. So was tie political landscape. Both Golda and Dayan bowed to growing public pressure and resigned, The premium was on finding replacements who were sufficiently experienced, but did not bear responsibly for the errors of the war. For Prime Miuisicr. the choice fell ou Yitzhak Rabin. Te had strong military credentials. of course. But he had left the army and entered politics, and hac been ant of [sricl for several yes us Ismel’s ambassidor fo Washington, He had joined Golda’ gosemment only weeks bolore the wear, in the relatively minor cole of Minister of Labor. Much the same thing happened in the army. Only ane of the genentls who had been in the running to succeed Dado before 159 fhe war was unscathed: Motta Gue. [1e, wo, had been in Washington. Within days of the inquiry ceport, he was called back to replace Dado as chief-ol-staf My role changed, toa. Not everyone emerged from the war with his reputation diminished. The hon’s shave of the credit for Israel's eventual victory went to the rank and file of our citizen army. But in the officers’ corps, there were also examples of coolheadedness in crisis. and leadership. One was Moussa Peled, who was now made head of the wrmored comps. My averall wartime commander, Bren, replaced Gorodish as head of the southern command. And Dan Shomron, whose 401" armared brigade played a critical part in defeating the Firyptians, wis another, Dan und 1 hud fiest wot ta know auch other well 1 Kavanch, thew daring my period as ssyorot commander, We would go on in the years ahead to work more closely logether than almost any senior officers in the military, He was now promoted as well, He became katzhar, overall head of infantry and paratroop forces. and he recommended me as his successor in Brigade 401. Still, T knew that the Motta would have the final word. with input from the twa senior officers most dircetly affected: Peled and Bren, [don’t thmk cither of them had anything agains me personally. But both were Lauk officers through and through. There were other candidates to succeed Dan who, unlike me, had spent their whole careers in the urmared corps. heard Formally 1 was being considered as | wis shoul to rein fo my ‘battalion from Ramar [Tasharon one Sunday morning. [ was ordered to report to Mott's office, When I got there, hie gestured toward the small table at the side, He uheady had two other visitors: Mowssi Peled nd Bren. “Yon probably know you're a candidate for taking over 101.” he said. “These two gentlemen think you're not yer ready. What do you say?” 117d hid more time to prepare, [might have answered more subtly. But | did very much want to be given command of the 101st, and had no doubt T would be a worthy and dedicated commander. “I don’t know exactly what the two gentlemen mean by whether I'm ready,” replied, “So 1 have u proposal. Tind a battke-tested officer whom you trust. TTave him check who among the three of us, me or these gentlemen. is more familiar with the tank and its systems, Wha of us knows better the terrain, in Syria or Faypr, day ar might, where we have lo ight? Who knows the operational requirements for an armored force, and the armored doctrine these gentlemen signed off on. Finally, which aie of" us has spent more thm in i Inmet of a funk, on the batlcficld, shooting at encany focces and being shot at by the enemy?” 160 There was silence, a grave look from Peled and Bren, the hint of a smile on Motta’s face, and the meeting, was over. Several days later, 1 was notified of his verdict. | would indeed be named the commander of the 401st Armored Brigade in the Sinai, and promoted to full colonel. Our bose wag a 15 mikes from the canal. 11 was @ huge expanse of sand ringed by metal fencing. We spent three months at a time in this forward deployment and three manths in our rear base, 50 miles from fhe canal, During anc of uur forward deployments, Motta came on an inspection visit. He wanted to discuss how we planned detend the area near the canal in the event of a repeat of the 1973 war, 1 told him everythmiz we were doing in the brigade was aimed ut crsuring flexibility. | ed also been thinking bout sone uf the broader issues relating to our defenses in the south. “No matter how good our tactics or plans.” 1 said. “what warries me is that we're stiff not looking at our overall approach to defense against Egypt. Is es if we've focgotten that in 1967, when we captured Sinai. it was io ordec to have a bullec zone. We had 750 miles of sand between southern Israel and the canal. But when the Tgyptians attacked in 1973, we defended the desert us i was the walls of Jerusalem!” Since the 401s was one of twa regular brigades un the Ligyplian front, it was not easy to make the four-hour drive home to Ramat Hasharon. When 1 got word Nava was going into labor with our sceond child, 1 was fading a training exercise five or six miles from our base. As she was on ier way 10 the hospital, T grabbed my car and headed north. Unlike Michal’s birth, this one was not cusy. When the baby emerged, she was struggling to breathe, The immediate danger passed, but she was placed in an incubator. When | goto the hospital, Nava was asleep. Twas taken to see our tiny daughter, Yael. When the nurse left, 1 noticed the baby’s pinkie trapped in the plastic cover of the incubator. [ started binging on the window of the room. ‘The nurse rushed back. With a look of sympathy mixed with world-weary experience of other fathers ia similac ‘panic. she raised the cover. folded Yael’s tiny hands onto her stomach. and all was well 1 veas another health erisis whieh hastened the end of niy period as brigade commander. But this time. T was the one in the hospital. T neazly collapsed from high fever and exhaustion. The initial suspicion wis some kind of contamination linked 10 the rudimentary sanitation in the Sinsi. When the symptoms persisted, the doctors suggested T probably had hepatitis B. Years later, better diagmostie tools rule all that out. [ve never discovered wht the 161 illness was. But for nearly six moaths, getting through the day, sometimes a single task, remained a struggle [did not want to leave my command, 1 was still barely 18 months into the roke. and anxious 10 get further command experience. But just is [ was fechnyg ul my weahesl, there was another belated casually from the 1973 war. his tie, it was Uzi Yairi. No one could reasonably have held him responsible for the losses suffered by Battalion $90 at the Chimes Fam, I'm sure tht if he'd Known what happened fo the Isrcli forces that hud heady tried 1 take it over, he would never have allowed Yitzhik to po in without adequate armor and artillery support, Still, he blamed himself. In abvious distress ufter the war, he was roussigned as wn operational officer in mili intelligence in the Kirva Ue was still at his desk when Fawal tecrovisis landed on Tel Aviv's seafront a Tittle before midnight on March 4, 1975. They were spotted by a police patra, which apencd fire. The Fittuh men rn from the beach, Firing Kalashnikovs and tossing grenades. A block in from the sea, they burst into & modest, three-story building: the old Savoy Hotel. They shot and killed three peaple in the lobby and tak he rest of the stall and guests hostage Suyoret Mutkal was callod in. As the unit went through final preparations for their assault. Uzi showed up. [le had a rifle. He was in his everyday officer's uniform, unlike the sayeret team, which was weighted down by special-farces gear. As i Former commander of the sayere. he persuaded Therm be could help take ouc the terrorists and locate the hostages. Shortly before dawn, led by Amram |evin, they attacked. They killed three of the Fatah men within sceonds. Bul unother terrorist set off an explosion, collapsing most of the top floor. Uzi joined a couple of the other sayeret men in search of the hostages. Ile was shot in the head and neck. Seven of the eight terrorists were killed, the other captred. Though five hostages were fred, five lost their lives. Uzi died an the operating table of [ehilov Hospital. a few hundred yards from the kira, PE Though T doubt ULi's family and fiends would agree, my put feeling was always that his death was one more result, however indirect, of the shambalic waty 1m which we'd orginized our tacks on fhe Chinese Farm. | hat wis part of the reason for my reluctance when Motta told me he wanted me to take Uzi’s 162 place io the kirva. 1 realized Twas the only available replacement with a similar backround, and sayecel experience. But [ was still gaining brigade command experience, And [ couldn't help feeling the role was intended as a kind of rest- underecavery cure because of my illness, not loo different from the vesson Uzi had been given the job. Still, [did need rest and secovery. Even if fully healthy, I'm not sure I could have convinced Motta to change his mind. In my weakened state, | had no chance. Skeptical though | was about the job. it opened up a new world tw me. The fry itself was not new territory. But now, I became exposed to how how the huge range of intelligence information we gathered was collated, evaluated, wssessed und ultimately applied. Helping with this process was my new assignment. There were, in fact, lwo of us. We were both colonels and together we provided the mtelligence background for military operations. [had the post on inside the military intelligence deparunent. My opposite number was in the aperations department — the more senior sale, in a way, because he had a more direct link to the people actually doing the operations. Ile was a friend from officers” school: Dovils Cirmiri’s vonmger brother, Shi. Once iw week, Shad und [put together an assessment report. Then, we'd join Moua's operations meeting with the general staff, often atcended by the man who'd followed Dayan as defense minister, Shimon Peres. The analysis of military intelligence included separate teams for ligypt aud Syria, Jordan and Lebanon. Iraq and other neighboring states, as well as other countries and superpower relations, It relied on all our raw intelligence material, from buth miliary intelligence and Mossad, us well as academic amd specialist literature. Tach desk dealt not just with militacy issues, but political and economic developments. 1 was responsible, along with Shai and a few others. for bringing all this together. This mean! Frequent meetings with members of the analysis leans. Cor the first six months or so. T barely uutered a wond in these sessions. I listened, not just absorbing the information but getting to understand the wary the analysts worked wd ought Our whole intelligence department was responsible for drafting an annual strategic assessment for the army and the government. The final report was written by Shlomo Gazit, who had succeeded Eh Zeira as head of militry intelligence. Before we sent it w print, he held a long meeting, inviting the views of all the military intelligence officers. The focus in 1976, just three years after fhe wr, was on the risks of a new surprise attack. At the end of the discussion, however, he said: “We know we run a real danger for the country if 163 we fail 1o spot the signs of a war. But has any of you asked yourselves something 1 find myself wondering from time to time? Is there not a similar risk if we miss the signs of an opportunity for eae?” His words stuck with me for the rest of my time m public fe. They also had u strong impact on me at the time. One of the beuchils of my job was that { could read the full inquiry report from the 1973 war, including the portions thar haf been kept classified. Some dealt with the political situation before the war. Golda had relied hiavily on a “kitchen cabinet” of trusted ministers and a few close advisers. The inquiry material described how Sadat had been extending negofiuting feclers before the war, And how Golda, Eli Zeira, Dado and Dayan a responded. [was like an exercise in collective reinforcement. |hey agreed the Arab countries would not simply go on living with the humiliation of their defeat m 1967. At some stage, they would try tw regain the initiative, on the battlefield. But none speared to think though the implications of this for pur puitical approach. Perhaps. like Eli Zeica in 1967, they assumed a kind of historical inevitability of Iscaeli triumph. Though we'd ending up prevailing in 1973, it was impossible ot 10 wonder whether, is Shlomo suggested, we had missed the signs of a possible peace beforchand. Now, however. we were facing an escalating challenge from an enemy with no interest in peice: the armed Palestinian groups. The Democratic Front took aver a school in northern Israel a half-year afler the war. In March 1975, Fatah had seized the Savoy. And about a year into my posting in the A#ye, the Popular Front fur the [.iberation of Palestine launched an even more audacious operation. Tbecame known by the name of the airport where the ordeal ended. FEriehbe, And when it began 1, like Uzi Yairi, was sitting at my desk. 164 Chapter ‘Ten Sundry is an ordmary working day in (src! and the first sign that ime 27, 1976 would be aay different came shortly after noon. It was an urgent message from Lod Airport, now renamed in honor of David Ben-Gurion, who passed away after the 1973 war, Radi contact hid been lost with Afr France Flight 139 from Tel Aviv to Paris, shortly after a stopover in Athens. We couldn't know for sure what had gone wrong. Maybe a mechanical malfunction, a glitch in the electronics. a crash. Or a hijack. But we did know there were roughly 300 passengers and a dozen crew ou board. Many of the passengers were Israelis. and others were Jews from abroad. Tver since the Sabena hijacking four years earlier, whenever a civilian airliner was thought to be under attack within three hous of Iseacl, step-one in our response had been automatic. Sayeret Matkal was ordered to the airport Because I'd communded the Sabena operation the first, and still the only, time we had stacked und freed u hijacked plane — it was probably ineviuble | would take some part in liguring out how. or whether, to intervene if the Air France plane turned out to have been hijacked. But my pivotal role, as the crisis intensified, wis down Lo a combination of facions: my broader experience us sayerel commander, the fact that T now worked in the kirva, just one for up from the chief of staff, and. as so often, pure chance. As the sayeret assembled at the airport, its cunent commander Yoni Netanyahu, my former deputy — was hundreds of miles away iu the Sinai, preparing for an operation across the canal. So it was Mookie Betzer. now Yoni’s deputy, who beg bricfmg the men for 1 possible hostage rescue m case ihe jet veurned to Israel. Au the kirva, we were also without our commander: Motta was in the Negev observing a major militery exercise. So it was his deputy the head of the operations branch, Kuti Adam who buzzed me on the intercom al two in the aflernoon and summoned me 1 his office. By ow, we knew the plane had been hijacked, but that it wasn't heading. back to Isracl. The terrorists had renamed it “Arafat” and ic was on its way to Libya. 1 took the stairs down lo Kut’s office, two floors below mine, and he immediately handed me a lacge, black-and-white acrial photo. 1 showed the incernational airport in Benina. just outside Benghazi on the eastern edge of Libya “Can we do anything, Ehud? he asked me. | didn’t say no outright. But Ttold him that even if we had a treasure trove of intelligence about Benina — 165 which, T soa verified. we didn’t — the obstacles would be enormous. Unlike the Sabena jet, this one was a wide-bodied Airbus, and EI Al had none of those in its fleet, Fen we could find a way ta make sure 4 sayeret team ot briefed on the airizer, we'd be mounting an aek-und-resens operation i thowsimd miles away. And even if we could take out the terrorists, we were almost eettain to face opposition from the former anny colonel who ruled Libya, Mummer Gleddafy. The chance of success seemed slim, the risks enormous. Soon, luwever, Kuti's question ceased to matter. Later Sunday night. Flight 139 took off again. Before leaving Libya, the hijackers freed a passenger: an tsraeli dual national, with a British passport us well, who maniged to conymee them she was going info labor. We leamed through her hal there were four hijackers: two Arabs aod two Turopeans. Tt was a PFLP operation, but included members of the far-left West German Ruader-Meinhaf terror group. They forced the pilot to head for the east African state of Uganda. On Monday evening, it landed at Eolebbe Airport, 20 miles ouside the Ugandan capital of Kampala and just a couple of hundred yards from the shore of Lake Victoria. It wats five dimes Nurther away than Benghi Yet with cach passing hour, increasiugly alarming radio sud television reports focused on the obvious agony of the hundreds of captive passengers. To this day, I"ve never been able to establish why it was a further 24 hours before we started seriously 10 work out if there might he some way for us 10 ree them, Prime Minister Rabin was clearly asking himself the same question, however, because on Tuesday afternoon, hie called Mort in the Negev. It was now a full 53 hours aller the hijacking, he said. Whe the hell we ware doing o try fo come up with a plan? Mota was immediately summoned back to Jerusalem foc an emergency meeting of the government. As he was on his way back from there 10 the irs, Kuti called me back dow 10 his office. “Mots just told them that there is a military option” he seid, with a wry smile. Kui had been a aganeh officer in 1948. in charge of the Golani brigade, head of both the northern and the southern command, nd hid known Motta for years. “hal means we now have w find one” Thad just begun briefing a few of the analysts in my office when Motta retumed. When 1 gat to his office, Kuti waved both of us eros the hallway to the big. rectangular conference room where general stall meetings were held On the side of the room veas a globe. Giving it a spin, he said: “Ni. Motta. Tell me, when you told the government we had a military aption, did you even know where Gntebbe is? Motta didn’t so much as crack a smile. “We have to (ind a 166 sesponse,” he said. “I've committed us. Thud, Twant you 10 check what can be done. Take whatever you need, from wherever you want. Bring me suggestions by seven tomarmow maming.” Then, he said, we would ga brief the Defense Mimisier, Shimon Peres. Lassembled a Lean the same way we'd prepared for special-operations missions in the sayeret: looking; for information, intelligence and above all experience and msight from whoever | thought was likely to make tht ahwuys- narrow difference between failure and success. My firs alls went to Mookie Betzer and another of my most trusted and experienced sayeret comrades, Amiram |evin, Then | brought in Ido Ambar, the personal aide to air force commander Benny Peled. and Gadi Shefi, the commander of the Shayerer 13 SEALS. Finally, two oflicers from Dan Shomeon’s office. Since Dan was kenizhar, in overall command of paratroop and infantry forces, it was critical to Keep bit in the picture. T10ld them all that we’d be working through the night, and that T had to be able 1o tell Matta and Shimon by the morning whether we really could mount a rescue mission. Util thought 1d end np Baving to tell them no. However difficult the absiackes we'd faced with Sabena, they were almost childs play compared ty getting a sayeret assault team 5,000 miles across the continent of Africa, surprasing the terrorists, Freeing fhe hostages unharmed und getting them out. That wes even assuming, ws | diel at that pout, that we wouldn't fee armed opposition from the woops of Uganda's increasingly Lyrannical president, Idi Amin, Amin had begun to align himself polincally with the Palestmians m the past Rew yess — one reason, no dob, the lerorists had landed there. Bul he had actually been on a pacalroop course in Israel befoce taking power in 1971. We had sent officers to bilp wain his army in the early 1970s Now, [ discovered, Mookie himselC had been on ne of the tram missions. “Uheir men acen't great fighters. at least at night,” he said. au insight of abvious relevance fo planning a commando attack, if we could get that far. When Ambar, the ar force wide, spoke np, 1 finaly began to feel we might at least be able to put together the outline of a plan. 11e’d brought with im a copy of the standard reference book on world airports. which gave us at least a general idea of the Liyout of Entebbe, He alsa said that the air foree bud run 4 training program for the Ugandans. In Entebbe. He'd contacted one of the reserve pilots who had been on the training mission. and he was on his way to joia us. Sill, time wins shor we were nowhere near being able to recommend a specific plan of action. The hijackers had set a deadline — noon va Thursday. 167 Tuly 1. 00w less than 36 hours away. Uaving moved the passengers off the plane to one of the terminal buildings. they were threatening t stact Killing then unless we freed a list of 53 Palestinians and PLO supporters, farty af them held in tamed nd the rest in a nue of Fusopen countries, ind pid a smsom of five million dollars. Well past midnight. we started looking at our options. One which seemed — briefly fo hold pramesc drew on suggestions from (do Ambar ind Moot: o's almost shiapsodic description of the capabilities of our C-130 Hercules transporte planes convinced us we could parachute in a Sayeret Matial team, as well as vehicles for them to use on the ground, Mookie and agreed that to csure surprise, we would disguise the commandos ss Ugandan woops, in “Ugandan” Jeeps. The final twist came with the arrival of the reserve aic force officer who had been on training duty in Entebbe. He brought a reel of fmm film [Tom a0 official cecemany at the airport. AL the star, a Ugandan army general could be seen arriving in a black Mercedes. “That's iL” Mookie said. “The Mercedes. Every top Ugandan miliary officer has one.” We decided to svar ome of our Jeeps far jet-bliack limousine Yet by daybreak on Wednesday. when | went up wo brief Molo, we'd set aside the option of a parachute drop. Any initial surprise would be outweighed by the risk of exposure from the very stmt of The wssault. We'd also one cold ana second option, lo infilfeate sayeret teams aloug the shore of Lake Victoria from across the nearby border in Kenya. T doubted we had enough time 10 navigate ull the operational and diplomatic abstacles before the deadlme expired. Tha loll option three: living the SEALs. along with a core wim from the sayeret, parachute onto Lake Victoria with rubber dinghies and attack the airport trom on foot. We arranged to do a test parachute assault off the Israeli const in Hifi hater in the day, but if that went well ii seemed the only practical alteraative. Motta and T went met Peres around & 30am. Shimon had no first-hand mihtary experience, hav played 1 political vale alongside Ben-Gurion from tsrael's early years. So lie was uot really interested in the details. But he wats keen to hear our assurances that a military option did exist. TTe was even more intrigued when we were joined by the head of the air farce, Benny Pele. Unaware of the sithorne parachute drop we had been discussing overnight, Peled suggested something fac more ambitious. Rather than using a single Hercules, he proposed usm four of fhe want transport planes to ferry in a kirger force, some 200 men in all, land them on one of the runways and take over the 168 entire airport. Though T dida't say so, T had my doubis it would work. Tt was a bit like the initial option for the Rue Verdun raid Dado had rejected: a classic ground assault which, in addition ta eliminating any chance of suprise, obviously ran the risk of igniting a small ground war. Bu 1 did think that some combiuation of Peled's idea and the surprise commando strike we'd been looking at might provide an answer. A few haus biter, the hostages” ordeal took chilling turn, which soon alsa provided us with our first real detailed picture of the scale of the challenge we taced. In a haunting: echo of the Nazis “selection” process in the Holocaust. the terrorists separated all the passengers with [srueli passports or Jewish numes, They lot the rest of them go, aud allowed them to borrd a special Air France: flight back lo Paris. We immediately dispatched Amicam Levin to debrief the freed passengers. On a sccambled feleprinter line Wednesday might, Amiram came up with fac more than we could have hoped for. One of released passengers was a [each woman who had managed to hide the fact she was Jewish. She confined reports we had been petting that the hostages were being held im the airport’s Former feminal building, about a mile Fron its newer terminal and the main cunways. Other passengers revealed that the hijackers had placed explosives around the old terminal building. And that, despite my hope that Idi Armin would stand aside if we diel decid 10 go in amd vesen the Tostages, his troops were helping 1o guard the area. So in addition to taking on the hijackers, we'd have to find a way to deal with Ugandan soldiers. In another round of discussions in my office through the Hite hours of Wednesday night, we Finally seuled on onr plan: Peleds nusjor airborne operation. but with a Sayeret Matkal suike Sorce, with its “Ugandan” motorcade, spearheading it. Minutes later. three other C-130s would fly in additional Iroops to secure the rest of the siport, deal with any Ugandan army sesistance, and fly out the Tseaeli soldiers aod the hostages. An operation on that scale naturally meant bringing in Dan Shoniron. After I'd taken the plan to Kuli Adam, he briefed Dan on the full detail and called me dower 10 see hint again. Den had left 10 start preparations for the vperation. He'd made just one request, Kuti said: that Tbe in command of the sayeret force. PRO 169 Tcould see why Dan bad said it. Working with Mookie and the rest of my team, ['d been in charge ofall the initial planning. | was in command of the Sabena assault, the only remarely similar aperation Israel had attempted, Thomgzh ui stent la rescue dozens of lerrificd hostages in Enlebbe, with both the terrovisis and possibly Ugandan soldiers armed and ready, would be much harder. As Sayeret Matkal commander, I'd conceived and commanded other missions thal tequiring us 10 break new ground. Bul — and it was a huge but — ( Anew from the moient 1 lel Kuti's office that | would have to find a way to avoid undermining the current sayeret commander, Yoni. Dan had clearly been aware of that as well, He'd stressed fo Kuti that he meant ne disrespect to Yoni. “But | know Lbud.” be said. “Uve worked with hin. | want hin to lead it.” Yoni was still in the Sinai. I'd phoned him before our first overnight planning session to tell him 1 was hemging in Mookie and Amitam, Mookie had been giviog him daily updates. Bui the clock was ticking. Under the initial deadline, the hijackers had theeawned Lo begin “exceutions™ on Thursday. Today. The deadline had now been pushed back. but only uncil Sunday morming and only aller Rubin fell hie had no opiion but 1o drop ow public refusal to consider negotiating with them When Dan called our first operational briefing for Thursday night, Mackie sent plane to bring Yoni back, an set out the plan with ns customiry contidence. The four Hercules would take off on Saturday evening from Sham el-Sheikh at the southernmost tip of the Sinai. to cut the Nying distance at least slightly. The first plane would kand on the runway near the new tenmmal, Inside would be a small wil of paratroopers, the sayerel strike force, a pac of keeps and the Mercedes. The next Teccules wouldn't arrive [oc another seven minutes: the most critical minutes of the whole operation. That was when our “Ugandan motorende” would make its way 10 the old iennmal, burst in and tke care of the tercorists. The second Tereules would include another Sayeret Matkal wean, to reinforce the arcack unit and secure the perimeter of the old terminal. Ilercules Number Vie, s mime later, would carry # joint farce of sayerer. fighters, paratroopers and a Golani team. Their job would be to take over the new terminal and the rest of the aizport and deal with any Ugandan ary resistance. The finul plane was a flyin medical unit, ta pravide treatment for the hostages and carey them back 10 seac] Yoni arrived just as Daa was finishing his presentation. Ie looked focused. energized, and eager to play his part. 1 realized it was important to explam fo him the decision to place me in command. Despite our close relationship, T 170 Lacw that would be a sensitive task. We spoke only briefly before he and Mookic drove back 10 the sayeret base to begin more detailed preparations. Yoni was insistent that he should be in charge. {told him | understood. and [ did. In bis position, | would have fell exactly the sme way. Bul for a variety of seasons, Den wanted me in command. tll, siessed ny determination aot to detract from his authority. Yoni would lead in the main assault unit. ITe and Maokic would choose the other uflicers and soldiers, decide their roles and tale charge of waining, bricting and logistics. 1 could tell he was still not satisfied. But 1 told him and Mookie Id join them later that night, We could talk further, ahead of the next full briefing, which Dan had set for nine o'clock on Friday morning ou the sayeret base. When they lel. T joined Daa. Motta and Kuti fo go see Rabin. Shimon Peres was there toa. He would liter say that, as Defence Minister, he was i crucial voice in pressing to go ahead with the rescue mission. [1e’s right, and had he been sceptical. or opposed the idea ofa recuse, it would have made things much more difficult. But his position was far easier than the Prime Minister's. Ile ticked Rabin biancls-on corrmand experience, his grasp of the detsils of what we were proposing to do and the abvious risks. All Istaclis were aware of this. | the operation failed, or if we decided in the end not to attempt it it would be. Rabin who would bear the responsibilty and get the blame. ven under the host of circumstances, Rabin was naturally cautions — the flipside of the meticulousness with which he ran through the fine detail of every military mission. As | remembered from when he was chief of staff, in our slightly surreal conversation ahoul the danger of @ buoby-trapped communications intercept exploding as T defused it. he would focus on everything that might conceivably po wrong with an operation before approving it. Now, he wins also under hinge sedfitonial pressure. From he start of the hijick crisis, there had been calls fiom the hostages” families to do something to cod the ordeal. Bur as I later discovered, one of the leading scientific engineers in tel, Yosel Tipman, had i daughtor among the passengers. Like Yitzhak, he liad been a Pelmachnik. e'd come Lo see the Prime Ministec and implored lit 1ot to attempt an operation that might endager her or the others. “I demand one thing only,” he said. “Don’t 50 an any adventures. Da not play with the lives of these people, with the life of my daughter.” Aller Tatebbe, there would be suggestions that Rabin’s readiness to negotiate with the terrorists hid been a ploy. designed ta buy time, Yet his message to us (hat night was that if there was a military option with a 171 reasonable chance of success. be would approve it. But otherwise, we could not let dozens uf hostages be murdered if by talking, even deal-making, we could have saved them, He fumed to Dan and asked whether there indeed was © suilitary option with a ressonable prospect of get the hostsges oul. Dan said yes. Rabin turned 0 me nest. T agreed: we had a plan, and we felt we could make it work. Motta was a bit more hesitant. Ile suggested we couldn't know for sure until we'd finished wating key parts of the operation. But for Rabin, it seemed 10 me Dan's was the key voice. $0 he told us thal he was approving it In principle, He said he still needed answers to two questions. The first was whether it was physically possible 10 cross Grom the new terminal arcs, whore we'd be landing. to the old terminal buidling. [Te wes right to press us. IF a retaining wall ora drainage trench hud been added druing the modemization work on the airport, any element of surprise could be lost. Rabin's second condition was that we find a way 10 make absolutely sure, by the time the first Uercules landed, that the hostages were still in the old terminal building. T knew why that nonbled him, From a remark 1°d heard him mike a few years earlier when deseribing an American hostage-rescuc raid behind enemy lines in North Vietnam. That aperation went exactly as planned. Txcept that the POWs had been moved. Ldsove 10 sce Yoni aud Mookic at the seyerel base. We spent most of The meeting on the opening few minutes of the operation: the rolling out of the vehicles, the drive to the old termmal, and how to handle the possibility that we. sight meet Ugandan resistance. Mookic renmived adamant about the Ugandan. [rom his time taining them a few years earlier. Even if we did run into a aroup of Amin’ troops, even if they Were armed, even if they were pointing their guns al us, even if they shout at us 1 stop, they “wouldn't dare open fire on a Mercedes. T trusted is experience. 1 kept emphasizing that we had to go in with the mindset of nor engaging Ugandan troops unless there was nor chonee. [we did need to do so, we would nse only small, silenced Berets since ['d made sure the unit trained on the Berettas afler Sabena. Talso raised another critical condition for success. “There will definiefy be an armed presence im the control tower,” | sad, We needed to desimate a special unit whose sole job would be 10 twain machine guns, rifles aud grenade launchers on the tower as soon as we got off the Teccules. “The moment that we lose the clement of surprise, they apen fire.” 172 Dan began the next mocning’s briefing wilh a stape-by-stage review of how the operation would unfold. But just as he was gating to the detail of the motorcade attack, [ felt a young sayeret officer tap me an the shoulder, Kuti had phoned 10 say [was 10 go see bin al the kira. “He sid immediaely.” the alficet added, “and not lo discuss it with anyone. Just to tell Dan Shomron that you've been taken out of the operation.” PEE Ta say [was surprised would be an understatement. But 1 allowed myself to belive the decision t “take sue oul” could still be reversed. Not anly was | seady Lo command the critical Jisst pact of the vperation. T believed Twas hest phiced to ensure it succeeded. [felt that was best for Yoni, too, due ta fensians inside the sayeret of which both of ws wore aware. There was no uificer to whom | was closer than Yoni. |e had extraordinary strengths as a soldier: in the Six-Day War, in 1973, and afterwards when, with my encouragement, he'd taken command of tank battalion m the north ff lost in tatters fron: the Yom Kippur War. But there was more 10 Jim as well Lused to marvel how ar the end of 16 hours of sayeret training, he could spend a further twa or free reading history, or a novel or poetry. He always steugeled between the impulse to devote bis life to fighting for the State of (sacl, and Lo studying, reading and living as a more “normal” family man. His drive fo serve, and to excel, was stronger, Tuti Goodman, the youn worn hed et as a teenager and married, anderstood what drew him 10 w hfe in uniform. Bue that wasn't what she had signed up for. At one point, Youi asked me to speak to Tuti, She asked me to speak to him. 1 did my best to explin such 10 the ther. But the gap between what cach of them wanted for their lives was just 100 wide. Before the 1973 war, they’d separated. Afler the war, professionally fulfilled but personally shattered, Yoni heard that 1'd found wn apartment in Ramat Hasharon, and he asked me if there were other flats m the building. 1 turned oul that the over of the tat below ours was willing to tent it. Yoni sapped it up. Over the past year or so, with Yoni leading the sayeret and me in the kiryu, we'd seen more of each another. For the irs tine in years, he seamed lo have fond a sense of peace, und fulfillment, in his personal life, That was m large 173 pant because of Bruria Shaked, bis girlfriend, whom he'd met while commanding the tank unit fier 1973. While be was a thinker and a brooder and in many ways a loner, Bruria was outgoing, playful, funny and full of life, She sensed his need for a shonlder 1o lean on, i hand lo hold al the movies or on i Satucday stroll on the beach. They made their apartment & home. The shelves crezked under the weight of Yoni's books. Often on a Saturday. when Nava and Udropped in 10 see them, au old 33 rpm record would be playing on the stereo. Yoni would be sitting pulling vn his pipe, reading, and smiling. But outside this domestic haven, he still struggled. [Te had looked forward to commanding Sayeret Matkal, But there wis a grown distance between him wid those hie fed. a kind of dissonance between these more typically Isai youngsters and the aloof. reflective. intellectual side of their commander. There was anather tension as well Sayeret training was notoriously tough, Yoni earned Lhe admiration of his mea by participating personally in the most difficult of the excceises. But just as he pushed himself Lo his limits, he insisted relendlessly on seeing the same drive in them. This was a challenge all sayeret commanders faced to some extent. | had, oo. But a number of the officers had onc 10 the Aira to urge that Yoni be replaced. Ile knew this. Though I tried to reassure hi. telling him that every sayeret commander was ditferent. with his own strengths and weesknesses. he becime only more determined to push limsel (and those around him harder. No we were ia the final countdown for Tntebbe. Tt was a life-or-death mission not just for us, but the hostages, an operation in which even a second’s hesitation or tension or uncertainty could prove fal. 1 was worried that the sumblings of uncasiness in the unit might prove an additional obstacle that wasn't worth the risk When | ined lo pensusde Kuti lo stick with the original plan, however, he was ingistent. 11¢ told me 10 get ready 0 My not inw Uganda. but to Nairobi. ('d been re-assigmned to accompany a Mossad team to Kenya. Our first task would be 10 gel the answers to the questions Rabin had asked us, Then, we would bem cliarge of ranging for the Ketyaus tw allow us to refuel the C-130s ou the way out, and to setup a medical facility for any injured soldiers oc hostages. During the attempted rescue, | would ilso be the chamiel of communications from the Nairobi side of the aperstion lo Kuti. lens of thousands of fect ahove Eniebbe in a command 707. Dan, as overall commander, would be in charge on the ground 174 xoxo The Kenyans were not exactly allies of Israel. But relations between President Jomo Kenyuttu’s security services ind Mossud had been close for some years. T flew in with theee leading Mossad men. While one of them called on the aging President Kenyaea, our main point of contact, was the head of Kenya's security services, Since the secrecy of the mission had to be preserved, we couldn't make advance preparations for refueling or the additional 707 which we intended to fly in as a field hospital. But he smoothed the way for us to do both, withaut anyone asking too many questions, The Mossad men took The lend in anangmg lo get Rabnts questions answered. They contacted 2 pilot they knew. The pilot flew to Entebbe carly on Saturday moming, circled, and, after he was cleared to land. claimed cchanical difficulties and few oul again. | had his telephoto pictures by mid- morning and phoned Rabin’s intelligence officer to let him know we'd confirmed there was a clear path to the ald terminal, We still had to make sore the captive passengers were there, however. A nurse from Kampala who had been allowed ww visit them made three further visits: late Saweday afternoon, then shortly after the first Hercules had raken off from Sharm al-Sheikh, and finally round nine ut night, | was able ta reussure Rabin that the question to his seeond question was also “yes”. Although all of the C-1305 were weady airborne, it was only then that he pave the mission the final go-ahead. As commander of Sayeret Matkal, I'd always found running an operation from a command post hugely frustrating. | his was even worse. Once we got word the Tseaeli force was on the way to Usanda, we put in place the arrangements for refueling. [f all went well. the first C-130, with Yoni's assault team and at least some of the hostages, was duc to reach Entebbe and beg the assault at midnight Saturday. Assuming there were no major problems. it would take an hour at most. All £ could do now, from 300 miles away, was wait. Shartly atter midnight, Kuti radioed me with a terse message: the first of the Uercules had left Lotebbe for Nairobi, and the command plane was returning 1 Israel. About quartet to one in the morning on July 4. the transport planes began their staggered arrival, When the first Hercules taxied to a halt, | went out to meet it As ils giant rear door lowered, Dan was the first person | saw. | could tell from the awkward silence, the lack of any greeting, something must have 175 gone wiong. “Thud,” he said ually, “Yoni's dead. We got the hostages oul But Yoni was killed. [sought out two other friends: Moolcie and Ephraim Sneh, the Battalion 890 doctor, who had been with us at the Chinese Farm, Both were obviously tam between a sense of accomplishment iu having freed the hostages and the blow of losing: Yoni. I asked Ephraim to take me to the ront of the plane’s huge belly fo see im, He was on # stretcher, covered with a blinket, [peeled it back. Yoni's face had lost all color. Bul when | wuehed his forehead, it seemed slighty warm, almost as if there was still a spark of life inside him. [couldn't rise Kuti by radio, so 1 used the landline in the airport director's office fo phone Molla, “Yoni is dead.” Told him. “Are you sure?" he asked. [ said: “Yes. I've seen him Before the transport planes began leaving for trac, made another call. I was 10 Nava. She was asleep. | wld her that the upecation wo free the hostages had succeeded. “But Yoni has been killed.” 1 could hear her rasp. “Listen.” 1 sand, “you have 10 ro downstairs, ‘Tell Bruria, Before some army officer shows wpa her door. Or worse, because they're not marsied. no one may come and shell hear it on the radio. Go. Tell her. Stay with her.” At first, she seemed not so much unwilling as unsble to do it, “What can [sap Usaid knew how bird it would be, but that she needed to make sure Bruria heard thie news from a friend. Later, Nava told me she'd waited until daybreak. not wanting to make things worse by waking her, Then, she went downstairs, She told Rruria what had happened, stayed with her, talloed with her, und held her, during those Grst few awful hours. I found Yoni's death even more upsetting when 1 learned from Mookie and others how it had happened. As the sayercl motoreads: hen making its way from the Lereules to the teeminal, with Mookic and Yoni in the Mercedes, two Ugandan soldiers had seen them. One of the Ugandans raised his rifle. Rather thin relying an Mookie’s assurances he soldice wouldnt setually fire, Yoni nd another soldier shot him with their silenced Berelias. But they'd only wounded him. Tn case he managed to fire back, another soldier in the Jeep behind them Killed him, with his we-sifenced machin gn, Now that all surprise was gone, the commandos abandoned their vehicles and began sprinting: towards the old terminal, Only seconds later, still 80 yards 176 or 0 [rom the terminal. Yoni was hit. Tied been shot front the control tower. [ realized that unexpeeted setbacks or slip-ups were inevitable in any operation. But the crucial first stage of the attack had not only gone wrong, 1t bad gone wramgz in exacrly the wity that we bid first discissed buck a he sayeret base, and now Yoni was dead because of iL. I had to remain in Kenya for a few more days. Though we'd rescued 102 passengers and crew, three of the hostages hid been killed in the crossfire. While most of the injuries 1o the others were minor, we amanged 10 have several of the more seriously wounded taken to a Nairobi hospital. So 1 was unable ro join the gathering of hundreds on Mount Herzl in Jerusalem for Yoni's funcrul Or 10 hw Shimon Peres praise bin in lerms [knew oust have Alled bis parents and Bibi, wo, with enormous pride. Shimon described him as “one of Israel's finest sons, one of its most courageous warmiors, ane of its most promising commanders.” I'he fiest evening | was back, however, [visited hie Netanyahus at thei family home in Jerusalem: Ben-Zion and Tila, the parents: Ido, the youngest of the three children, nd Bibi, who was still al MIT. 1 was a few nights m the shiva, the seven days of mourning, and there were dozens of wher well- wishes there as well. I spoke to Bibi first, outwardly strong but I sensed still overwhelmed by their loss, Hugging im, 1suid the weeks abead would be Tough, not just because of Yoni®s death, but because much of the respousibility of providing emotional support for his parents. both in their sixties, would fall on his 26-year-old shoulders, This was the first time 17d met the father, Ben- ion, face to face, but | was struck by how this balding, professorial Tigre seemed able 10 keep inside the pain and loss be must have been feeling. Tle did clearly know of me. both from Bibi and from the frequent letters always wrote 10 him at Comell. Now, afler I'd suid what {conte to comfort him, be asked whether we could meet again. When wee did, a few days later, be was clearly conscious of the his late, lost son's beureeoning place in Ismel's pantheon of mations] heros. He asked me 1a be ane of the speakers al Yom's shloshim, 4 conuuemorative eval in Jerusalem which. in Jewish religious wradition. would mark the end of the first month of mourning. “You knew him well.” he said, and praceeded to stress the impartance of using my remarks fo explain, and elaborate un, Youi's powerful accomplishments and personal legacy. thought about what he wanted. and about Yoni himself, in the days ahead. About the fragedy of his death, but also the way m which ull of us now bud to draw meaning, value, and ideally something of permanence from the feelings of 177 Toss. As T prepared my notes, 1 also spent time working out how to square what 1 felt T needed to say, with what many in the audience, and cenainly Ben-Zion and Rib, would exper me 10 say. Not only was Yeni being mourned across tne aller Enlebbe. He was being elevated — in the spirit of Shimons words al the funeral ~Lo something approaching sainthood. [ did aol want to detract from his evolving stars as national hero, or his importance as a symbol of a cominiando success which had, for the fiest time since the 1973 war, restored a meesuce of laracli sense of self-confidence. A vietory, over all logic aud all odds. But [ also wanted to find a way of capturing Yoni as he really was: a brave man, an extraordinary fighter and officer. But alsa a man sometimes Reeling tor inside, and alone. Thegan with words of ancient rabbinic wisdom about the path which all of us travel from birth fo death, and to whatever comes after. The quatatian [ chose from the 2,000-year-old volume known as Pirked Avot, the Ethics of our Fathers — seemed right o me. “Know where you came from: 2 puicid drop... Kaow where you are going: to a place of dust, maggots and warns... And know before whom yon re destined 1 give your final accom, the King of Kings.” | spoke al the loss of Yoni, and said it was impossible not to think about the meaning of what lay between the “putrid drop” where each of us begins our life and our final seckoning. “Cbeheve that Hl is wot just sum of the hours and days between the beginning and the cad. 11 is the content we pout inw the space in between,” I said. I'd known people who were given the gift of a long life but who, by that definition, had hardly lived at all. There were also people like Yoni. l1e*d lived cnly bricily. But he had learned and loved. Fought and trained others to fight. Grappled with the most profound puzzles of existence, and yet remained apen “to the wonders of a smile. A journey. A flower. A poem.” If there was any consolation for a life ended cut off at age 30, Usaid, that was it. But T wanted to give a more personal, nuanced picture of the life that he, aod we. and lost. “Our Yoni... We have seen hint torn becween his passion for Knowledge on the one hand, and the sense of mission and of personal fulfillment that he found in uniform. There was the Youi of histocy and philosophy hooks: Plato and Marx. Wha sav the history of Israel not just as 2 compendium of facts. but a source of inspiration, and a call for action. The Yoni who rebuilt a tank baualion reduced tw ashes and dust on the Golan. And there was the Yoai at peace. Tranquil. At home. With his pipe and his phonograph records. out of uniform. We saw him in his hours of supreme achievement and satisfaction. We saw him, foo, sometimes standmg alone, with pin m his hit, bitmg bis teh, 178 carrying the heavy, lonely burden of commanding the very fighters who be was leading when he (ell. “We have seen him on fae bartletield. engaging the enemy, heading into a test of fire with conrayee and wisdors znd his indomitable spirit the very essence of the spirit that made possible the operation in which he would lose his le." Because, make no mistake. [ said: beyand the weapons used, the people who participated, the training and exercises before the fleet of Hercules had taken off: heyoud the fine balance required in the planning, execution, and decision-making; it was “this spirit, this essence. that was tested at Entebbe.” When 1 sa Yani's family afterwards, though they thanked me for my semuntls, [contd see thal they were sill bloedmg inside. 1 am suse tha a Rected they way they related to Bruria. Tven before Yoni met her. he had told me how hard his parents were finding his separation from Tutti. Bruria uftended the Timeral und the shloxfin. Bu she ida’ sit wath the family, think that with the shack of his death, mixed with the pride they fel at his cmerzence as a national hero, they found it ditficult to include her. a woman they hardly knew, in their moumime. A few weeks later, go a call from the Netanyahn nily’s lawyer, Erwin Shinron. It was an odd. rambling conversation. Ile seemed to insinuate that, as her and Yoni’s neighbor and friend, [ was encouraging fae unwelcome ide that Brutia was pant of the immediae circle of the bereaved, tit this mere girl fiend was somehow his widow. [le wanted me to withdraw whatever mantle 1 might be providing, and help separate her fram Yoni and his legacy, He went so far us 10 ay that one reason he was calling me was because hie didn’t want lo bisve to take “legal steps to make that happen. 1 saw no point in getting into an argument, 1 sensed thar, while it would fake time for the grief felt by those closest 10 Yoni lo begin lo heal, the wssue wonld gradually resolve scl Bul 1 saw even less point in leading the lawyer 10 believe | would do what he was supesting, “Mr Shimron,” {told him, “1 lmew Yani, 1 know Bruriu. | do not know you, But T have a musical ar. T don’t like the undertone Thear in what you've been saying. I've seen them close up. Bruria gave Youi, at a critical time in his lite, prabably more warmth thin he ever received from any other human being,” 179 Chapter Eleven Yet despite Dntebbe, the trauma of the Yom Kippur War. and the cracks it had shaken loose in Israeli society and politics, were ye to play themselves out. The hostage reseue was like a sugar rush, an intoxicating reminder that the army till had the capacity foc initiative and precision. audacity and quick-fire victory Tike our air strikes in the first hours of the 1967 War, Bur the real reckoning over 1973 was whoul 10 come. 1 wonkd change Israel beyond recogmtion, with repercussions still being felt today. IL would deamatically alter the course of my life as well [still remember the moment it hit home, on the evening of My 17, 1977. As. Neva und | watched i our finy living vom in Ramat Hasharon, Chaim Yavin, the anchorman on the country’s only TV channel, was handed an exit poll from Israel's latest national election, He bean with three words: Gviriai verahoia, Mahapakh. “Ladies and Gendemen, revolution.” For the first time since the state was declared. Tseael's government would not be in the hands of David Ben-Gurion or his Labor Zionist heirs, Our next prime minister would be Menachem Begin, wha had inherited the mantle of Jabotinsky’s Revisionist Zionism. Tle'd headed ifs youth wing, Bear, in eastern Europe, and led the Irpun Zvai Leumi, the main right wing militia force before 1948. Lacking the intellectual depth and subilery of Jabutsinky a liberal intcllecinal who, among ater things. translated Dante into Hebrew — Begin drew his political strength from his powerful oratory. and a refusal to countenance any compromise in sceurmy whl he viewed as he ultimate goal: a Jewish state in all of biblical Palestine, from the Mediterrancan to the Jordan River, with whatever military force was necessary to secure and sustain it. But perhaps Yavin should have used a different metaphor in his dramatic election-night broadcast: reidat adamah, an carthquake. Begin's victory, afler the loss of eight straight elections over three decades, was the culmination of seisinic rumblings which liad been building for years. The big, decisive, shock wes the 1972 war. Yel this was not just because of the colossal intelligence failure, or the mysiad errors of our militacy commanders and political leaders. Tt was the fundamental loss of fru in the cosy, self-perpetuating establishment hit had dominated ull aspects of Grech polis, soerety and culture from the start: Palmachniks like Rabin and Dado; political players like Golda and Shimon Peres; 1laganalh veterans lie Dayan and Bar-Lex: and, of course. the Kibbutzmik ploncers. Almost all wer: of Hast European background 180 Ashkenazin — and their prominence and privilege had stoked increasing resentment anong Isael’s disadvantaged Sephardi majority, with theic cots in the Arab world and especially north Africa. Bein not only sensed this, While he'd never lost the formal bearing or the accent — from his childhood in Poland, his loug years in Iseacl’s political wildemess mimored the wider exclusion felt by the Sephardi. The last election he had lost. in December 1973, proved too soon for the carth tw part. But he told his suppress: “liven though Labour has won these elections, afier something like the Yom Kippur War happens to a country, and to a government, they must lose power. They wilf lose power,” He was night, Only twice in the four decades that followed would a Labor leader defeat Begin's Likud party: Rabin’s election victory in 1992, and mine over Bibi Netanyahu jn 1999. During the first twa vears of Begin's rule, however, | was 7,000 miles away. Ten days before the election, 17d gone fo see Mot, and hed agreed tha 1 could return wo Stanloud, 10 finish what I'd bacely begun when the 1973 war broke out. [nad been in the amy, with the ane hiatus as a sayeret reservist at Hebrew University, sme the see of seventeen, [did not regret committing myself to life in uniform. But Stanford offered an extraordinary opportunity lo broaden my horizons. Even in the tew weeks 1d spent there before the war, I'd felt reinvigorated. It engaged o different kind of meelhigence, a different part of who was: the books, the professors. A chance to listen to, and al least uy 10 play. beautiful music. And to spend more than a few stolen evenings or weekends with my family, The timing hae nothing 10 do with the election. ike most other hor Israelis, and many of Begin's own supporters, I hadn't expected the Likud to win, It was because [ felt I'd reached a natural punctuation mark in my military curcer. I'd led Sayerer Matkal. 1°d commanded a tank company, 3 bitualion in 1973. and, more brictly than 1'd hoped, the 4017 Brigade aller the war, I'd speat the last twa vears in the kiya, The next step up the command chain would be to lead i full armored division. But at wee 35, | was probably toa young, und | figured I'd have a far better chance in wo years’ time. | also feared losing the chance 10 go to Stanford altogether. Motta’s term as chief of staff would end the following year. Among those m the frame ta succeed him was Rafial Fitan, Recalling Raful’s dismissive, almost sneering, opposition to my makiug the Sayeret Matkal into Israel's SAS. [wasn't exactly confident I could count on his support. 181 Reluctant though I'd been 10 leave the 401 for the kirva, Thad partioulacly enjoyed the last year. | was promoted to Shai Tamaris job, in charge uf the intelligence team for our military operations, when Shai left to command a tank bagade. My office was no longer on the thivd (oor, bul m the underground bunker, the bor. [wes part oF nearly all high-level planning meetings, oflen with Motta, sometimes also including Peres. Almost everyone around the table was alder than me, and owrenked me by some distance. Yel with my intelligence brief, 1 was ofien the one with the most thorough command of the details. Though still just a colonel, I'd risen through Sayeret Matkal. 1 knew the planning process trom the other side as well, having attended the same sort of meetings, from the carly 1960s, Wo present our operations. So | was oficu asked, and always welcome, to weigh in on what would work, what wouldn't, and why. My final yea in the Airy also lucther cemented my relationship with Motta. Though as chief of stall, be tended to keep a formal distance from all but his fellow penerals, he did seem to enjoy having me around. Ile even put me in charge of wnew depatment of my own. Not officially. The *depunmen” was strictly ad hoe, as was the name which Motta gave it: Mishugas. The Yiddish word for craziness. All army commanders, in all countries, receve their shire of imsolicited advice. Bu [can’t imagine any of them gets the number, or sheer range, of wild suggestions which make their way 10 the kirva. Cverything from levitation michines, to ideas for making tanks fly. Motta didn’t have the time to read all ihe fetes, much less sit down with the self-styled mventors or sages who showed up in person. Still, he couldn't be suce that a jewel of an idea wasa't lurking inside one of them. As an insurance policy, he began sending all the letters, und every supplicant, to me Lnever found Lhe jewel. he most vivid memory have is ofa visit from a former soldier in Shasked, Israel's Negev reconnaissance and tracking unit, He had taken np meditation, und the study of ancient civilizations, Fresh from i period of contemplation iu the desert, he arrived in my office with a pamphlet he'd written. Tt was about special-forces strategy and waining, as practiced eight ceniuries carher, in the time of Genghis Khan, listened for sierly am hour, enjoying his enthusiasm, the listory lesson, and the simple weirdness of it all. I did check his facts afterwards. If nothing else, he proved an wssiduous student of the Mongols. He explamed lo me tha in heir largest battles, involving tens of thousands of troops, they would designate a 182 commando uni of a couple of dozen men. Tis sole task was Lo seek out and kill the caemy force's leader. The key io their success was mind-tcaining, Over a period of months, sometimes years, the commandos” seif-percepiion was altered. They were Taught lo believe tian they bid already died. Since theit lives an earth were done, all that remained was a formal passage through the tunstile into eternal happiness. and to go out in glory. My visitor not only suggested that trae] establish exactly this kind of death-cum-suicide unit. He volunteered to cain the men himself, and lead the fist mission. With as straight a face as | could muster, 1 thanked him for taking the time fo see me. But I told him his idea was probably not for us. Little did [ know that a whole new kind of enemy, epitomized by Al-Qaeda and the sel styled [slamic State, vould build a terrorist death cult around it PREV Nava aad I. with three-year-old Yas], and Michal just turning seven. left for Cahfonma in the lale summer of 1977. The two years that lollowed were uplifting and reinvigorating — aot just because of Staaford. but a fucther, utterly unexpected transformation back home soon after we'd left. It, 100 had 1s roots m the 1973 war, but on the Arab side, Before the war, Egypi’s Anwar Sadat hed extended feelers sbout the possibility of peace negotiations, only to see them ignored. Israel won the war in the end. But the Kiyptians” surprise aftuck ueross the canal and the panic and huge Israeli losses i the early days of the war — had shared our ana of invineibiliy. Politically. Sadat had gone a long way lo erasing the humiliation of 1967. That freed him to do something which — after decades of Arab-Israeli contlict was wstomishing. He travelled fo Jerusalem, The capital of w country which neither Ceypt nor any other Arab country even recognized. Tle met Begin, and he addressed the Knesset with a call for peace 11 is impossible to convey To Tsractis who did not live through the bizth of The state, and our lumultuous carly decades. the power of the emotions stirred by Sadat’s visic. It was on November 19. 1977. With my arm around Nava. T watched the five American television coverage us Sadit’s plane touched down a Ben-Gurion uivport. Begin was at the center of the thong of dignitaries on hand to greet hin: a who's who of political and military leaders not just from his administeation, but who bid led Issel in 1967 and 1973. Golda was there. 183 Rabin, 100, pulling fuciously on his cigaretie. When the erect figure of Sadat emerged, there was spontancous applause, and a serenade from [sracli army frumpeters, Even before Sadat’s Knesset address the next day, | understood that his visil, his willingness to make the first, bold move loward a possible peace, marked Just the beginning of a difficult negotiating road. Bur there was one passage in his speceh that touched me especially. He ran through the history of how Fgypt and other Asab states had not just Fought Israel, but denied our right 10 exist ag a state. “We used to brand you as so-called Israel.” he said. Now, the leader of our most important Arab enemy declared: “You want to hive with us m this purt of the world. In all sincenity, [ell you that we welcome you among us, with full security and safety.” The formula he proposed was straightforward. Fizypt would agree to a full peace, scceptmye and formally recopmzng the stale of [sracl. But Israel would have w withdraw from all Avab land captured in (967, including “Arab Jerusalem.” We would also have to accept the “rights of the Palestinian people fo selidetermination, including ther right 1 establish thar own state.” Bogin's seply was more sensitive than I'd expected from a leader who, through my Labor kibbutnzik eyes, [°d always seen as an extremist, unwaveringly committed 1o 1 “greater Isvel”, Though he did make it clear his views on the shape: of an eventual peace differed trom Sadar’s, he proposed further talks with the aim of finding an agreement both sides could live with. Still, like all Tsraelis, [knew he would never accept at least two of the Figyptian presidents demands: retreat from our control of w umited Jemsalem or the creation of a Palestiman state on the West Bank of the Jordan: for Begin. biblical Judaea and Samaria. On our territorial dispute with Ceype, 1 did believe a deal was possible. I did’ expect us to rolum all of the Sinai, i only becuse 1 eouldn’t sce Beg agreeing Lo iL For sceurity reasons, 1 also fell we should Uy 1o old on to a pair of air force bases built atter 1967, with American help, just a few miles over the Negev border, But as for fhe rest, | saw no reason not lo give it back. As Ud told Motta afice ihe 1973 war, I'd long believed [sracl bad lost sight of the original reason we'd held onto the Sinai after 1967. Tt was supposed to be a huge, sandy sceunty buffer. IF we did manage to make peace with Fizypt, there was surely no reason Lo hold vu fo iL. The moment of truth came almost exactly 10 months later, in September 1978. American President himmy Carter hosted a swnmil with Began and Sadat at Camp David. in search of a “framework agreement” for final negotiations on 184 a peace Lseaty. Again, [ was watching closely, via American TV. But as the summit was winding down, our phone suddenly rang in Palo Alio. “Ehud, how's it goin? Are you following what's happening here? What do you think? recognized the voice immediately: Fz Weizman, the fone fighicr pilo! Begin had chosen as his defense minister. ['d known Ezer since the early 1960s, when he'd been commander of the air force and Sayeret Matkal was planning its first operations. Sul, even though be had & reputation foc batting ideas back and foreh cntside the bounds of hierarchy or chain of command, 1 was startled to hear from him, “What do 1 think about what?” | said. “The solution we’ve arcived at here, We found there was no way bul to give bak everything.” The only exception was Taba, u sliver of land where the Negev mel the enstem edge of the Sinai, across rom the Jordanian lown of Aqeba. “Was there 10 way to convince them, even with some kind of a land swap, to Keep the two uir buses?” 1 asked. “Believe me, we wanted fo,” Ezer replied. “But no way. Nol if we were going to get a peace treaty.” So I said the obvious; if that’s what was necessary for peace, there was no ater choice: We were now well into our final year at Stanford. Our home was in a leafy “student village” off cumpus, called Escandito, for married students from abrond. Our two-storey Mal wiss one of row of cabin-like stiuctures: a bit like i Kibbutz. only smaller, American-style. a lol moe upmarket. IL had a fenced-ofl play area for the children and, in a common room for all the village residents. an upright piano. 1 found the richness of the academic environment — and the tine 10 explore and savor it enthralling. I'd chosen my master’s program at Stanford because it offered the etme 10 leam across a range of different schools and disciplines. The official home for my degree courses was the School of Ligincering, in a department called “Engineering: Teonomic Systems” Ts focus was on applying. mathematical modelling and analysis to decisson-making m “large and complex 185 arpanizations” such as private companics of government deparnents. OF the armed forces of Tsrael. The theorists at Stanford were leaders in the field But from the start, | was drawn to other disciplines as well: business, ceonomics, political science, history. sociology, psychology. 1 studied game theory al the business school, and the evolution of political systems under the sociologist Seymour Martin Lipset. 1 alsa went to lectures by James G. March, on haw psychological, social ind ather factors mfluenced decrsion-makmy 1 psticubirly enjoyed leaning (fom Professor Ames Tyersky. Born in Haifa, he was half of an academic partnership with the psychologist Daniel Kahneman, who was ulso Israchi, They were myestigating the effect of human bias and ofher subjective factors an how we perceive reality, and thins make decisions. Tuersky s work especially fascinated me, because il questioned a basic assumption in the kind of predictive formulas my own department was advancing: tha we make choices rationally, caloulating the outcomes of competing altenatives. Tversky had found that the human beaia didn’t always work that way. For choices with a fairly obvious outcoue — 90 percent of cases. say the assiumption dic hold. But at the win, the bridn did, or couldn't, always gauge the implications of a decision accurately. A couple of decades later, he would also show that aa individual's choice could vary significantly depending on the way the options were presented. These behavioural and psyeliological approaches were at odds with what was being taught in my home feeulty. Tis prevailing orthodoxy was that by using. specifically desumed interview techniques, alongside mathematical modelling al the predicted outcomes, we could isolate the effect of human agency on low, and what, decisions were made. Yet the wider my studies had ranged, the more sceptical I became tha the complexities of human decision-making could be aceommadaied by such models. {also saw problems in the methodology we were using. Siace it was based pactly oa interviews with participants in the decision-making process, it seemed to me that this introduced a subjective clement into our ostensibly objective conchisions. My department wasn’t enamared with ty views ou our modeling approach. But ane of the things T most valued about iy time in Stenford was that, far from discouraging my excursions mio other departments, my professors combined i confidence in their own approsch with a genuine open-mindeduess to other ideas: the hallmark of true intellectuals. and of gseat universities. 1 got something chic From my sindies a Stanford, although | didn't speak about it at the time. uot even to Nava. [ became aware that [hed a particular 186 aptitude for focusing on the minute details of a problem, yet never losing sight of the farger picture, he wider issues. From my experience as commander of the sayeret and during the 1973 war, and fram watching other officers whom 1 sespeeted, it struck me thal this was un essential part of elfeenve leadership, By “leadership”, at thal stage in my life, | did not mean political leadership. | was thinking in terms of the army. But 1'd now finished my masters degree, and it was impossible to be umiware of the political cones in which 1°d be seturning Ww uniform. Since Camp David, our negotiators and the Egyptians had been ying to thrash out a formal deal. Sadat was being denounced as a traitor in the Arab warld, Begm was seen by most in the outside world, and many. Tsauclis, as dragging his feet on the negoliations und risking the chance for peace altogether. If we did manabge w sign a peace treaty, however, we would be withdrawing for the first time from land captured in 1967, That would mean finding a new approach to security in the south, as well as a new [ous on the majorly of ou Arab acighbors who were ailing against Sadat and seemed loss interested than ever in making peace. In some ways, it was harcl to leave ont mini-kibbutz in Palo Alle. Michal. now neady ive, had rived, quickly leaming English and coding up with a pertectly American accent which has never lett her. Yael has less vivid memories of our time there, But we'd had the nearest thing fo a normal family life since our first, war-truncated, time al Stanford. During the wiversity holidays, we'd also wavelled: to Canada. Mexico. Lake Tahoe. Even Las Vegas, where, thankfully, we lacked the money ta chance our luck, but where my years in the sayeret suddenly came in handy. We spent the day al Cireus Cireus, a joint casino-and-theme park tailored for families with kids. At a shooting sallery in the anwsement area, [ had no trouble landing dead-center hits on a pussinig procession of metal geese, 10 ihe consternation of the wy behind the counter but the delight of my two young daughters. Tn probably the single ‘ereatest moment of parental accomplishment I'd experienced since their birth. 1 barged i hnge fluffy eddy bear for sich of them. oan {returned to Iseacl not just with the hope. but a reasonable expectation, that | would pet command of one of 1stael’s two regular armored divisions: the 252", which wis responsible for defending the sonth and, al feast for now, was based 187 inn the Sinai. Dan Shomson was cow head of the southern command and had wold me, before we headed back (rom Califoraia, that he'd recommended me for the post. It was an especially exciting prospect because the LS-backed negotiations. with Egypt did finally sppear to be nesring sn sgreenient. As commnder of Division 252, I'd be coordinating aod implenienting IscacP’s Sinai withdrawal But I didn’t get the job. at least not on my requrn. Rafiul Citan had indeed succeeded Matta us chief of stafY, and he bad the final say. Ud evidently been sight Lo assume [would figure no higher in his estimation than | had as sayeret commander. To be fair. however. he did agree to my becoming commander of Dan's reserve division in the south; the same 611" that Arik Sharon had led eros the canal in 1973. When © took up thal post in April 1979 — just days after the formal Tscaeli-Cgyplian peace Lreaty was indeed signed — 1 was also pramated, 1 became «one-star general. And eighteen months later, when the regular division post came open agaio, 1 did get the nod tw command the 252% Liven then, it was a elose-nun thing. Raful called me in 10 see him aod said he wanted me to return ta fe kirye instead, in fae one-star general's post inside mifiary intelligence. He said be had more than cnongh candidates for division commander, but thal my previous experience meant | was the best choice for the intelligence post. [ was determined to remain in the field. especially with signs thst Begin, und certamly his more right-wing supports im fhe |ikud, were already having second thonghts about the peace deal we'd struck with Egypt. In par, they feared that a withdrawal from azy of the land taken in the 1967 wa might create « precedent, and invite pressure, for mare withdrawals, But the real buyers’ remorse centered an he Gael that, as pert of the initial agreement at Camp David. Begin had needed tw aceept a parallel framework for negotiations toward a broader peace that would include the West Bank and Gaza Palestinians. In any case, with Raful balking a second time at giving me the division command, [ figured I had little to Tose by fightinh my comer, and telling him exactly what 1 felt. “Took, [ realize hal you're che of staff,” suid. “But don’t forget we're Dark just temporarily in whatever role we hold. I'm not here as a drafiee. I'm in the army by choice. I's your decision to tell me what position you want me to take. But you can’t inpose anything, | ean always kav, Or 1 can bide my time until vou leave.” Raful apparently concluded he couldn't actually force me to take the intelligence job. With Daa having made his preference clear, he didn’t press the point. 188 My main responsibility as commander of the 252% was to implement the withdrawal from the Sinai. Israel had commitied itself to bring all of our Forces behind the 1967 border within net twa years, and, along with Dan, [ threw my energy into planing and implementing the tems of the treaty. Bul especially with Begia soon (acing & reelection campaign against Laboe, now led by Shimon Peres, he was keen to play to the opponents of any further negotiating. concessions. le was positioning himself as the voice of military streugth, and painting Peres es someon who would risk our security by going further than he separate peace with Sadat Beginhad no more experience or knowledge of military details than Shimon. Bul front his days in he pro-staic (rz, he'd been su nnapologetic admirer of men of military action. Afler his vieocy in the 1977 election, he'd formed a government stocked with some of [srael’s best-known former generals, Not just Ezer Weizman. Tle'd brought back Moshe Dayan, as foreign minister. And as agriculture minister, the country’s most swashbuck ingly self-confident, and controversial. battlefield commander: Arik Sharon. Begin liad recently lost both Free und Dayan, who sicensed lm of defiberatedly tomedoing shinee of building on the peace with Egypt. But Arik was sill there, fouc-squae behind a more forceful military posture on Israels other fronts. As agriculture minister, he had abso heen the draving force in a plan for selllement “blocs” desigaed 10 encircle the main Arab towns and cities on the West Bank and foreclose any realistic prospect of a Palestinian state. After Begin's second election victory, in June 1981. some commentators, and miy in Labor, insisted thal he'd won becase of a dremalic surprise iic strike. a ew weeks before election day. against a Trench-built nuclear reactor outside Baghdad. 1 never believed that. in pact because I knew fiom intellipence Friends that the atiack had been sci for carl, smd was pu buck because of fears he plan might become public. But mostly because of what witnessed in the heart of Tel Aviv the night before the election. when I joined one of my top alficens, a Likudoile, at Begin's fin campaign rally. Shimon sill had a uarrow ead iu the polls. hadn't been at his closing cally. the previous evening. But like the rest of Israel, I'd heard and read about it, in particubir the wammeup wet: a popular, solidly pro-1abor comedian and actor named Dudu Topi. Greeting the crowd. he'd said what a pleasure it was that it was not full of chachachin. The word was sagering Tsracli slang: for uncouth, uncultured Sephardim, not fa from the equivalent of using the “n” word in America. In a single sentence, he’d managed to sum up everything the 189 Sephardim rescaled about the Ashhenaci, Labor Zionist establishment. Begin, at his cally, played it like a virtuoso. “Did you hear what they called you?” he cried. Chachachim, He slightly mispronounced the ward, as if he'd never heard, sue fess used, 1 before, und that even having to wept 1 mide Ins blood curdle. “18 that what you are?” There was pandemonium, Maybe Begin would have won anyway. But it was close. just one Knesset seat berween the twa major parties. And win, he did I became increasingly convinced in the weeks tha Tollowed that Begin’s second government. with Arik now moved to defense minister, would turther put the brakes on any follow-up negotiations for a deal with the Palestmians, | did not yet know that Arik, in particular, had s fr more ambitious, military plan 10 try 10 bury the possibility of a Palestinian state once and for all. But T did know he had his eyes on a passible thrust across our northern horder into Lebanon, where Acafat and the PLO were based. I here was no public mention of any of this. But several times in 1981, | was ordered to mave a large part of my division onto the Golan Heights for weeks at wrime: two brigades, 200 tanks and dozens of APCs in a missive motored from the bottom 10 the lop uf the country and back again. We dubbed it Cincrama, from the Hebrew words tor Sinai and the Heights, Rameh. If there was an eseilution of hostilities, the northem commands regular division would cross into Lebanon, Our role would be 10 take their place in defending the Golan. and possibly follow them in. When | retumed fram my final episode of Cinerami in the late summer of 1981, thie Sima witheawal was cutering its final stage. 1 organized a full-scale military exercise on the roughly one-third of the Feyptian desert we still held. knowing that we’d no longer have the room to do so after the final withdrawal. Twas the lagest exereise Ud ever commanded. The advamees und tactical setreats, the flanking maneuvers and ambushes and fighter jot auachs were like avery big war in a very small place, But a war game wus not a reul war, The Sma was not hke the Golun, or the cramped. hilly confines of Lebanon. And it was in Lebanon, the following year, that the war came. Ir was different from any in Israel's history. Arik was in charge, And | would become mvalved in ways which began to change the way | saw not only Arik, but the political and military dircetion of our conniry. 190 Chapter Twelve My own pact in the Lebanon war would change dramatically as a cesult of that Fast military exercise in the Sinai, Arik Sharon was now Minister of Defense. and he came for the final alleenoon. From his experience as a frontline commander — in 1956, 1967 and 1973 - be knew the dunes and wadis and sprawling expanses of sand us well us any general in Israel, Watching our intricate mini-war dian 10 its close, he made no effort to hide his enthusiasm Cor the kind of quick, assertive baulefield maneuvers he'd long championed. But more than that, his closest aide soon began sounding me out on my views about the fome-ferm organization, force hakmee and funding for the sel military. A Rew weeks later, Arik offered me a promotion: & returi lo the Ady, as a two- star general, to become head of planning: for the armed forces. Ldon’t know why he chose me: the Sinai exercise perhaps, the fact he knew 1d studied “Farge and complex organizations” of Stanford, or maybe just the fact our paths had first ecossed two decades eadier whe T was in Sayeret Matkal, But even though it ment leaving my division command, especially Tough since the Gal Siviai withdrawal wes approaching il was in offer | never contemplated Luning down. Not just because of the second star an my uniform, Ever since the 1973 war. along with a few other senior officers including Dan Shommron, 1 had been making the ease for a shill to move mobile ind fess vulnerable forces and weapons sysiems. | saw the new role as a chance to help encourage that critically important change. “There was just one hiteh: all senior military assignments required the formal approval of the chic-of-stafl; my old friend Raful Eitan. Raful did manage wo delay things for several weeks. At one point, he even brought to bear a quality Ud never suspected he hid: a sense of humor, “OK, ll agree to promote Barak.” he lold Arik. The next day, he said he'd met Eitan Barak — a very goad commander, by the way, who had heen one of my instructors in officers’ school. Aik insisted, however. My appointment went through And ane, wnsnticited result was that | didn’t just play the field command solle I'd anticipated, from our Cinerama deployments, in Arik’s loweringly ambitious, ill-plamed and ultimately disastrous war in Lebanon. | became part of months of planning discussions m the kirva before our tanks finally rumbled across the nasthern border on the morning of Jun 6, 1982. 191 My new posting came not just as momentum was building towaed an invasion. It followed on the heels of a major new crisis in our peace with Lgypt Only weeks before [ gave up my Sinai command, President Amar Sadat was shot sad killed by an exirermisl Mush officer at the annual Cairo miliuny parade w mark the anniversary of the 1973 war. Like many Israelis. I felt an almost familial sense of bereavement. Sadat was not just the first Arab leader to make peace with Israel, He seemed to understand ws: people who were ready. willing sud able 10 fight, but waned above all to live unmolested and accepted by our neighbors. Yet for Begin and the Lileud, | knew the assassination would ¢ust the whole peace process into doubt. Sadut’s successor, Vice-President Hosni Mubarak, did make 11 clear he would abide by the peace Lrealy, defusing calls on the Israeli right for us to cancel our final withdrawal from the Sinai. But after Sadut’s killing, Begin and those around him seemed more determined than ever to hold the line against the wider peace aegotiations ageeed with President Caster and Sadat at Camp David. At Bepin's insistence, Camp David had not proposed giving the Pulesiniuns a siaic, but instead “awonomy” and a locally elected “sel soveraing authority”. Yet that was defined as a teansitional period. The elected Palestinians were to be included in negotiations for a yer-unspecified “final stalus” rangement. for the West Bank and Gaze, Tht, Begin feared, fell the door ajar for something amare than autonomy. Shuting that door, | would soon discover, was a big part of Arik’s ornate reasoning for invading Lebanon. Beyond the tact that my new job was a promotion, 1 had a personal reason Tor welcoming the move back wo Tel Aviv. Te days aller Sadat’s assassination, Thad endured a [rightening few days succounding the bisth of our third daughuer, Aunat. The crisis was another reminder that the demands of frontline command rested wot just on my shoulders, bit my Ganily’s. We hid moved house agsin early in Nava's pregoancy, 10 the subue of Ra’anana. about 10 miles nocth of Tel Aviv and a few miles in fiom the coast. We bought one of a newly built row of small, semi-detached lownbowses which, best of all, bid a backyad. 1 was tiny by American standards, but was still a place for the girls to play. Onee apain, however, I wasn't there when my daughter was born. I was rushing north as Nava went into labor, “he bisth itself went smoothly. By the time 1 gol to the hospital, both baby and mother seemed happy and healthy. A few days later. however, when they were back m the townhouse and 1°d refumed fo my division, Nava felt suddenly, desperately unwell. T shudder to think what might have happened were it not for 192 he fact that one of our new neighbors was a friend from my first military intelligence stint in the Airy. Tn almost paralyzing pain, Nava phoned him, and he rushed her to the hospital, It turned out that the doctor wha delivered Anat Bc fe) prt of the placenta inside. Onee the mislke was discoverad — is | was again speeding north — be weat back in and rectified it. When I arrived. | was relieved. to put it mildly, to find Nava smiling bravely, and on her way back to full health. Sill, doctor friends of mise wld me that it the problem uot heen diagnosed and addressed quickly, she could have suffered shock, serious infection, even death PE In my new tole, Iwas nominally responsible to both the defense minister and the chief of staff, but Arik made it clear lo both ne smd Raful thal he was boss And though my official brief was longer-term planning. almost from day-one the issue of Lebanon overshadowed all others. 1 kaew. from Cinerama, that preparations for a possible military operation m Lebanon were mderway. Yet from my first meeting with Arik aod Raful, it became clear it was move then just a possibility. “Why the hell is Arafat still alive,” Arik snapped acus. Ile said that when he'd been commander of Unit 101, he'd never wid for the government 10 ask him to pla an opesation. 116°d plan it hinusclf, and go lo ministers for approval. When I told him that I'd done just that when I was commander of the sayerer, only to be told Arafat was “not a target.” Arik replied: well, he is now. The PLO leader's cursent residence was on the southern edge of Beinit, and in the weeks ahead Arik left no doubt that he meant to go after him there. To anyone looking from the outside, there was no pressing reason 10 expect a wer. Tis teue that the potential for conflict was always there. The PLO had nearly 20.000 fighters in Lebanon and hundreds of rockets capable of reaching our northim towns ind selllements. The Syrians were there, Too. As part of im Arab League agreement in 1976 Lo quell two years of terrible civil war between Lebanon's traditionally dominant Maronite Christians and an alliance of PLO and 1 ebanese Muslim forces, some 30,000 Syrian troops had been brought in as the core of a peacekeeping force. But in the summer of 1981, uew US President Ronald Reagan's Mideast envoy. Undersecretary of State Philip ITabib. had 193 brokered a cease-fire to halt Palestinian Katyusha rocket fire into Tscael. Tt was eencrally holding But fundamentally, Arik’s war plan was not a response to the Katyushas. [¢ wats a wiry of using military foree to achieve Prime Minister Begins political wim: stopping the Camp David peace process in ils tracks, aud ensuing it did mot fro beyond the peace treaty with Egypt. And even that message was not prmcpally intended for the Pulestmians, suspect, bat for the Americans. Israel's Labor-led governments had always calculated that we needed at least some measure of support from foreign allies, especially the LUIS. Under Begin, we'd already bombed Saddam Hussein's nuclear reactor without telling the Amcricans hofovetand. Shortly atier | reummed to the kira, hie provoked further anger in Washington by annouacing the de aero annexation of the Golan — in effect “balancing” our Smai withdrawl with a dramatic reassertion of Israel control over other land captured in the 1967 war. Part of Acik’s plan in Lebanoa wes to deliver an even more forceful riposte to any suggestion that we would aive up control of the West Bank and Gaza. Yel these polineal aims. which 1 was gradually beginning to grasp in their full form through my discussions with Aik, were only part of the reason | was deeply uneasy about the plans for our Lebanon invasion. Having now spent nearly two decades m the mifitary, [ recopmized tha the seeurity challenge north of the border was real. | did not believe it was inherently wrong for Begin's government 10 order a pre-emptive military operation with he aim of ending it My view, as an army officer, was that the decision on how, when and whether 10 20 Lo war was for our elected government. Bul for that prineipke lo work, | also believed that government ministers had to know whar they were deciding. The more we peared up for an invasion. the less certain I became that Begin’s cabinet understood what we were pling 1o do Arik’s original plan was codenamed Oraniz: Hebrew ov “pine tees”, It involved pushing deep into | .ebanan, all the way up ta the strategically critical road that van between Beit nd Damiscus, We would fink up in Beirut with the main Maronite Christian force, the Phalangists. whoni we had been supporting and training for several years. When that plan was presented to Begin's cabinet at the end of 1981, howaver, most ministers opposed it. Thus was born Arik’s Plan B, so-called “Lite Pines”. 11s stated aim was a lot more modest. We would create a “security zone” — a 40-kilometer. or 25-mile, strip running north of the harder with [.ebanon. 194 Teould see that Lids Pines was a kind of fiction. All you had 10 do was take 2 map and draw in the 40-kilometer line. Tn the arcas nearer the Mediterranean, in the westem und centeal parts of the border area, it indeed covered femitory contiufled by anned PLO groups. Bil in the sistem scetor, there wore Syrian positions 2 mere 10 Lo 12 kilometers up from the border, well inside the “security zone”. Not much further north were two full Syrian divisions. That meant we'd be fighting not just the Palestinians, which was the ostensible aim af Lille Pines. We would have 10 take on Syria. Ag soon as dose hostilities began. we would have to destroy radar and SAM sites in the Syrian-controlled Beka'a Valley further north into Lebanon. After the first costly days of the 1973 war in the Sinai, we were not about 1o enter a niajor conflict without ensuring, air superiority. Unless the Syrians retreated or surrendered, the inevitable resulc would be a wider conlict, not limited to dealing with Palestinian fighters in south Lebanon but paving the wey for Arik 1 go ahead with his original plan and push all the way to Beirut This wasn't tere supposition on ny part. In February 1982, we ran a simulation exercise in the Kirva based on Plan B. The result: Litt Pins became Big Pines. A clash with the Syrians proved inevitable, if only because on target even under Little Pines was the main road between Beirut and Damascus. It lay well beyond the 40-lalometer hme. As the main sipply ron for theit forces in the inlerior of Lebanon, it was also of critical importance for the Syrians. So any idea of a quick, limited strike to establish a security zone was fantasy. A few days later, Raful chaired a wide-ranging discussion on Lebanon, Near the end of he session, | asked him directly whether government ministers wert aware that our war plan “will inevitably lead to a clash with the Syrians”. Raful hesitated fora second. but then answered briskly: “Yes “That assurance would tum out to be untrue, But my wider cancer, as the weeks passed. was Arik's political plan, of which T was getting an ever clearer idea from him. It struck me as no just rand, but grandiose. Part of it was to obliterate Arafit as a political force. io by killing lnm then by forcing bim and every one of his fighters from Lebanon, a eountey Arik wanted to place under the unchallenged control of the most prominent of the younger generation of Christian Phalangist politicians, Bashir Gemayel, 1 felt ll that would be challenging enough. Bul in Asik’s eyes, this was only part of a complete reordering of our conflict with the Arabs. Tle expected Gemayel s Lebanon to openly alin itself with [srael and expel all Syrian troops. As for the expelled Palestinians, they would go back lo Jordin where they would resume and, this time, win their civil war with King Hussein. The result. with Hussein deposed, 195 would be a ‘Palestinian state™ in Jordan, which would free Israel to retain open- ended, unchallenged, control of the West Bank. Even the Labor party. fitteen years into Israel's occupation of the West Bank, was shill speaking about a “Jordanian option” for an cventnal political selllement with the Palestinians who lived there — though this meant a kind of confederation with Jordan under Hussein's rule. Very tew Israelis began seriously to engage with the Palestinians own separate identity or national aspirations until later in the 1980s — when |, 100, would do so, amid the widespread Palestinian unrest known as the fvifiude. But even without a fully thought-out view on these issues, | was taken wback by Arik’s almost godlike supposition tht he conld use fire and brissione, or the modern military equivalent, 10 remake the Middle Tast as be and Begin wished to see iL. Tf only because of the tacit assumption that the outside world, and especially the Americans, would sit by and let the whole drama play out as scripted. it struck me as an exercise io sell-delusion. There was also the matter of Arik’s vision of 2 “new” Lebanon under Bashir Gemayel's Phighingists, Unlike the other generals in he firva, Ud never actully et any of our “Lebanese Christian allies”. Yet a fow weeks afler taking up my new post, [ was invited to a lunchtime discussion with a group of Phalangist officers on a training course m Israel. | emerged both unsettled and underwhelued. They were obviously politically astue. |hey bandied around military vocabulary proficiently enough. But they were a bil like teenagers plying with guns: full of macho, and too much after-shave. Hardly the kind of “army” | could see as a lynchpin in Arik’s pli lo redraws the geopolitical map of the Middle Test. PE By June 1982. Arik’s invasion was 2 war simply waiting for a credible trigger, On the evening of June 3. Palestinian termonsts shot and critically wounded Jsusel's ambassador in Laadon, Shlomo Argov. Appalling though the attack was, as a catalyst for a full-scale invasion, it seemed unlikely to be enough for the Reagin Administration, Habib’s cease-fire terms did not include terror aacks like the one in London. 11 was meant 10 keep the PLO from fiving across our northern border. Even to some Israelis, the arack on Ambassador Argoy seemed more # rationale than reason for war. But Begin summoned an 196 emergency cabinet meeting the next day. TTis adviser on tercorism, Gideon Machanaimi, was someone F knew well. When the cabinet convened, he pointed out to the ministers that the London terrorists were from a fringe Palestinian sronp led by Abu Nidal. Far from being an ally of Arafat, he had been sentenced Lo death by Fatah, According to Gideon, Begin wasn’t interested in the distinction. ven less so were the two leading military figures in attendance: Arik and Raful. They said all Palestinian terror was the responsibility of Avafat, and that now was the lime to hit back hard. The cabinet was informed that our initial response would be limited: aerial and artillery bombardment of PLC targets throughout 1.ebanon. Yer Ratul told the cabinet that the Palestinians. would almost certainly respond with shell and rocket fire im Isracl. Then, he said, we could strike more forcefully. In other words, the invasion would begin. It did. Dubbed “Operation Peace for Galiles™ to convey the aim of protecting northern Israel from shell and rocket fice, iL got underway at acound [1 am. on Sunday June 6. The publicly declared aim was Little Pines: the establishment of our 40-kilometer security zone. Both Israelis and the Americans were led to believe it would be a reltively short aperution aimed al destroying the PLO’S military capacily in the border area. We also said that we wouldn't auack Syrian forces as long as they didn’t attack us. “That last public pledute had particulir relevance fo my role on the ground. © wea depuly commander of the largest of [sacs three invasion forees, under Yanoush Ben-Gal, head of the northern command until shortly before the war. We hid 30.000 troops and 600 tanks and were responsible far the “eastern scetor — from the edge of he Golan Heights, novh throngh the Bekaa Valley along Lebanon's border with Syria. At first, we deliberately stopped short of Syrian forces. We deployed our main reserve division just 10 kilometers across the border, below the first Syrian positions at the boom of the Beka. But despite the public assurances we were in Lebanon to establish our security zone, we had no orders to hale at the 40-kilometer line. From day one. our part of the vision force began w pincer movemen! around the area of castem Lebanon where large nunibers of Syrian soldiers were based. My former Sinai division, the 252, came down from the Golan and started making its way up alongside the Syrian border. Our ather units, further inland, also began pushing northward, Tor the first couple of days. we did avoid a confrontation with the Syrians, Yet an June 8, day three of the war, the morphing of |attle Pines mio Big Pines began 197 The two other Israeli invasion forces had crossed the border parallel 10 us, one pushing up tough the steep hills and twisting valleys of centeal Lebanon, and the ofher along the Mediterranean coast, The central force was now ordered 10 mount am attack thal would bring them within siriking disuse of the Bei Damasug road. The first skirmish came in the hilltop own of Jezzin, sill baely within the 40-kilometer zone. The Syrians had a commando force and tauks in the town. An [sracli battalion was ordered in, and it tok Jezzin by the evening of June 8. Bul it came under assault from Syeian units with grenades. RPGs and Saggers, as well as shellfire from a nearby ridge. Shortly before midnight, another unit of Israeli tanks and infantry passed through the central 1.ebanese village of Ayn Zhala, 10 the north of Jezzin and beyoud the 40-kilometer line, and began winding its way through a valley toward the Beirut-Damascus road. They waded into a Syrian ambush, and for hours tound themselves in a fierce Buttle with Syrian units. Tdon'Lbelieve Arik specifically planned to confront the Sycians in Jeszin and Ayn Zhalea. But he could not lave doubted that, given the enormous scale and range of onr invasion, i clash with Syria forees would buppen an some point. Now that it had, all that remained was for hin to tell the cabinet that Israeli forces had come under Syrian fire and insist, as defense minister, that the imperative for our forces on the ground was lo strike back. On the afteroon of June 9. the fourth day of the war, we got the arder to go on the offensive against the Syrians in the Bekaa. As our artillery pounded the southernmost SAM sites, nearly 100 Israch jets swarmed into the Bekaa Valley and attacked Syria's wir defenses in caster Lebanon. When a sceond wave screamed in an hour later, the Syrians sent up their Soviet-made MiGs to intercept them. Forcy-one Syrian planes were shot down. Seventeen of the 19 SAM birtteries were desroed by the end of the diy. The other wa were tiken out the next morning, and another 43 Syrian jets shot down There was no longer any pretence about our war aim: to fight our way fhwonggh any resistanes and reach the Beirui-Damasens road, Bot fier the Bekaa air battle, and the most serious air losses for an Arab state since 1967, Yanoush and T knew that international pressure for a cease-fire would quickly escalate. Aware we were Ticing against the clack, we began a co-ordinated push Towards Ue Beinl=Damaseus road. | he lel arm of our “pincer” wis ordeved lo make its way toward a town called Jobb Janine. It was still some distance from the Damiscus road. bud wn important way-station: Syvim headquaniers on the western side of the Bekaa Valley. The astern part of our pincer, the 252 198 Division, advanced up the Bekea, alongside the Syrian border, ward the town of Yanta, across from Jobb Jannine But as it was making its way there, we rot word a cease-fire had been agreed. Twas sel for noon the next day, Friday, June 11. The main focus of our advance shifled to a crossroads a few miles cast of Jobb Janine. Jt was a Nal, open area surrounded by hills, codenamed the Tovlano Triangle on our maps. We knew we would meet some Syrian resistance. On the way up the valley, we'd seen signs of reinforcements from inside Sysia. But we had overwhelming superiority in tanks, artillery and infantry in the area, as well as full control of the an, In our command post, about five miles back from our frontline forces, Yanoush set in motion the plan for s pre-cease-fire advance: 10 take the hills overlooking the Tovlano Triangle. Tt was still about eight miles short of the Beirut-Damascus road. But the idea was to establish a more secure defensive position by the Lime the truce took effect, and to pul us in position 1 advance fucther if the cease-fice collapsed or was delayed. Shortly before sunset, Yanoush lef: by helicopter for a field commanders” mecting with Raful in northern smel, That left me in charge, alongside Yanoush's de facto chief-ol-stall, Amram Mitma. A decorated veteran of 1967 and 1973 whom 1 knew well, Amram had the added distinction of being disliked by Raful almost us much as | wis, Our muin reserve division hud been ordered 10 take control over the hills south of the Tovlana Triangle. One of its brigades, led by a former Sayeret Matkal soldier named Nachman Rifkind, was sent lo take up a position immediately south of the triangle, Soon after nightfall, Rifkind radioed in tht he was there, and thal the area seemed clear of enemy forces. The divisional command post thea ordered a second brigade to move toward the hills dominating the crossroads. “The first sum of trouble came around mmdmeht. From our overall conmand post, we were listening in on all radio traffic, and heard the second brigade report that it had come under fire while moving toward the crossroads. At first, we sssumed 1 must be from the remnants of a retreating Syrian unl, But Rifkind. who had reported the area was clear, sow said thal fie could sec Mashes of shellfire two or three miles to his north, Only the following morning did it become clear that he had nat deployed immediately south of the mamgle as planned. He had mistakenly halied ata bill shout 1wo miles short of there. By the time Yanoush returned to the command post a little aller midoight, we were ficing unother problem. he batlalion nearest to the sonth of the triangke had spotted a dozen lacee vehicles armed with missiles a few hundred 199 yards ahead. The missiles seemed wo be poioted norih, away cont them. But the battalion commander was asking us for permission to open fire “Da nat open fire,” | was saying as Yanoush arrived. “I repeat: do nf open fire.” When Yanoush asked me whit was gomg on, [old him the lead unit hid sepocted unknown velicles with missiles and wanted wo know whether it could attack. “Tell them ves,” Yanoush said. I looked first at him. then at Mitzna, “We can’t,” Usaid, “Its dark. The situation is confused. We don’t know whose missiles these are. 1 doesn’t make sense they’d be Syrian, just siting there, pointed north. At least give it a few minutes.” I think Yanoush would have grabbed the microphone and fold the unit to fire had not Amram been there as well. Together, we convineed him 10 hold oft: 1 ordered the brigade commander 10 gel one of the battalions APC crews 10 20 out on foot and gel as neac as possible to the missiles. It was nearly 15 minutes later when they retumed. They said they d never seen this Kind of missile vehicle, but thal the soldiers manning them seemed Lo be speaking Hebrew. It Lumed out 10 be a new ground-to- ground missile, not yet formally in service, which had been sent into Lebanon without our knowledge hy the nortiiem command. While that trouble was averted, muel worse lay ahead. Yanoush asked to be brought up ta date on our progress in taking control of the area around the Tovlana Triangle, We briefed him on the situation as we understood it: that Ritkind had reported the triangle was clear, bul that the second brigade bad still not reached it. Yanoush tried to radio the divisional commanders. When he couldn't ruise them, he ordered the brigade and bitealion commanders to pick wp their pace sud move forward. With Yanoush back and the advance resumed. | tried 1o grab at least a few hours” sleep. But around 3:45 am, a junior officer shook me awake. When | sjomed Yanoush and Amram, they told me the lead battalion was now in deep trouble. Jt was led by Lea Lpheon, onc of Dan Shomron’s best company commanders during the 1973 war. For reasons 1've never been able to establish, Ira's orders were nol ta take the hills south of the trianyle us we'd planed, but 10 20 trough it 10 a point wo mikes or so north. Minutes aller crossivg the triangle, his tanks came under heavy fire. loping w escape, he kept going, only to find himself surrounded by a Syrian armored force. They were trapped near a village called Sultan Yacoub, nearly three miles north of Tove. Since it was early June. it would be light soon. and his predicament could only get worse. Al dawn, he reported he was nnder heavy wtillery, anti-tank missile, RPG and elose-range cil fire. The only realistic hope was to retreat, We were unable 200 to get air support, but the commander of auc anilleey force called in all available units, and they drew a kind of protective box of shellfire around fea’s men as they moved back, We sent our other reserve division towards the crossroads to provid support, snd Aram wen with therm to co-ordinate the operation. Bul Tra still had to fight bis way out. IL was 15 minutes of hell. By the time be reached safety at around nine in the morning, he'd lost ten tanks and nearly 20 men, four of them during the final, fiantie retreat. Five more were missing. The seserve division also found itsel in a fierce firefight with the Syrians, and lost eleven men. We were now just three liours trom the cease-fire. We did advance nearer to the Beivui-Damascus rosd. An hour before noon, our dedicated anti-tank wil destroyed 20 of Assad'’s top-tier tanks, Soviet-made T-72s. Under different circumstances, those successes might have been a cause for consolation, Yet it wes hard Lo dwell on them given what had happened north of Tovlano. After the wer, Sultan Yacoub created Fertile ground for conspiracy theories. hal-ruths and finger-pointing. That there had been many oversights and errors was clear, though there wis never i full and Garmal debriefing proces to udenafy in demi whet had gone wrong. 1 found it deeply frustuating that, unlike in 1973 whea I'd been in a battlefield command role, 1 was now at several steps removed from whl was hisppening on the ground. But everyone involved shared responsibility for the failures — including the overall commanders: ¥auoush, and me as yell. That weight felt even heavier because the tragedy occurred only hours before our own force's involvement m the Lebanon War was over, PEE 1 wis mot, however, he end of the war. The ecase-fire held only intermittently in the cest of Lebanon, barely at all in sone accas. Freed from fighting in our sector, Yanoush, Amram and 1 began spending time wich nits elsewhere. A coupke of days after the cease-fire, | found myself alongside 1 pair af generals. Uri Simehoni and Yossi Beu-lanuan, south of Beirut. In font of us. troops from the Golani Brigade were completing their takeover of Beirut airport, “You were tight,” told Un and Yosst. They bad been m charge of the simulation exercise in the Kirva, predicting how Arik’s ostensibly more limited invasion plan would inevitably develop into Big Pines. Even as we were talline, 201 another Tsracli unit broke through lo the Beirul-Damascus road. On the far side af Lebanon's capital city, they linked up with Bashir Gemayel’s Phalangists 1 remember a mix of feelings at the time. Partly, amazement that throueh sheer determination and political maneuvering, Arik seemed fo have pulled off his grand plan — or at least the Lebanon part of it. Yes, we'd euded up lighting a Kind of half-war against the Syrians which, though we'd won it, still left 30,000 of Assad’s men m | ebunon. And they showed no signs of leavmgz, Our main strategic threat north of the border was nol, in fet. the Palestinians. Syria was in military control of Lebanon and. after the peace with Egypt, our most powerful adversary, And no matter what Rig Pines might have achieved, it seemed fo clear to me that the Syrians would be free simply fo replace the weaponry we'd destroyed and fight another day. In Arilc’s mind, Bashir Gemayel would soon be in a pasition fo fix that, But beyond my skepticism fram having met some of Ins boy officers in Tel Aviv. 1 couldn’ see how that would work. | strained o imagine Gemayel daring to form what would amount to a formal alliance with Istael and ordering the Syrian troops to leave, And given whist would be at stake for Damascus, | certainly couldn't sce the Phalangisis being able to drive them out by force. The more immediate, open question involved Arafat and the Palestinians. Our ofher twa invasion forces had driven almost all the PIO fighters aut of south ebm, though not without costs and casualties. Most of the Palestinians, however, had retreated north to their de facto capital. the southwestern neighborhoods of Beirut, The idea of a ground assault street-to- street bitthes in an se picked with fighters, weapons and fens of thosands of civilians — didn’t bear chinking about. After the war, some of the officers around Beirut said Arik seemed to haping that the Phalangist milita would yo into the overwhelmingly Muslim wesiem sid of Bef. Al one pom, he was evn considering an Iscacli attack. Fortunately. given the Phalangists’ wecord of violence bordering on savagery during the |ebanese civil war, Bashir Gemayel wasn’ willing to send them in, As for an Israch asssult, Begins misters weren't ready w sign off ou it, and the Americans let it be know, repeatedly, that they were vehemently apposed to the idea. Arik ageain tumed fo a fullback plan. He knew that Begin dil share his determination fo get Arafit and the PLO ow. of Lebanon. Even the Americans were ready to support such an arrangement, assuming it could be negotiated and implemented 1m a way that would bring the Gizhting tw an cn. Whether by intent or political fortune, the mere prospect of Arik further expanding the 202 invasion had the effect of persuading Washington to send Philip [Tabib back into the diplomatic fray. With no carly sign, however, of Asafa agreeing 1 leave, Arik naw steadily tightened whit amounted to a siege on west Beirut, For seven weeles in July and Augus, our fares pounded the PLO-comrolled neighborhoods fom land, air and sea: inteemitiently cut water and electricity supplies: and hoped that the accumulated pressure, and casualties, would force Arafat and his meu to agree to 1lahib’s terms for & wholesak evacuation. By this point, [ was spending most of my time in the &irye, with periodic ists north. sometimes with Arik or Raful, to our positions on the eastern, Phalungist-controlled, side of Beirut, On several oceasions, [ helicoptered bck with Habib ov his deputy, Morris Draper. In one instniee, {acconmpanicd Draper into a meeting with Arik. In what T imagine had become a familiar. and frustrating, part of the US mediation mission, he pressed Arik to rein in our bombardments. arguing thal we were in danger of ruining the chances of getting 2 negotiated deal on Acafal’s leaving. Arik argued straight back. 1Tis view was that unless the PLO felt squeezed into submission, they would stay pu. On that, 1 thought Ank was probubly right, Other Israch generals with fur more experience, and weight. also seemed to agree. Notably, Yitzhak Rabin. te was no longer in government, nor even in charge of Labor. But he had always hula soft spot for Arik, is did Sharon for hm, With uncasinss, questions and ouright wilicis of the siege building both iutermationally and inside Israel, Arik got Rabi to helicopter north with him to Beirut. Yitzhak spent six or seven hours there. His verdict on the siege, at least as reported in the [sraeli press, was ore than Aik could have hoped for. Jekadek, he said. “Tighten it” Tn the ead, Pm convinced the siege did have a critical elfect on getting the evacuation deal. But unleashing our single most relentless series of air attacks. on Angas 12, when the deal was basically done, seemed both perverse and excessive, and not just to me. TTabib, end President Reagan himself, fumed. So did a lot of Begin's own ministers, with the result, unprecedented in Israeli miliary anal. that they Formally removed Auk’s anthority to decide on Rune air fore missions. That ured out not to matter, however, because August 12 effectively marked the end of the siege. On the afternoon of Saturday. August 21, the first shipload of an eventual total of nearly 10,000 Palostinian fighicrs lofi Beirut harbor for Cyprus, und then for a variety of new host countries. Ox this cove at least, Acik’s grand design hid proven beyond him; the Palestinians were nat bound for Jordan, By far most of them headed for the PLO’ new political base, the north Affican state of 203 Tunisia. Arafat himself left on August 30. Sill, as the evacuation proceeded. another one of Arik s central aims iu Big Pines was alsa achieved. On August 23. the [ebanese parliament elected Bashir Gemayel as The country’s new president, ore Dusing the several weeks that followed, there was a confident feeling among Arik and his inner circle in the fry. To the extent that Arik and Raful saw any cloud on fhe horizon, it was their concem dbout “several thousand” Palestinian fighters who they were cerlain hud stiyed on in Bein despie the evienanon. True, Bashir Gemayel liadn't been formally inaugurated as president. There had been reports that he was privately assuring I ebanese Muslim leaders that he would be concalfatory once he took office, und thi he was nol about lo consider a formal peace with Isracl. Le hed also been resisting Isiacli clots lo make an carly, public show of friendship. such as an official visit to meet Prime Minister Bain. But there was wn indsguised hope that this was just brief pofitical hiatus, for appeatance’s sake, and that before 100 long Lebanon would become the second Aral country to make peace with Iscael. Not just peace, bur something more nearly like an alliance, Thongh | will looked through the eyes of an amy officer, note politician and certainly not an experienced diplomat, I had serious doubts this would happen. Simple logic seemed to suggest that. since Gemayel knew we had no sealistic option of luming our hack on him, Ins political interests were best served by keeping his distance and trying to build bridges at home. But on the early evening of September 14, nine days befare his scheduled inauguration, not just that question but the whole new political edifice Arik hud envisaged in launching the invasion. became suddenly, irretrievably. irrelevant Lwas at my desk on the third floor of the ky, getting ready t go home, when the news broke: 1 huge bomb had exploded at the Phalanst Party headquarters in cast Beisul as Gemayel was beginning to address hundreds of supporters. For a while, the reports from Beir suggested that Gemayel liad survived the blast, but shartly before eleven at night the confirmation came; the president-elect wis dead. 204 Though na one claimed responsibility, there was no shortage of suspects. During and since the eivil war, Gemayel had at various times been at odds with a whole armay of enemies or rivals: Muslim militias, the PLO, other Marmite actions and, of course, the Syrians. But [ihink for all of us, even Arik, the iss al who was behind the bombing was hardly the most urgent concern. The immediate danger was a revival of the kind of rampant bloodletting Lebanon liad euduced in the civil war. The day afer the assassination. | joined a hall- dozen other members of the general staff and befiooptered up to the Lebanese capital. Arik, ignoring weeks of US pressure not o do so, had already ordered Tstaeli troops into west Beirut not to fight, but to take control of key junctions and vantage points and keep basic order. But the questivn obviously on everyone's mind was how Lo make sure the situation remained under control. It was early afternoon when we reached an Tsraeli command post in the largely Palestinian southwest part of the city. TL was selup by Amos Yaron, the former paratroop commandee whose division had landed by sea at the start of the invasion and was part of the push north to the capital. Al is side was Amir Dror, the head of the northern command. They had set up a tooop observation post just 2 few hundred yards in fom where [ had landed with my Sayeret Matkal tear a decade earlier for the Rue Verdun operation. 1 overlooked a pair of Palestinian refugee camps: Sibri amd, 4 couple of hundred yards closer tw us, Shatila. Raful was with us as well. So was Moshe Levy, the deputy chief-of-scaff, and Uni Saguy, the head of the operations branch in the kirva, listened rather thin spoke. All could gather from he other generals” conversation was that they were tying to figure oul how to handle the Palestinian camps. No one explicitly mentioned the idea of Israeli oops going in, presumably because they realized tha, Ger from helping ensure order, thi igh well inflame things further. Even Raful, at least in my earshot, made no teference to the “several thousand” PLO fighters that he and Arik sill wanted out of Beirut. The only note that struck me as odd was a general wgeement hal the Phatmgists iad not been carving their load of the fighting during the war. One comment in particular stuck with me, though I didn’t take it as referring to the Palestinian camps in particular. | can’t remember which general suid it, only that everyone seemed to agree: “Why the hell do we have 10 do their lighting for them?” Tt wes not until the next morning, back in Tel Aviv, that the alarm bells rang for me, and by then it tumed out to be too late. [1 was Friday, the eve of the Tewish New Year. Yet in the wake of Gemayel's assassination, the kirya was 205 crowded. [heard the fist rumors from a stall officer in military intelligence, though neither he nor anyone else T asked was sure if they were tue. But it seemed that the Phalangists had been sent inta Sabra and Shatila, And that they Hcl begun killing people. I'd like to think that, in Ames Yaron's or Amir Dori's place, I'd have been sufficiently wise not to have allowed the Phalangists into the camps in the first plice. But the truth is that I'm not sure. If the decision was to send someone in, { certainly wouldn't have sent in Iszacli troops. But unlike other Israeli generals, my first-hand knowledge of the Phalangists was limited to a single lunchtime encounter m Tel Aviv, My impression from that meeting was hat they were avarblowu, post-adolescont thugs, not muses. | did, of course. kaow the milila’s reputation for untrammelled violence in the Lebanese civil war. Sull, T might conceivably agreed to have the Phalungists go in under strict arders to Tit themselves lo keeping order — in the knowledge that our own troops were stationed in the area immediately around the camps. Yet from the moment of the first rumors — as soon as I heard even the hint that killings were underway | aed nots seeand’s doubt about what fad 1 be done next: gel the Phalangists out. Immediately. 1 fell a particular uracney because of the rooftop gripe 1'd heard the day before, about our oops having to do sheir fighting for them, That made me pretty certain that, us the very feast, we had indeed sent the Plialangists inlo Lhe camps. Tried to reach Arik, but couldn't get through to him. T contacted Oded Shamir, the farmer intelligence officer who was his main liaison with the army, told him that i€ the Phaksmgists were side the camps, he bid 10 uge Arik 10 get them out. Then [ called Tsila Drori. Amir’s wife. [ asked whether she'd spoken to him that morning. She said no. He'd called her the day before, however, und she was sure he'd be in oneh before the New Year. “Please, swear to me, Tila, you'll give him a message” | said. “1 was there yesterday Tell him please do whatever he can ta stop this action, It will end very, very budlly.” told ber he would know whi! 1 mint Twas oo kate to stop it altogether. The slaughter — the round-ups and the beatings and the killings of Palestinians in the two camps — had indeed begun the night before, Amir found out about it late an Friday morning, Not from me, [believe, bul from his stall officers. He ordered the Phidangists 1o slop. Bul they didn’t. No one in command acted, at least successfully. to make sure that the militiamen got out of the camps. Tie alrocitics went on. 1 wis another 24 Tours before the miliamen finally withdrew. 208 One night’s massacre would have been enough tw produce the outcry that sesulted once the (ist news reports, photos and TV pictures were sent around the world. That the bloodletting was allowed to continue after we kaw what was going on, beyond the cost in innocent ives, made the fallout even worse. tn Tira, the response was unlike anything in the past. Theee had been some opposition to the war: from parts of Labor, fiom political groups further to the Tell and partieulauly the pressure group Peace Now, foemed in 1978 ww protest he Begin government's obvious desire o use the peace with Ligypt as a means to limit, rather than actively explore. prospects for a wider agreement with the Palestinians. Aller Sabra and Shatils, Pesce Now was the driving force behind demands for an inquiry into the Tsracli role int what had happened. But the Leauma went deeper. stags of all political stripes jammed shoulder-to-shoulder into the Kings of Israeli Square in the heart of Tel Aviv 2 week aller the massacre. There were soldiers, 100: 20somethings back from the fighting and cescervists a decade or more older. Same estimates put the size of tae crowd at as many as 400,000, almost Ten percent of the population of sacl at the ame. The protest wes nominally aimed at foreing Lhe government Lo empower a commision uf inquiry. which it did a couple of days later. But the mood in the square was more like an onpouring of shock and shame. While the catalys! wis the massacre in the camps. it tapped into a rumble of growing questions, and doubis, about the war itself, which had been building ever since the prolonged siege of west Beirut. what the invasion was for, how it had been planned and prosceuted. and what it said about our country, our government and our arnicd forces. Lwas at home with Nava, watching the coverage of the demonstration on television. | stared the protesters” view thal un inquiry wis needed. In Ue days since my phone call to Tsila Deo, 'd remained troubled not just by our failure to stop the killings once we knew what was going on. but by the response fron Begin, Arik smd sine olher ministers lo the massac. Determined lo shifl the blame and responsibility elsewhere, they kept driving home the point that it was Phalangists, not Israelis, who had carried out the killings. That was true. But ic could nat erase the failures of judgment and control an our part. We were the anes who had allowed them into the camps. Our frees were deployed around the perimeter. And the killers were our “Lebanese Christian allies” The formal picking-apart of Istacl's share of responsibility would be the job af the inquiry commission. T did take some heart from the very fact such large 207 aumbers of Tseaclis, and ultimately the goverament. had ensured a truly independent probe would now go ahead But other ways in which the war had gone wrong were already glaringly apparent. Some were operational. 1 is fue we ended up overcoming Palestinian and Syrian resistance. Given the numerical balance of forces, thal was a foregone conclusion. But with all the attention paid to the pofiical aims of the invasion, we'd never sufficiently plamed for operating against a wholly different kind of enemy than in our previous wars, and on a wholly diflerent kind of terrain. Huge columns of Israeli armor had found themselves stuck on the windy roads of central 1ebanon, running low on gasoline, vulnerable ta selatively small ambush squads. In some instances, s dozen Palestinian fighters ar Syrian commandos had halted the best-armed, best-trained, tank forces in the Middle Fast for hours on end. Overall, the pattem of past wars had been broken, Even in 1973, once the surprise attacks had been tuned back, Tscaeli forces had advanced. attacked and broken enemy resistance. That hadn't happened here. There was a deeper problem as well. At the scart of the conflict, Begin had declared, boastiully slmost, thal this vas sracl’s first “war of choi.” That wasn't true. But 1956 and 1967 were wars of choice. Yet tose preemptive attacks, especially in the Six-Day War, were in response to a sense of strategic threat that wis commonly understoad by almost all Israelis, There wis u sense 201 just of consensus, but national nity. his war was different. [Led been launched in pursuit of a specific political vision: a marriage of Begin’s political credo and Ari's determination to use overwhelming force to bulldoze i new political reality in Lebanon. The findings of the inquiry commission weee published iu February 1983. They were all the more powerful for fhe forensic language sed. The inquiry did concede Bght's point: 11 was Gemayel's men who had actiafly done the Killing. But it said that the Isacli commanders” decision to allow the Phalangists info the refugee camps “was taken without consideration of the danger which the makers and exeentors of the decision were ablated to foresee as probable — that the Phakngists would commit miessacres.” The commission added that “when the reports began to arrive about the actions of the Phalansts in the camps, no praper heed was taken, ‘The correct conclusions were not dravent. No energetic and immediate action was lake lo resteain the Phalangists and put a stop w their actions.” Ank bore personal responsibility for thas, the report said. So did Raful, and the head of military intelligence. Yehoshua Saguy. The commission 208 secommended that Begia fice Sharon and Saguy. They lef Raful in place, but anly because his term as chicf-ol-stalT was due to end in a mater of weeks. Arik at first refused to go, and Begin refused to fire him, Yet in the end, popular pressure forced the fuse. When smother demonsivation was called in profest al Shacon’s continuing as Defense Minister, a right-wing political activist tossed a grenade into the crowd, killing a young Peace Now member. Even Arik was evidently shaken by the spectre of one of his presumed political admirers murdering a fellow Jseacli for peacefully protesting. Or at least shaken enough to step down as Defense Minister. He did remain in the government as a minister without portfolio. Still, Begin himself would quit as Prime Minister, setiring into virtual seclusion, about balf-a-year later Like the est of the senior officers corps, T tried with difficulty 10 get oa with my awn job, | imagined the contribution { could best mike for now would be, us Teed of Planning, to easure the mix of fovces and weaponry deployed in any future conflict were better suited 10 the task then in the Lebanon war. But [ didn’t believe that such technical failings or planning lapses, however serious a contabuion to the more thin 650 rach hives lost, were what had mainly caused the war Lo go wrong. The eenteal mistake was what had bothered me all along: the invasion was not a considered response to a particular security threat. was an overreaching exercise in geopolitics, with skeight-ol-hand used lo evade the teed to make aud win support From goverment ministers and, critically, the public. Even with questions stil to be resolved about when and how to withdraw the thousands of Israeli fraops that were still inside [ ebanon, [ remember wondering aloud 10 a Gow any friends, and to Nava as well, whether we would look back in a decades time and see the war as “our Vietnam”. Tn fit, Iscaeli troops would still be in south Lebanon nearly wo decades later. when 1 bid left the military and was about to become [saci Prime Minister, Even as a two-star general in the kirva. T doubted 1 would be in a position to help fix the deeper issues raised by the war. Any real influence would be in positions like the chicf-of-stall and his deputy; the head of aperations; ihe had al military incelligeace. They were the core of the armed forces” leadership end had the most regular dealings with senior figures in government. But 1'd failed ro factor in the effect of the inquiry recommendations. Within days of the report, sracl had a new Defense Minister: Moshe Arens, sho sewned from his post as ambassador in Washington. Among As first odes of business was fo act on the inquiry’s verdict on Raful und Yehoshua Suguy. As chief of stall, Arens setled on a choice T suspect most senior officers saw as the 209 sight man for the moment: Raful’s deputy, Moshe Levy. Well over six fect tall, he was known as Moshe Fechetzi. “Moshe-and-a-I Tall” Ife was reserved and soft-spoken, a sat pair of hands after the trauma of the war, Bul Arens also hid to mime i successor lo Suguy as head of military intelligence. And for that job, he nominated me 210 Chapter Thirteen To was a huge responsibility, and not just because T was suddenly ia charge of an mtelligence appacatus ranging from Lit 8200, our sophisticated signals collection and decryption unil, to the operational units like Sayeret Matkal. It was whal was at stake if things went wrong: success or failure in war, and the lite or death of thousands of men an the battlefield. It was a price we'd paid painfully in 1973. And now sein, jus! wne years laler, in Lebanon. 161 newded any reminder, it was conveniently placed on my new office wall: the photographs of each of my nine predecessors since 1948 as Head of the Intelligence Iirectorate, or Rosh Aran in Hebrew. All had come to the role with talent and dedication. All but three had cither left under a shadow, or been fired. Sometimes this was because of ultimarely non-tatal lapses, like a botched mohilizition of our reserves in 1959, or the Rater crisis a few months later, Sometimes, it was due 1o lethal fiilues like the Yom Kippur Wa and |ebauon. I went to see all eight former directors who were still alive. “You know, 1 used to read the newspapers and listen to the BBC in the car fo wark,” Shlomo Gail old me. He was the director 1'd worked or in operational micthgence, the one who'd so memorably made the point that ye might endanger Israeli security nar only be missing the signs of a war, but signs of an appartunity for peace. He was also one of the few to have left office without blemish. “By the time 1 gol to the kirve, | alieady knew 80 percent of what | could about what was roing on,” he said. “Then 1'd spend six or seven hours reading intelligence mistrial, to fill in at least part of the remaining 20 percent.” His message, echoed by my other predecessors, was tht the job wasn't mainly sbout the raw information. It was what you concluded from the information. what you did with it. [t was about judgement. The intelligence did miter, of course. For all of Israels strengths in hat area, I knew from my own experience at Sultan Yacoub that there was still Toam to pret more, better, and more timely information about our enemies, and mike sure il got fo the commanders and eld units than needed at. And while the details of nuny uperations | approved for Sayerct Matkal and other units remain classified, we did succeed in doing that to take just ane example, by finding an entirely new wary to get intelligence from inside Syrian command poss. Yet above all, set ont to apply the lessons of the 1973 md 1982 wars. In rereading the official inquiry reports, | saw thu the intelligence failings had 211 been different in cach of them. Tn the Yom Kippur War, the problem was not just Eli Zeira's failure w activate the sayerel’s listening devices in Lygpt deeply damaging though that was, [t was judgement, Inside Aman, a kind of sronpthink had take hold. 1 was rooled in a confident, costly misconception which went unchalleaged: that Ligypt would never risk another war without an air force capable of breaching our defences and striking towns aud cities deep inside Israel. No one pressed the alternative seenasio: that Sadat might sirike with more limited territorial objectives and. under cover of his SAM batterics on the other side of the Suez Canal. advance into the Sinai. In the Lebanon war, the inquiry suggested, Yehoshua Saguy did ry to wam the generals, and the government, about mor visks. But individual minisiens testified that they hadn't heard, hadn’t been there. or hado’t understood, leading the inquiry to stress the respansibility of a Rosh Aman to ensure not just thi his message was conveyed, but that it was received as well 1 sel out to address both problems. Inside the department, | insisted on making all our preconceptions open to challenge. I set up a nit whose sole fimetnan was to play devils advocate when a consensus was reached. 1 began with the opposite conclusion and, through competing avalysis of the data, and logical argument. tried ta prove it. also wanted to be challenged on av preconceptions. | ussigned a bright young major us my personal intelligence: andanalysis ide. 1 read everything that crossed my desk and could acess any material in the department. “You have no responsibility 1 agree with any of the analysts, or with me,” 1 said. “Part of your job is to disagree.” In the 1chanon war, Signy had Gsced an additional problem. He wis excluded from some government meetings at which crucial decisions were made. That was out of his control. 1 didn’t want it ta be out mine. [ raised the ust wth Begin in our fost meeting, “16 you want 10 gel the maximum value from your head of intelligence.” 1 said, “you should make sure he’s there not just after, but when decisions are made.” Yet he was now only months from leaving office, exhausted by the war and its aftermath, He waved his hand weakly it response, as it lo say tone of it niattered. Ls successor, in October 1983, was Foreign Minister Yitzhak Shamir. Ideologically, he was cut from the same cloth: an advocate from the 1940s of sceuring 1 Jewish state in all of Palestine, by whatever force necessary. He'd broken with Begins pre-state Trgun militia to set up a group called Lehi, which went further and carried out politicul assassmatians: the 1944 killing of 1 ord Moyne, Britains Minister for 212 Middle East Airs, and four years later the United Nations envoy, Count Falke Bermadotte. “Why are you so strident,” Shamir asked me, only halt-jokingly, after I'd insisted on joming 1 government discussion ind pressing several itelhgence suatiers. “Us because Ive read the Lebanon inquiry,” | replied. “1 saw what happened when a message isn’t delivered assertively. I'm not going to be in the position of milking the same mistakes.” He nodded, and didn’t raise it agom In fact, it was under Shamir that T began to get more involved with political and policy issues beyond the armed forces. Part of this came with the job of Rash Aman, There was hardly u major domestic or foreiym challenge that did noi have some security component, and io seenrity mailer on which intelligence was not critical. Buc [also found myself working more closely with leading politicians; mainly Shamir and Misha Arens, who as defense minister was my iin point of contiel. Since | was a Labor kibbutz, we mad m odd threesome. Arens was also a lifelong Jabotinsky Zionist. He had bee in the Betar youth movement in America, before going to Palestine in 1948 and fofmmg the Ign. bn ficl, 1 was with Mishia’s personal bucking that one of my Tormer Saycret Matkal officers — thie sou of a Jabotinsky acolyte — had recently taken his first steps into the political limelight. After a two-year stint as Israel's numbertwo diplomat in Washington, Bibi Netanyahu hid become aur anhassedor to Ue United Nations With both Accas and Shamir, Tbuilt a solid relationship, based on mutual respect, and it would deepen further when 1 moved on to a wider role in the Kiva a few years hater. They wore straight tallies. While wesolute about decisions once they'd taken them, they were genuinely open to discussion and debate. 1 also sometimes found a surprising degree of nuance behind their tough exlerior 1 he toughness was these, however. One of the frst major sceurity crises we faced atter Shamir became Prime Minister was known as the Kav 300 aftair. numed for the bus route between the southern part city of Asadod and Tel Aviv. On the evening of April 12, 1984, four Palestinians from Gaza boarded the bus and hijacked it back toward the border with Feypt. They told the passengers they were armed with knives, and that a suitcase which one of them was caving comtiined imexploded tink shells. Afr a highespecd chase, an Ise amy unit managed to shoot out the tires and disable the vehicle. when it was still shout Ten miles short of Gaza. One of the pissengers had been severely injured ul 213 the start. A number of others managed to escape when the bus was stopped. But several dozen eemained inside. 1 was in Europe at the time. on one of my periodic trips to discuss Middle Fast issues with i fellow infelligence elie. Yet un aide called me with the news. Leas several thousand miles away from what happening. But | knew there was every possibility Sayeret Matkal might be called in. and my instincts told me we should proceed with caution. The situstion we were ficing felt nothing like Sabena, much less nichbe. Here, we had a single bus. Our troops, and in fact everyone from ministers and officials to reporters and photographers, were in a Toase cordon a couple of dozen yards away, That sad to me there wis no sense thst the hijackers posed un immediate danger. Nor did they seem to have come equipped for a major confrontation. In place of the AK-17s and grenades we'd seen in previous terror attacks, these guys had knives, and, if they were to be believed. a couple of shells with no obvious way lo detonate then. I phoned a friend in the conunand post set up near the stranded bus. 11e told me that Misha and Moshe Vechetzi were there. There was a standoff with the terrorists and, for now, it was quicl. The defense mimster nd the elrici-of=st if, af course, did not need my presence, much less my agreement. Lo order the sayeret into action. But | said: why not wait? Though the last flights back to sre! had already left, 1 canld be at the command post by midemorning, Beyond wanting 10 be present if the sayeret was ordered in, [helicved the crisis might even be brought to an end without another shot being fired. “T'll tell them what you said,” my friend replied. “But 1 doubt at°Il be allowed fo drag on much past daybreak” Ile was right. With my Chinese Uarm comrade Yitzhik Mordechai in overall command, Sayeret Matkal stormed the bus af about seven in the morning, They shot and killed two of the hijacks immediately. through the veheks's windows. Sadly one of the passengers, @ young womau soldicr, died in the assault, bul the Test of the hostages were freed, none with serious injuries. A cantroversy saan erupted over what came next, The sayeret commandos had captured the other two terrorists alive and uninjured. Yet bacely a week later, first in an American newspaper and then the [sraeli media. reports emerged that the two surviving Palestinians had been killed after the higckmy was over, A your later, Yitdik Mordechs was — wrongly — put on trial for his alleged part in what had amounted to a summary execution. And, rightly, exonerated. Though the fill details never became public, the poopks responsible turned ou 10 be from the Shin Bet, our equivalent of the [BL 214 Weeks later, Misha Areas mentioned Kav 309 inone of auc tepulac meetings. Ii was not so much a statement of what should or shouldn’t have happened, but a show af genuine puzzlement, “How ean it be,” he asked, “when there is a real Fight. an apzaion im which our soldiers wre shooting, that ferorisis come out alive? The answer. Lo me, was simple: Sayeret Matkal. From our carliest days. there was an understanding that you used whatever force necessary in order make an operation successful. Yet once the aim had heen achieved — in this case, eliminating the danger to the passengers — it was over. | am convinced, by the way, that Misha didn’t actually order the sayeret, or anyone else, to kill all the terrorists, 'm equally convinced there was a tacit assumption on the ground that Misha's view, and Shamir’s as well, was that this would be no bad thing. PE Yet by the summer of 1984, Shamir and Areas appeared in danger of losing their jobs. Isacl’s next election, the first since the Lebanon war, was duc ia July. Just as the Ins of the 1973 war had helped Began end Likud’s three decades in opposition, the polls and the pundits were now suggesting that Shimon Peres might bring Labor back to power. There was no prospect he'd win an oulnght majority in the 120-seal Knessel. No one had ever dane that, nol ven Ben-Gurion in his political heyday. Urom 1948, Lsracl’s political landscape had been populated by at least a dozen-or-so pasties, mostly a reflection of the various Zionist and religious groups before the state was established. The dominant party always needed to make deals with some of the smaller ones wo get the required 60-vote parliamentary majority and form a goverment. The Likud looked vulnerable. Domestic concerns, alone, were eroding irs support. Under Begins turbo-chirged version of Millon Freedimim ceanomies, an economic boom had given way to cunaway inflation and a stock market crash. Lebanon, however, was the min issue. and it remained a running. political sore. The ussassinaled Bashir Gemayels brother, Amin Germayel, had become president. Bul Israel still had large numbers of troops there. And while most of the PLO fighters had gone, we faced a new and potentially even more intractable enemy in the south of the country, When ur invasion began, the arce’s historically disadvantaged Shi'ite Muslim majority had been the one group besides the Christians with the prospect of benefiting. The PLO rocket and aillery bases had disrupted ther fives amd, worse, placed them in the Ime 215 af our retaliatory fice: Some of the Shi'ite villages in the south even greeted our invading units with their traditional welcome, showering them with rice. But for anew Shiite militia calling itself Hizbollah formed afer the invasion and inspired by the Ayatollal Khomeini’s revolution in Lun — our conliuing militacy presence was anathema. la Noveanber 1983, Iicbollah signaled its intentions when a truck bomber drove into a building being used as our military headquarters in the south Lebauese city of 1 yre. killing more than 60 people. Yet the election ended up as a near-tie. Peres did lead Labor back into top spot for the first time since Begins victory in 1977. Buc he got only 44 seats, to the Lilud’s 41, After weeks of horse-truding with smaller parties, be could not form a government. Neither could Shamir. The result, Gov the frst time in peacetime, was a national-unity coalition, including both main panies. Peres would be Prime Minister for the first twa years, and Shamir the final two. But the stipulation of most relevance to me was thal one man would be the Defence Minister thoughout the four years: Yitzhak Rabin. My relationship with Rabin went back much further than with Misha. I'd first met him when 1 was a saverel soldier. 1d interacted with him more as sayeret commander, and of course during Entebbe. Now, we began io work even more closely, and the main challenge in his early months as Defense Minister wis what to do ubout our troops in 1ebanon. We had gradually been pulling back. We were more or ess on the d0-kilometer line which Sharon had claimed was the point of the invasion. But even this was costing us lives, with 70 obvious benefit from controlling a luge slab of territory on which nearly Bal a-mmillion Lebanese lived. A decision was now reached to shrink ous “security zone” further, pulling back to the Litani River. It meandered about 25 kilometers north of the border, and in some areas was even closer to Israel. 1 argued stramgly fn favor of geting out aliogether. §aceepled that the “Litani line” might help impede cross-border raids. But especially since the remaining Palestinian fighters and Hizbollah were acquiring newer Katyushas, with a rimge of up lo 20 kilometers, they could fire rockels over the security ane. My deeper concern wes that we intended to hold the acca with between 1.000 and 1,500 Tsraeli troops in open alliance with a local Maronite Christian mihtia, called the South Lebanon Anny, This would rule out iy hope of working out security amungements with the non-Christian majority in the south. tried to persuade Rabin we should withdraw all the Tscaeli soldiers and coordimite security arrangements with the equivalent of a local eivil-defense guard. T suggested four separate militias drawn (rom the local population — 218 Christian, Shi‘ite Muslim, Diuse and ethnically mixed — with the aim of reflecting the balance in cach part of the south. Israeli troops might still have to cross inte Lebanon. but only for briet, fangeted operations to preempt prepartions for a lerror sltck. “We need lo remember what we're there for.” said. “We have no lerritorial claims. Is lo protect the north of [srael. But it will end up being about proteciimg our own troops inside the security zone. 1 will be like the Bav=Lev linc in 1973, fighting for fortifications we don’t need.” [ couldn’t persuade him. I'm sure he understood the argument. and he may even have agreed. But when Katyushas next fell on northem Israel, he us Minister of Defense, not 1, would be the one m the political firing line Far from straining our relations, our frank exchanges on Lebanon seemed to build further trust between vs, We worked closely on a range of issues, When Sayer! Martkal or another intelligence unit planned an operation across our borders, both of us would present the action to the cabinet. Ducing the operations. I'd be either in the kw ar a forward command post. Since nearly all of them happened afer nightfall, Vitdusk would sully be back home, asleep. by the time they ended. | would phone him. The trademark voice — slow, aravelly. deep even when he was wide awake would answer. I'd tell him the mission was aver and with only one exception during my period as head of intelligence — successful. “Todah.” he would say. “Lekitrant™ Thanks. Bye. He was never a man lo waste words. Far ane of the very few times | can remember, fu phoned me one moming in October 1985. 11 came coupke of days aller an especially gruesome Palestinian terror attack. Even with Arafat now more than a thousand miles away in Tunis. much of Rubin's focus was taken up in responding to, or trying to preempt, Palestina terrorism. Thi issue was especially sensitive polineally in the wale of a wav in Lebanon that was supposed o have eliminated that thecal. For Rabin, ‘moreover, it had become personal, He'd had to sanction an unprecedented exchange of 1,150 Palestinian scenrity prisoners earlier in the year fo sceure the freedom of three Iseaeli soldiers, including wie of ow men from Sulan Yacoub, who had ended up in the hands of the radical Popular Front for the Liberation of Palestine General Command. Now a group fram another of the radical factions, ihe Palestine Liberation Froud, had hijacked an laliau cruise ship called the Achille Lauro ea route from Egypt to Tscael. They murdered one of the passengers, a wheelchuir-bound, 69-year-old Jewish Amencan named Leon Klinghoffer, and dumped his body overboard 217 Rabin's closest aide. whom [knew well, was aware that Unit 8200 had intereepts that laid bare the details, and left no doubt the murderers were from a PLO group. He called and asked me to appear on a weeldly television inferview program called Moked. 11 wis hosicad by Nissim Misha: brash, ineisive, und one of Tsracl's best-known broadeast journalists. [ pointed out to the Rabin aide that I'd never done anything like this before. But he insisted it would go well Ile briefed me on the questions [ could expect, nol just about the Achille Lauro but the wider issue of Palestinian auacks, as well as Syrian President Uafoz al- Assad’s efforts to re-equip his air force after his losses in Lebanon. So [ came to he interview prepared. | brought audio tapes of the hijackers, and a large plhotwgraph of the MiG-255 which the Syrians were seeking tb squire. My appearance will not go down in the annals of greal momeals in television, Rut af the time, very few Israelis even knew who | was, and (felt I'd done OK. Twas sueprised, however, when Rabin phoned the next day. “Ehud, T dido’Usee it. Twas aliending some eveal” he said. But his wife, Leah, had recorded the program. “1 just watched it. I should tell you, I think it was exceptional. You did a grea job. 1 was highly portant for us, for the army. and, [ dare say. for you wa ow Twas not sure what he meant by saying it might be good for me as well, although a decade later, at the end of my army career, he would play the central soll info my entry into Ismael polities. 1s fue tha there was also some politics al the upper reaches of the military as well, especially acound the choice of chief of staf, and that Moshe Vechetzi's tem bad only a year-and-a-half to po. Bur I didn view mysell' as a serions candidate al this sage. Moshe’s own preference seemed 10 be iter Amiv Dror, the head of the nother command duriog the Lebanon War, or Amnon Lipkin, the veteran paratroop commander who'd been with me on The Rue Verdun raid in Baul. My own hope was that the nod would go to any even closer friend of mine: Dan Shomron Thad first got to know Dan well in the late sixties after Karameh, Israel's costly standoff with Arafat, when Futah's influence was in its infmey, We exchanged impressions un what had gone wrong, and why? Whe | became commander of Sayeret Maral, we remained in touch, and he took a close terest in all of our operations. We also crossed paths in the Sinai iu the 1973, 218 itl which Dan's division was key in staunching the Teyptian advance in the first days of the war, later inflicted heavy losses on one of Sadau's armored forces and was part of the final push on the offer side of the cal, And, of course, dusing Frleblb. Daun lid ship tactical instincts, u bilief in the inpovtancs of using new lechnology 10 gain and sustain an edge. and an openness Lo unconventional approaches. Faced with a challenge in planning or executing an operation. he looked at it from all sides, determined to come up with the right approach, not always the expected one. In a lot of these ways, we were similar. which was no doubt one reason aur relationship had grown claser as he and 1 six years younger, and a step or twa behind rose up the rans, In fiset, Dan was the reason I'd made onc of my rare forays ino kira politics not long after Moshe Vechetzi took over as chief of stafl, when Misha Arens was sill Defense Minister. | acted ta derail what seemed to me a blatant attempt by Mashe to advance Drori’s and Amnon Liphin's prospects for eventual succession as chief-ol-s1all. and to Lake Dan oul of the contest altogether: Twas sitting at my desk on the third floor when the chief of internal army seenrity, an officer mumed Ben-Dor, walked into my office. “Listen,” he said, “the chief of stall las a right 10 give me a dircet order in cases where he thinks there is a need for a special investigation. But you're ory commander, so | wanted to lt you know.” “What is 12” | asked. Ile replied that he liad been ordered to “check out rumors that Daa Shomon isa homosexual {wes applied. The whole thing stank, on every level, and not just because | was confident the “rumors” were nonsense. “Look.” Tsaid, *T have no idea whether some sub-clause in anny regulations allows the chief-of:staff to ive you orders over my head. But even il it docs, 1m ordering you to do nothing until Ttalk to Moshe Tle nodded in ageeement. Tn fact, he seemed relieved. Tle also lec ine know tha the source of the rumors was a umber of senior officers, including a couple of generals. [went straight dosnstaics and into the chicf-of-s1alPs office. Moshe was al his desk, smoking a cigarette. One of the advantages be had in being nearly a faat taller than most of us was that 1 found myself loakang not into his eyes, but up al them. “Moshe.” | said, “Ben-Dor told mie youve ordered him 10 investigate a rumor chat Dan Shomron is a homosexual.” He said nothing. So 1 went on. “ve told him wot 10 do it. And I've come here to conviniee you thet it's 219 improper.” This was more than 30 years ago, at a time when being gay. and cenainly being gay in the armed forces, was a much bigger deal than now. But 1 still had na doubt at all that this amounted ta a witch-hunt, Moshe still suid nothing, 1 have no wea whether Dan is ov is nota homosexual. Aller knowing him for years, | have no reason at all to believe that he is. But let’s assume. for a moment, that he is,” [ said. He's not some junior lieutenant... This is i mam sho bss risked his fife for Isracl. Repeatedly, Under fire.” Theu, | got to the real issue. “J hesitae lo mention this.” | said, sealizing, and in a way hoping. that my tone would sound vaguely threatening, “But if vou order this, the very fuet of doing so might be mierpreted as being a result of some uther motives on your part. I'm doing my best to comings you to think again. But T want you to know that if T can’t, I'm going com here to Misha’s office, I'll try to convinge him of the damage from what you're contemplating to the whole fabric of trust in the general staff and the army, to the image of the army.” Sill. he said nothing. Tle nodded occasionally. Te puffed on his cigarette, put it our, lit another one. It was pretty clear he liad no intention of sescinding his order Within 20 minutes, was in the Minister of Defense's office. | spoke 10 him for about 10 minutes. Misha listened. At the end. he said: “1 understand what you've fold me.” | never discovered whit exactly he suid to Moshe Vechetz, But the investigation never happened. 1 never spoke # word about any of it 10 Dan until years later. after both of us had lef the army. The result, however, was that Dan became deputy ¢hief-of-staft under Moshe, the hafest step in whist was beginning lo look like # steady rise to the lop. But Misha did make a few concessions to Moshe's preferred candidates, and that now turned out to have major implications for me. It was a long-accepted practice thal ehichsof-stf had moe thm one deputy drm reir period in charge. In the homestretch of Moshe’s teoure, he was able wo bring in Amir Duori fora spell as his number-two, And early in 1986, he also brought Amnon Lipkin buck to the kirve, Amnon was given my job, us Director of Intelhgenee, But | got the post which Amnon was leaving: head of the ecatral command area. 1 his meant that, for the first time, T'would be in charge of one of Israel's three regional military commands, and we were based on the edge of Jerusalem, with seeunty sespousibility for the West Bank This was my first direct exposure 10 Lhe combustible mix of restive Pulestiniins and the growing number of Jewish scillers, Our min bricf was lo prevent terror attacks. vioknee or unrest from the roughly 850.000 West Bauk 220 Palestinians toward the 50,000 Israelis who were then living in the settlements. At the time, by far most Palestinians weee not involved in any violence. They were mainly interested in getting on with their lives. Yet there were signs of fronble. The PLO keaders” refocation fo Tunis hid reduced ther dircel inline. But the briefings | got rom Shin Bet officers made it clear that some young ‘West Bankers had begun trying to organize attacks against police, soldiers and Lsracl civilians. | he seulements were also growing in number, and their residents were not above acts of violence against Palestinians. Further complicating the situation was the fact the settlers enjoyed the support of key Likud members in the cabinet: Shamir, who was about to take his tum as Prime Minister iu October 1986: Misha, now a minister without portfolio: aud most of all Arik Sharon. In an astonishing demonstration of resilience and determination, not only had Arik remained as a minister without partfolio when Shani succeeded Menachem Begin. In the coalition government, he bad become Minister of Trade and Labor. Most importantly, when he'd been Agriculture Minister under Begin, he was the driving force in plans to expand Jewish settlement an the West Bank, including “blocs” placed around the major Palestinian wwns and cities for the ficst time since 1967. Thad a responsibility to protect the settlers, and [ did my best to fulfil ir. Yet Lbclieved it was essential they understood that they were subject to the authority of the state of Israel and, like other Isracli citizens. had 0 operate within the law. This was no mere theoretical problem. A Jewish uaderground had been established by members of Gush Emunim, the Orthodox Jewish movement set up in the 1970s w advance what they saw as a divinely mandated mission to seitle the West Bank. Tt had carried out car-bombings and other attacks in the carly 1980s, leaving two Palestinian mayors crippled for life. The femor campaign had ended only when the Shim Bet canght the cell placing explosives under Arab-owned buses in Jerusalem. Iopeful of preventing misunderstandings, and ideally building a relationship af trust, | vised sony of the settkemonts dumm the ety weeks in my new post and spoke with their leaders, a few of whom remaiu friends 10 his day. But in the spring of 1986. we faced our first major test on the ground. In a pre- Passover event organized by Gush Emunim, some 10,000 settlers streamed into Lebron, a eity sacred not only to Jews but Muslims as well as the burial place of Tebrew patriarchs and matriacchs. Peace Now activists had planned a counter protest, but Rabin denied them permission. Still, anti-sertlement members of the Knesset und other Isvach peace activists did gel eleanunce to march from Jerusalem to Hebron. 221 My job was Lo ensure the security not just of the Gush Emunim march but of the counter-demonstrators, and, uf course, the local Palestinian population. As the rival marches by the Israelis proceeded, 1 personally delivered wamings against ny viokaee, both 10 the seltlement leaders und 10 1 pair of the most promincal counter-protesters, the peace activist Uri Avneri and Knesset member Yossi Sarid. The event went off without major incident. But the next day. Davar. the venerable Labor newspaper I'd fivst ead as a child in Mishmar Usharon. let sip against me. Under a photo of me with Avaeri and Sarid — my arm raised, ostensibly in some kind of threat but actually in the time-honored Jewish practice of talking with my hands the article aceused me of siding with he settlers. (blood was spilled in the weeks and months ahead. the newspapec said, “it will be on Barak's hands Ordinarily. I would have ignored it. But never in my military career had 1 been similarly attacked on a0 issue of any importance. [ was especially angry because not only was the insinuation unfounded. Tt was diametrically opposite to the stance I was determined to take in this, my first regional command. Yes, 1 wes committee Lo providing sceurity for the seillers. Bul especially in the wike af the crimes of the Jewish underground, 1 was determined to ensure they remained within the boundaries of the law, Afew dys later, | called Rabin’s aide und asked fo sce the Defense Minisicr, and vas 10ld 10 come see hin afler Saturday lunch at his home. When Tarrived, Rebin got right down to business. “Ehud, you wanted to see me?” he sand. “You've probubly seen Davar.” 1 replied. “It was a pretty nasty piece. It distorted things.” Yet as he began asking for details, it seemed he had no ides whet 1 was talking about, “Thud, T never read it,” he said. “IF you hadn't wld ne, I'd never have known there was an issue.” 1 assumed this was a white lie, told 10 reassire me. Bul years later, when | was Mimister off Defense, und then Prime Minister, T sometimes found myself on the other side of such meetings. An officer or official would come se¢ me because of something said about them in the medi, or remarks they wee quoted is birving mad. When | old them I'd been unaware of it. J could see the disbelief in their eyes. By then, however, I realized that under the multiple demands of a senior role in government, you really could fail to natice events that ofhers viewed as crucial to their seputations or careers. To reassure them | truly hadn't noticed, 'd tell them the story of my meeting with Rabin. PEE 222 There was another, slightly less noble, reason | wanted to sel he record straight with Rabin. Though only gradually did 1 admit this even to myself, [ realized that my experience m a regional command had ticked the one missing box in the CV of our wp generals, meaning that | might indeed be a candidate to succeed Moshe Vechetzi as chiet of statf. Ar first, I resisted taking the prospect toa seriously. The job of ransarkal not only eimied responsibility for overall command of the amied forces. Since our countey still faced multiple scourity threats. the chief of staff was, along with Prime Minister and Defence Minister, among the most impartant, influential and visible positions in Isrucli public life, Yet as the April 1987 date for the changeover drew nearer, it wis difficull not 1o think about it. Not only was T apparently under consideration. To judge (rom media reports, and officers” smalltalk, it ippeared that Rabin had whittled down the possibilities to two. One was Dan Shonmicon, and T was Lhe other. Sull, it was voly when Rabin phoned me carly in 1987 that [knew it was true and that 1 would not be getting the top job. “Ehud,” he said, “I wanted you to know I've decided on Din ta be the nest ramatkat, 1 wml you 1o be his deputy.” [ean’t say was surprised he'd chosen Dan, I wasn’t just that he was more experienced, or even that, since he was older, missing out on the top job this time would probably mean missing out for good. Yitzhak bud always valued Dan's directness and honesty. his courage and record of service. Above all. I'd long sensed that he felt a special debt io Dan: for Entebbe. Ata time when so much could have gone wrong, it was Dun who had taken 4 fim, conlident, suceesshinl hold on the operation. Sill. I was now 45. For me no less than for Dan, | knew that if | was passed over as chief of statf, there was no guarantee I'd be chosen the next time. “1 sespeet your deersion,” old Rubin. “And | five so donbl Din will be a good a very good — chief-of-stall.” But {had tw consider my own future. “Liven though I'm sratetul for the offer of deputy.” 1 said. “I think it’s better for me to leave, To open up i new chapter, and do something else in life.” Rabin said hie couldn’) accept that. “Come see me.” he said. “Now.” When | got to Jerusalem, 1 emphasized again that I had no doubt Dan would lead the armed forces well, But | said my decision to leave the military wasn’t a mere whim. 1 biel been thinking about my awn future and soy family’s. We bad three young daughrers. A few months earlier, we liad moved home again, into a wide, ancestory rumbles wilh a big yiud oul back. [wis in a new lown valled Kochi Yair. just inside Isracl’s pre-1967 border with the West Bank, and il struck me 223 as a good time 1 settle down in a way that would be impossible iT stayed on in the upper reaches of the military. Pechaps do something more academic, in a university ar a policy think-tank, For the firs time, polities had some uppeal, too, tough | didn’t say this to Rim. At that point, | had no idea bow, or even whether, 1 might gel involved. But since my appearance on Moked, others seemed to assume it might happen at some stage, Out of nowhere. a lead political journulist, Hanan Kristal, had wrillen w story in 1986 purporting w predict he successors Lo Israels political old puard: Peres and Rabin in Labor, Begin and Shamir in the Likud. It appeared in the newspaper Hadashol, The paper ran side-by-side photos of the ostensible futue leaders, doctored 1o look older, who Hanan predicted would go head-to-head in the election of 1996, a decade away. One was Tsrael’s ambassador ta the UN and « protégé of Misha Arens: Bibi Netanyahu, The other was ie Rabin listened with patience to my obviously seuled intention to Jeave, but remained firm that 1 should stay and become Dan's deputy. In the end, | agreed Ue think things over and tht we'd tlk in i weeks time. In the meantime, 1 went 10 see lwo veteran generals who had found themselves in a similar situation, mentioned as possible chiefs of statt but never chosen: Arik and Ezer Weizman, 1 saw Avik on hs farm in the Regev. He wis obviously enjoymys his extraondinary political rehabilitation since the Lebanon war. His expanding girth was settled into a sofa in the living room. 1 filled him in on my conversation with Rabin, “I’m considering leaving,” | sad. “It just seems like a long time to wal, even i 1 do get the job aller Dan. Theres i lot else [wan to do wo like.” Arik was probably Lhe genecal most experienced in being denied the chief-of- staff's office. On at least two occasions. he might reasonably have been considered. Bul in a career liuered with tense encounters with his superiors, il never happened. “You should stay on.” he said. You're not that old. TU'IL probably be good for you, and tae army. to be deputy aud then chief.” The only farther advice he gave me was 10 do all 1eoukd Gomally 10 commil Yitzhak io making me Dans successor after his term ended. Tisited Czer at his home in the seaside town of Caesarea. We sat on the femace, with Ezer’s gangly frame draped over one of the cane chairs, “Ehud, it you stay, do you think you hive # good chance of being the next ramatkal,” he asked. T said that while nothing could be certain, I thought there was a good chance, He replied without hesitation: “Then stay.” He'd come close to the top ob, be told me. On the eve of the Six-Day War, when Rabin had collapsed 224 physically from the weeks of tension, Yitzhak had asked him to take over. Tle'd said no. But be said he'd alvays believed he could and should have been chief- of-staff and that if he hadn't left to go into politics, he still might have got the ob. Then, suddenly, he shouted: “Retnnal’™ When his wilt appeared, he said: “Tell Barak the missing piece in my life, the vae I've never stopped regretting.” She smiled, and said: “It's the fact you did not become ramathi. I saw Rubin a couple of days later. Though ['d pretty much decided to take he deputys job, [was sill bothered by the prospect uf serving as deputy for the next four years only to find someone else being named chief-of-statf. [ knew that no mater what ussurances Yitzhale gave me, there was no way of bem sre. He did sy he viewed me as the natural nexi-in-line. But sill fel hesitant “T want you 10 consider two things,” T said. The first was a formal decision that Dan would have only a single deputy during his time as chief-of-statf, He said yes 10 thal. Yet the second request was going uw be even more difficult. Tleartening though it was lo hear was Dan's “natural successor”, | asked him to put if in writing. It was not that I doubted his word. Bu if the surprise result al the bast election wis amy medication, there wis no way of predicting which party would be in power when Den’s terms ended. | wanted hin to keep a record of our understanding in his desk and pass it on if someone else was Defense Minster by that time. Without a moment’s hesitation, he tok out a picee of paper aud wrote doven exactly what he'd told me about the succession. Tle shook my hand as Tleft. “You've made the right decision.” he said. And 1had, even though Danand 1 and Rabin too would soon face by far the most difTieul challenge iu Israel's conflict with the Palestivians since ous capture of the West Bank and Gaza in the 1967 war. 225 Chapter Fourteen Tt began with an accident. On Tuesday, December 8, 1987, an Tsraeli tank transporter crashed info a minibus caring Palestinians from the Jabalya refugee camp near Lhe main crossing (vom Gaza into Israel. Four passengers were killed By the time of the funerals the next day, a rumor had spread. no less incendiary for bem ubsurd, thal the crash had been deliberate relaliation for he fatal stabbing of an seacli nian a Rew deys cadier. Crowds of Palostinians leaving the burials began shouting “Death to [srael!” They hurled rocks and bottles at Israch security patra, und blocked strets with burmng fires, By the next day, the violence started spreading fo the West Bank, and then to parts of east Jerusalem. The headline-writers moved from the word “disturbances” to “unrest” and finally ta fhe Palesitnians’ own name for the mast serious outbreak al violence since 1967: the “insifada”. Ue uprising Atleast for the [ist weck or two, we assumed its ferocity and seale would subside. Our immediate aim was to contain it, and limi fhe human cost on both sides. Yel when Dan and [began visting umits on the front line of ts new conflict, we realized that if it kept escalating, we'd have to find new tools and strateyries to bring it under control. We were in charge of an anny trained to caquip ind fight enemy soldiers. Now, we wre askmg leenage recrits fo aperaic as viol police against sionc-throwing mobs. Before long. it wasn't just stones, or even botdles. In one incident in Gaza, a young soldier was surrounded by a crowd of Palestinians and stabbed. He opened fice, wounding two of hi witackers. Yitzhik Mordechai, now the head of the southern command, told reporters that his troops were under “strict orders to open fice only if their lives are under threat,” That was true. But | couldn’t help wondering how lng the atlier part of his statement would hold: hat we remained “in control of the situation.™ We did feee in control for the first few days. Defense Minister Rabin was away in Washingion on an official vasit. When bis office asked us whether he should My back, we said there was uo need. But on his return, we quickly agreed that, as a first priority, we needed to find an alternative to live ammunition in quelling the attacks. Otherwise, wed be fell with two equally bad options: cither simply stand aside, in order to avoid killing or injuring demonstrators: or intervene with the inevitable casualties. But ane of our most important early discussions was about the broader aspects of the violanee. The meeting, held 226 outside the kiya in a facility just north of Tel Avis, was Rabiu's idea. In addition to Dan and me, it included key members of the general stall and senior defense ministry officials. The idea was for us to hear a half-dozen academics and other specialists spel about the political uspects of the sudden euption of Palestinian violence. Though he spoke for barely 10 minutes. it was the last speaker who left the deepest impression. Shanon Shamir, a professor at Tel Avy University, began by emphasizing hie wis not an expert in riol control. Finding a response lo the violence was something we were far better equipped to do. But then he paused, looked miently at Rabin, an and me, and said: “What { can do is draw on History.” One by one. he cited examples of more thi a dozen broadly similar sebellions over the past century, in the Middle Bast and beyond. “TC we were dealing with simple rioting, things might be different.” But he said the Palestinians were, fundamentally, acting oul of a shared sense of grievance, and shared national identity. Both were in large pact the result of Israel having controlled their daily lives now for more than two decades. “I'm afraid I can find ro historical precedent. for the successful suppression of the wtional will of a people.” he said. Even when those in power used unimaginably punitive tools: like expulsion, or forced starvation. “Tven, as we know well as a Jewish people, exlermmation.” glanced at Vituk and at Dan. Both of them looked like 1 Rel: fu no doubt the professor was right, yet also aware that, in the short term, we still had 10 find away of putting 1 lid on the cauldron and keepmy: the situation for getting irretrievably out of control. Twasa’t as if I'd been unaware of the sense of the anger building among. many West Bank and Gaza Palestinians, or of their wish 0 see an end to Israel's military administration and Ue rowing nmnber of Jewssh selllements. From my tine ag head of the central command, © also knew that there was 8 young, activist core intensifying: efforts to organize attacks on troops and settlers. But none of us hud amy inkling that something of the scale, longevity and pohtical complexity of the intflada lay ahead. Pactly, this was a (ailuce of specific intelligence warnings. But it went deeper thn that, Sobering though it was, [ had to accept that 1a less so than before the Yom Kippur War in 1973 — Cand sony athens had for too long been comforting ourselves with a fundamental misconception about our military accupation und civilian seulement in the areas captured in 1967. The rools of the myopia went back w the immediate aflormath of the Six-Day War, lo the 207 generally eivil, and often friendly contacts, Tsraclis had wilh Palestinians at the time. The local population had, after all, been under orier aecupation powers before 1967: Jordan in the West Rank, and Figypt in Gaza, Assuming our welmiviistution was ess onerous, most [sraclis believed i way 10 coexist could be found. And hat sooner or later. there would be a land-for-peace agreement and we would withdraw from at least most of the territory. But as the years passed, with no sign of @ willingness by the PLO to consider any kind of peace talks, we made the cardinal error of assuming the occupation was sustainable Yes, there might be periods of violence. but nothing that a combination af political resolve, arrests, detention and, where necessary, military force could not hold in cheek. For us, and certainly for me, the Palestinians became essentially a security issue. As one of Tsrael's finest novelists. David Grossman, would lay bare in a bestselling book of reportage called The Yellow Wind, about a year info the intifada, we had ceased 10 see ihe human cflects of 20 years of occupation, not only on the Palestinians but on Israeli society as well Yet the power of Professor Shamir’s presentation lay not so nwuch in its novelty as iis succineiness, clarity md, shove all, ws timing. The rioting had already pone on for longer than any of us had expeoted. 1 seemed to be gathering strength. Buc until our meeting, we were still looking at it essentially as a civil distirbince. That wis what began to change, For all of ws Wha didn't change was the need 10 wy 10 bring the violence w an end. Dan immediately put me in charge of looking for allematives to live ammunition. T began with our own research and development engineers, We also asked military aitachés in our embassies 10 talk 10 lsw-enforeemient agencies, academics, or anyone else with knowledge of non-lethal methods of crowd control overseas. ‘Some of the more far-flung examples seemed promising, at least uncil further investigation. South Korea had years of experience i confronting student protests — gencrally, though not always, managing lo avoid (aualities. But it turned out this typically involved sending in serried rows of up to 25,000 riot pohce aginst a ow thousand campus protesters. Besides the fret we'd have needed an army the size of the Americans’ 10 field enough soldiers. it was absucd to imagine dealing with dozens of far-flung confrontations on any given day with parade-ground formations of troops. We looked at anything that seemed it might work. [u the varly siges, most of the auacks involved rocks and bottles. Our R&D engineers developed a Jeep- mounted “gravel gun” that fired stones ut a distance of up to 250 feet. They could eause injuries, but weren't lethal. We acquired launchers for pepper spray 228 and tear gas. We even looked at the possibility of dropping nels over crowds of attackers. Very carly on, we shilled to using plastic bullets. But even that presented problems, At a distance of a hundred feet or so, they could drastically seduce deaths. But when i young recruit sin hundreds of Palestinians closing in an him, he wasn't about 10 Lake oul a Lape measure. Over Lime, we began relying wherever possible on rubber bullets and, in extreme cases, snipers to target the legs of the organizers or ringleaders: Fall of this sounds soul-destroying. that's becuse it was. Especially with daily television coverage of the clashes amplifying overseas support for the Palestinians, morale among our soldiers alsa took a batlering, In visits fo unis an the West Bank and fu Gaz, Dan and 1, and Rabin oo, heard iwo opposite responses. Some of the young soldiers wanted us (0 use maximum force. We are the army, they argued. We have the weapons, Why the hell don't we use them? But we also beard another view, if less often: why are we here at all? We imposed elosures and curfews. We tiade thousands of arrests. Still, hundreds of soldiers and settlers were being injured, a number of them disfigured or disabled. By the end of 1998. the Palestinian death toll was above 300. In Uehruscy 1989, an lsraeli officer was killed by a cement bluck tossed from a rooftop in Nablus. A month later, a Palestinian knifed several people in Tel Aviv, killmg one of them. And m July, in the fist attempt mside Israel at i suicide attack, a Palestinian passenger grabbed the wheel of a bus ou its way from Tel Aviv 10 Jerusalem and drove it off the road. killing 16 people. PT By the summer of 1990, although the violence had begun o flag slihly, I ws fecling more dramed and exhansted than al any ime sie my boul of illness in the Sinai afler the 1973 war. | even briefly thought of leaving the army after Dan's term ended the following year, 1'm not sure whether [ would have done thi if the situation had nol begun to etunge. But {1 did, dramatically. The intifada gradually began to subside, and an entirely new crisis suddenly intervened. On August 2, against a background of longstanding financial and territorial disputes, Iraq's Sack Hussein seat in tens of thousands of his troops nd occupied the neighboring state of Kuwait. Though the immediate crisis was 229 nearly a thousand miles away from us, he tried to divert aeation from US-led international condemnation of his invasion by threatening Issacl. [le said “all issues of occupation” were on the table the West Bank and Gaza, the Golan Heights, and Lebron — and vowed 10 “lef our fire cal hall of rach” in a futnre wer. And we could not assume this was mere thetoric. Iraq had aa arsenal of Soviet-made ballistic missiles. Called Scuds, they were not always accurate at loug range. But they could reach Lsigeli towns aud cities, and could carry not just conventional explosives but chemical warheads. Moreover, Saddam had usead chemical weapons: during the Iran-Iraq war. and to kill thousands of his own restive Kurdish population in the town of Halabja in the spring of 1988. Even the prospect of American military action seenied not fo fuse hin. Tlours into the invasion, he moved an armored (ores toward Kuwait's border with Saudi Arabia, 1 key US regional ully, immediately prompting the President George Bush’s administration to go beyond mere verbal condemnation. With Saudi agreement. Washington dispatched a squadron of T-155 to the kingdom — the first step in what would become a huge American land, sea and air force to ace down Sedan andl Force bin oul of Kuwait Given the credible threat of Scud missile attacks on Lac, Den immediately assigned me to coordinate our assessment and evaluation of what Saddam was Hikely to do in the event of a US-led attack, and what defense arrangements or tne military response would he necessary. We knew we'd be under stiong, pressuce from the Americans 10 stay out of any war. Israeli involvement would be a political gift to Saddam, allowing him to convert 1 conflict over his aggression against an Arab neighbor into « “defense” against “lssacli occupation.” But we had a primary responsibility to protect our citizens Twas now working with a new Israeli government. After Shimon Peres tried und Farled 10 topple the wily coulition in the spring of 1990, Shamir hud formed a Likud-led government shoru of both Peres and Rabin. Misha Arens was again Minister of Defense, I began preparing: regular, fortnightly reports for him, Dan wd Prime Minister Shamir. Within days of the invasion, | produced my imtial assessment. The hotonline wes that we had 10 assume there would be & war. It was impossible to imagine the Americans would commit hundreds of thousands of troops and simply brmy them hame agam, imless Saddam suceinmbed and retreated. | was equally certain Saddam would use bis Scuds against us. He'd figure the benefits of trying to bring Tsracl into the conflict far outweighed the nisl of retaliation, But | was “nearly 100 pee-cent sure” he wouldn't use chemical warheads, since that would almost guarantee an Israeli military 230 sesponse, or an Ametican one, on an incomparably greater scale. Tt would also totally isolate Saddam internationally and end any chanee of peeling off Araly suppart for the Americans, It was my nearly 1 00-per=cent caveat Thal prompled i nse debate withm the cabinet. Even if the probability of a chemical attack was microscopic, any risk of civilians being subjected to terror, panic and very possibly agonizing death meant that the government had to take precautions. The obvious first step would be 10 distribuue was masks. But in 4 series of mcelings with Misha and Dau, | emphasized this was not a decision thar could be taken in isolation. By handing out ras masks, we might actually mise the prababality of u chemical aftack, We also his 1 mke sure a3 i mater of wzancy that we bad # workable military option to attack Traq’s Seud launchers. By early November, | was dealing both with plans for distributing the gas wuss and preparations Tor a possible imililary aperation. So when 1 got w call asking me 10 report w Shamir's ofTice in Jerusalem, | assumed he wanted to talk about Iraq. “How are things?" he asked. But when I began by filling him in on the plans to distribute the gis-maskes, he internpled me. “Cealled vou eve,” he said. “because | wanted you to know that we've decided that when Dau leaves next April, we want you to replace him as chief-of-staft.” Briefly and unusually tongue-tied, 1 smd: “Thank you, Prime Mimister”. The news was made public the next moming. A few days later, it was ratified by the government, There was only one vote against, fiom a former chief of stalf who was now Shamic’s Agneutture Minister: Raful Eitan, Twas one of ruse instances in all my yess m the my when 1 took a siep back, appreciating a moment which felt special. It was not only, or even mainly, a matter of a personal ambition fulfilled. Mare a sense that [ was being given the opportunity lo apply everything I'd experienced and leaned fn the amy, from the day | first joined Sayeret Matkal as an 18-year-old, to improve the security and safeguard the fiture of Israel. [ know that sounds comy. But, while fhe momentim toward war m Iraq almost immediately crowded ouf everytime else again, that was truly how | fell © oa 231 By mid-December 1990, war was virtually certain. Misha aod [had been to Washington in September and ageeed with the Americans that, unless we were attacked by Saddam, we would stay out of it, To do otherwise was clearly not just again the US-led eoulition’s interests. Given the importance of our alliance with Washington, it was against vue inceresis as well. Yet with hostilities obviously getting closer, Misha phoned Defense Secretary Dick Cheney a few days later to remind him of the guid pro quo: we would be kept fully in the Joop about the dewils and timiog of the initial American air steikes. Ataround five o'clock on the atternoon on January 16. 1991. Misha got a call from Cheney. He said “h-hour” would be at seven that evening Washington time. Three aan. in Lal. Though we hoped to stay out, I'd now spent months coordinating and overseeing preparations to ensure we could attack Saddam’s Scuds if necessary. By far most of the missiles were mounted on mobile launching vehicles, and Saddam was almost certainly going o be Firing them from the vastness of Trag’s western desert. That meant an Israeli air strike alone wouldn't work. We decided on a joint air und ground operation, bill around i newly created ar mobile division and other special units. A force of 500 1o 600 soldiers would take control of key areas and road junctions in western Iraq and start hunting andl destroying, or al least wpedmyg, the Send launchers, We also engaged in seeret diplomacy in the hopes of reducing auc of the obvious risks in such an attack: a conflict with Jordan, which we'd have to overfly to reach Iraq, The Mossad had a unit culled Feved, uw kind of shadow foreign ministy for stales with which we had no formal relations but wilh which. in both side’s interests, we had a channel of backdoor communications. It was headed by Ephraim Halevy. a London-born Israeli who had come to Palestine in 1948 us 1ecner. He hud bull up a personal selitionship with King TTussein, and now accanged for us to meet him al a country residence which the king had in Britain. A few weeks before the war, 1 boarded 2 private jel 0 London along with Uslevy and Prime Minister Shamir. Shamir had never met the king before and not, of course, had I. Buc we didn’t talk about the forthcoming meeting on the five-hour flight. Instead, Shamir opened up m i way 1°d never seen: about his childhood as part of a relatively well-off family in Poland: his love of literature, and of the Bible. In a way, it reminded me of how my father had spoken to me when Iwas growing up minus the “well-off fumily” part 232 When we go to Tlussein’s country home, we were greeted by an impressively self-assured man in his late 208 who, like Hussein, had studied at Britain’s military academy in Sandhurst and then gone on fo Oxtord, Tt was Abdulla, the Langs son sun baer his sneeessor, and he explained that he wonld be in charge of handling sceurity for the talks. lor a few hows ia the afiernoon, we held preliminary discussions, and 1 presented our assessment of the challenges and options facing all the different players in the erisis. Then we setired to a dinner at which — despite the soyal china, crystal and silverware — the atmosphere was alsa surprisingly informal. The main meeting came the next morning. Both sides recognized the seriousness of the issues we had fo discuss. Shamir began with 1he one we assumed would be the least dificult. Tsrael was on & heightened state of militacy alers, prompted by Iraqi reconnaissance lights over Jordan, and the likelihood he Traqis were also haping to get a look at our main nuclear research and development Eacility in the nearby Negev. IL was important 10 ensure this didn’t lead to an unintended contlict between us and the Jordanians. While the king ws careful lo siecr clear oF my detailed comment on the Ini moves, he mide it clear that he understood vue concern about stumbling int an sracli-Jordaian conflict and agreed that we had to avoid doing so et the issue of our overflights, if we needed to atic the Seods, wis more sensitive. We said that iC we did have 10 cross info Jordanian air space, we would find whatever way the king suggested to make it as unoburusive as possible. We raised the possibility of using a mimow wir corridor. His response was mot hostile, but it was fir. | his was au issue of Jordanian sovereignty, he told us. TTe could not, and would not. collaborate in any way with an Tscaeli attack on another Arab scate. It was Ephraim who tried to find a way around the apparent stalemate. He suggested Simi and the king withdraw to speak alone, ad they met for nearly an hou. When Shamir emerged, olasping the kings hand and thanking him for his hospitality. he wurned to us and said: “OK. We're going home.” Ue dido’t tefl us exactly what Hussein said. In the few sentences with which he described the talks on he flight back, he said that, as a sovereign, Tussein could not order his forees to ignore Israeli planes, But he added: “1 assume there will be no war with Jordan” | wok that 1 mean there might well be sm aucmpt to intercept our jets. with the risk that either we or they might end up with one of our planes shot down. but that the king would use bis wuthorty and experience to ensure this didn’t lead tv a wider confrontation. 233 PEE “The srueli public's concem over a possible Iruqi attack was growing by the day, in part because of the precautionary measures we'd taken. We had handed out gas masks to the whole country. Though I'd been concerned that might raise the prospect of a chemical attack, | sill thonghl i chemical stmke was highly unlikely. The government rightly decided that of distributing the masks would betray a fundamental responsibility to the safety of aur citizens. We'd also issued instructions about how to equip a room, usually the shelter included in nearly every lsracli home, as a cheder afm, or “scaled oom” 0 keep gas from getting in. The Israeli media was full of speculation about the likely effects of a chemical attack. Many families had begun panic buying of food and other necessities lo prepare for the possibility of days and nights in their sealed shelters. In my report for Dan, Misha and Shamir a few weeks hefore the war, I drew on syslematic umalysis by a Lean of experts in the Israch air force nd made my most specific estimate yot of the damage conventionally armed Suds might cause. We had gone back into historical accounts of the closest equivalent: the Nas’ use of V1 and V-2 rockets agains! London m the Sceand World War. Given Saddam's primary need to fight Americans, and the likelihood either they or we would take military action against the launchers. we concluded we'd be hit by roughly 40 missiles, and that, based on Britain's wartime experience, up 10 120 Israelis might lose their lives us a result. The first air-raid sirens wailed in Tsrael af about 2 a.m. on Januacy 18. 1991, almost exactly 24 hours after the Americans begaa their bombing raids over Baghdad | wits home im Kochay Yair. Like other Israelis, we'd set up a seated shelter. Though T felt a bit silly doing iL, having assured the goverment Saddam was vanishingly unlikely to use chemical warheads, we woke up the kids and Neva toak them inside. © pit on my own gas mask. Bul when 1 ran out to my car, [removed my mask and put it on the passeoger's seat before heading in to the fir. [ wanted to get there quickly enough so that the bor, the underground command bunker, wouldn't have to reapened when | arrived. [ took a short-cut, through the West Bank ww of Qalyilya. | hat wes, tw put it mildly, swpid Although the inifaada had become steadily less intense during the build-up to the war, 1 was’ completely over, Within seconds, my black sedan wirs being 234 pelted with stones by a half-dozen Palestinian youths. T thought to myselF: this is nuts. One of Saddam's Scuds might well be about to hit Iscac), and I've got myself stuck in ae middle of a West Bank town. Ta the obviaus shock of the Palestinians, | floored the accelerator and raced toward Tel Aviv. 1 sill tok half-a0-hour. Misha and Dan, who lived eloser to the Afri, were alseady in the buaker. Ten Seuds hit near Tel Aviv and Haifa that night, (¢ was nat until shortly before dawn that our tracker units got back 10 us with Rormal confirmation that there had been no chemical warheads. The rockers caused a half-dozen injuries. though thankfully none was serous. Still, the very fet Saddam had proven he could hit seal with ballistic missiles provoked widespread alam. Well ina the next morning, the streets were almost empty. Misha phoned Cheney and strongly implied we were going to hve to attack the Scud sites. { know that was Misha's awa view, and it only hardened after another fouc missiles hit the Tel Aviv area the next moring. Again, 10 oc was killed, but several dozen people were injured from debris, shards of plass and blast concussion. 1 visited several af the mes tht had heen hit amd was shocked by the seake of the damage. One four-story apactment building had been virtually destroyed, and thers was blast damage to other buildings hundreds of yards away. “The Americans were clearly determined, m both word ind deed, to persuade us not to take military action. They rushed an anti-missile system called Patriot 10 Tsrael. Cheney was also giving us frequent updates on American air sikes against suspected Seud kumeh sites. And the Israel public did seem to urasp the serious implications for the US-led conlition of our teking unilateral miliary action. Opinion polls suggested most Iscaclis wese giving Shamir eredit for the way he was handling the crisis. Sill, it wasn’t casy for Shamir to hold the ne. Ths was the first Hime since 1948 that enemy munitions had landed ou sracli homes, provoking not just fear, but a feeling of helplessness. That inevitably led to calls for the army and fhe wovermment to do something, si bis dilemma first-hand al an emergency cahinel meeting afer the fist two Seud attacks. or Arik and Raful, the political effects on the US coalition were irrelevant. The issue. for them. was simple: smack erties had been attacked, and we should respond with amy and all force necessary. Our air force commander, vib Ben-Nun, favored going shed with the joint and-and-ground atack we'd prepared. and Misha agreed with him. So did Dan Shomran, The key voices of caution were Foreign Mimster David Levy: Ariye Deri, the leader of the Sephardi Orthodox party Shas; and two 235 young Likud politicians, Dan Meridor and hud Ole, with whom [had become (ciendly. They. like me, were concerned about undermining the Americans” military and diplomatic coulition. Shami mostly listened, until very near the end. He then asked an Meridor, Misha and me to join him in a separate room. Ile asked each vf us for our views, Misha, even more strongly then in front of the full cabinet, argued that we could not allow night after might of missile attacks withaut responding Meridor reiterated his opposition. siiessing the damage we'd risk doing 10 the Americans’ war effort by possibly weakening Arab support for their attack on Saddam, When Shamir tumed to me, 1 said that if the government did decide on military uction, we were ready. From a purely military and sceuily poi-of= view, [ said, an auack made absolute sense. Even if we dido’L succeed in destroying, or even finding, the mobile lameh sites, putting a military farce on ihe ground would almost surely lead Lo a dramatic reduction in the number of Scud launches. But, echoing Meridor, T added thal a military response would carry a price in our relationship with the Americans. My view was that, at least for now, we should hokd off. When we rejoined the meeting. Shamir rapped his hand ou the table. fn the startled silence that followed. he said he shared many ministers’ urge to hit back against the Sends. But he said: “Az ths stage, we're not going to da anything, We bite our lips and wait.” Three nights later. bis resolve was strewched almost to breaking point Missiles landed in the Tel Aviv suburb of Ramar Gan, and nearly 40 homes were damsged. A three-story house was fattened tn all, nearly 100 peopke were injured, and three elderly residents died of heart attacks. On the night of January 25, another seven Scuds hit. Nearly 150 apartments were badly damaged. and a S1ayeur-old mim was lalled. The pressure on Shamir was all fhe greater because the Ramat Gan auack had come within range of one of the American’ Patriot batteries. The Patriots had been originally designed not as anti-missile weapons, but fo utnck sirerafl, and they seemed fo have been incfietive, Nor were American air strikes in lag stopping the Suds. Though American jets had taken out a few fixed launch sites. they were having no luck with finding and destroying mobile lunch vehicles, Even Shianiv now fel. that unless the Americans got the mobile kunchers, we would have to attack military action. 1 was sent to Washington along with Mists and David Ive, former ar force conmnder, 16 defiver that message to {he Bush administration. From the fist days afer Saddam's attack on Kuwait, 236 T'd been impressed by Presideat Bush's political acumen in assembling an international coalition including the key Arab states. Through Unit 8200 in military intelligence, we would only very occasionally get verbatim transcripts. af his conversations as hi brought first The Saudis and other Gull states on board, then Morocco, and eventually even Syria. More often, I'd sec the President's deft diplomacy second-hand. through intercepts of Arab leaders communications with one another. Bul the picture which emerged was of an American president defily able 1 stake out common ground. and common interests, with each of the Americans growing number of anti-Saddam allies, When we entered the Oval Oftice on the evening of February 11, Bush was Dianlend by Sceretary of State Baker, Delense Sceretary Cheney and rational security adviser Brent Scowerofl. Also there was Colin Powell, a general whom had got to knaw well, and to like, aver the past few years and who was now head of the joint chiel3-0f-s(aff. Given the seriousness of our mission, the start of the meeting was almost suceal. The Americans had obviously been told that Iwas bom on February 12. Since it was just past midnight in Israel, they began by washing me i happy 49 birthday Yet pleasing thought that was, it became clear there was a disconncet between the tension among Israeli govemment ministers. and ordinary Israelis, buck home and the refixed, self-assured, at times even jovial mood of fhe President and his inner circle. Their primary focus was clearly nou on Iseael, but on the overwhelming success of their air attacks on Trag and the approach of a ground offensive that they were confident would finish the job. That didn’t seem fo elinge even aficr i Iruly extraordinary infemption fo our meeting, when one of Misha's aides passed on the news that a Seud had struck the Tel Aviv suburb of Savyon, where Misha himself lived. Ie immediately excused himself und went 10 phone bis wale, Muriel, 10 confirm she was fine. When he setuned. despite theic pro forma words of empathy, it seemed almost as if the Americans thought we had cooked up the entire thing for political effect. Bush did say the right things us the discassion timed to the missile attacks on lsracl. He told us he understood ew frustration, and the pain the Scud launches were inflicting. Tle appreciated our restraint. T have no doubt that all of thst was true, But the message we'd been sent fo deliver clearly wasn't hitting home. As politely bul as clearly as 1 could, 1 told President Bush that while we didn’t want to do anything to undermine the coalition, unless someone else took care of the Scuds, we would have no choice but fo act. 237 The President cesponded by suggesting we 20 to the Pentagon and talk in greater detail about how, for both vue counties’ benefit, thal could be avoided When we convened in Secretary Cheney's office, 1 delivered the same message, but more forcefully. 1 ell it was essential nol only lo make il clear we sions about taking action, but that we iad the militacy capability 1o do so. So 1 10ld Secretary Cheney and Colin what we were planning. I said we intended to launch a combined air and ground assault by an air-mobile force and our best paraicoop units. Al that point, Colin, who was clearly worried, suggested the two of us withdraw to speak “soldier to soldier.” We retreated to his office. Spreading out a map of western Iraq, 1 went into greater detail, explaining how wee would remain in the Iraqi desert on a scarch-and-destroy mission against the mobile launchers. Colin stressed the efforts the Americans were making from the air. and the commitment they'd shown to Israel. Not only had they delivered he Parions. They had allocated their best fighter jets. F-1SE's, 10 the task of taking out the Scuds. Tt helped that he and Thad got tw know and respect each other, so it wasn't an all-out argument, But [ reiterated that if the Seud attacks kept up. we wauld have to act, “We will ast,” | said, For a few seconds, he said nothing. But as we headed back 10 join the others, he wld me that only a few hours a0, he had briefed American commanders on an anti-Scud operation by “allied forces” like the ane we were planning, “(twill happen,” he assured me. “Within 48 hows.” Tha task fell to Britain's SAS. The operation was almost exactly the same as the one we'd planned. A force of nearly 700 commandos was helicoptered in to Irag’s astern desert, equipped with Jeeps and Land Rovers, and anti-tank missiles and laser targeting capability. They were also able to call on attack helicopters and F-15 jets if necessary. The operation did not prove easy, quick, or entirely successful. The British troops blocked the niin roads and patvolied them. But they did not find or destroy a single mobile launcher. They ended up in pun bateles with Iraqi troops. The SAS lost something like two dozen men. Five were part of a group that got separated from the others and ended up freezing to death in the Februzuy cold. All of the men risked their lives. with incredible determination and bravery. in an operation to secure the safety of Israels civilian population. And | have no doub that fhe outcome, like the plan, would have: hea almost identical if we hind done it owseves. And it did have an effect. As T'd told Prime Minister Shamir when briefing him on our attack plan, the very fact of a military presence on the ground made dramatic difference, The number, seeuracy and impact of the Sends dropped off steeply. A few missiles kept coming, however. Since we did not yet have a 238 fully detailed pietuce of the progress of the SAS action, skeptics aod hawks in the cabinet were inclined w see a glass hal f-emply. They continued to press for Israeli military action, In a rare public statement, I tried to reassure the country we did have a military vption. bul also to urge restraint. | pointed out that the number of Seuds had begun decreasing. Though the threat had not been ¢liminated altogether, we hid “very good operational plans” that would be “eanricd out when and if the Lsracli government insituets us to implement them.” Yet | added a caveat, “On the political level. fingers are itching to carry out operations which, in our opinion, ean remove fhe threat, But in the complex situation created by this war, neither anger, hurt, nov itchy fingers can replace rational thinking.” The American ground invasion did tw out 1 be swift and decisive. In Israel, Scud artacks continued for a few mare days. But the last two missiles fell in the Negev before dwn on Febuary 25. among the very few to canse neither casualties nor damage. We turned out o have heen right in vur pre-war assessment abour the number of missiles: around 40. Fortunately, the casualties were far fewer than we'd anticipated. Not 120 dead, but fificen, only one of whom died directly beeause of a missile blast. The other deaths were the result of understandable panic: the misuse of as masks or the gas antidote drug, atropine, ot from respiratory and cardiae filure. The physical damage, however, was fur greater than I'd anticipated. Buildings were destioyed. Cars were crushed. Glass and debris (lew everywhere. In financial terms, the cost jan to hundreds of millions of dollars. The frue impact was greater; on families who saw the destruction non only their homes, but a lifetime of prized possessions. Tor Tolocaust sucvivors in particular, there was the almost unimaginable Leeror of having to huddle in sealed rooms for fear of pas. And all Israelis had experienced wniew sense of valnerabilily 10 i faraway enemy whom they couldn't see nor, apparently, stop. PE Twas due to become Israel's 11™ chief-of-staff at the start of April, barely a month after the lust Scud attack, As the handover drew nearer, 1 felt forfunite, ina way, 10 have missed out on the job four years earlier. Not only had Dan excelled as ramati. 1'd benefited from his range of experience. his judgment, und bis trust as well. We he worked together iruly as # lam, 239 Twas grateful not only to Shamir for naming me chisf-ol-staff, but lo Rabin and Misha. Both had honored the assurance Yitzhak had given me that I'd be Dan's successor. | also discovered Misha had played in even greater role than Ueissumed. | knew there wold be other candiceaies for the job. The strongest turned out lo be Yossi Peled, who was the head of the northera command and possessed the undoubted credentials to be an excellent chief-of staff. What I liadn’L heen aware of was Lhe sentiment among some in the Likud that [was the wrong choice politically. Not only liad been boen on a Labor kibbutz. There was the small matter of the article in Hadasho! several years earlier, imagining me as a Labor leader poing: head-to-head in a future election against Bibi Netanyahu for the Likud. Yossi was assumed 10 be more of a Likudnik, and a (ew weeks before Dan left office, 1 leamed how Mish had rebutted the suggestion 1 was politically unfit o lead the armed Goees. Tle was visiting the north and was Laken aside by 2 pcoup of Likud activists who asked how he could possibly be thinkiog of supporting Burak — a Labor puy — for chief-of-staff. Ac first, Misha didn’t reply. Bul one woman kepl pressing him “Do you have children in the army?” he asked. “Yes. 1 have a son in the Golani Brigade,” she replied proudly. “$0 Tet's assume your son is goin on a raid across the border. Would you went his company to be led by the hest commander in the baualion? Or by a commander who's Likud?” “The best commander, of course.” she said. “To which Misha said: “Well we do, two.” 240 Chapter Fifteen On the morning of April 1, 1991. [ gol up even earlier than usual, Lo visit the graves of the men who had Jost their lives in my battalion in the Yom Kippur ‘War. [ also went to pay my respects to Uzi Yairi, killed when he'd rushed from his desk in the kinva 10 Join the Sayerct Matkal attack af the Savoy Hotel. Then Nava and | drove 10 Jerusalem. AC lsracl’s national military cemetery ua Mount Herzl, we stood betore the resting place of Nechemia Cohen, Yoni Netanyahu, Dado, and Avraham Aman, From there, we went to the Prime Minister's office, With Dan Shomron and his wife looking on, Shams preseried se with my third star and formally made me chief of staff. For years, 1°d develaped the habit of carrying around 4 notehook in which Fel joi down thonghts on things 1 thought tht the Grae] military, and © as in officer. could have done better: errors, oversights. and how we might fix them. In the weeks before becoming rusmetial, 1d tilled dozens of pages an issues Hinge amd smal {hoped to address as the commander of the med forces. A lot al them dealt with what | sensed was an crosion of cohesiveness in the army. and, since ours was a citizen military, a fraying of the relationship between the army and Issacli society. Ta some degree, this was inevitable in a comniry now nearly 45 years old: developed economically and free of the Lind of existential threat we'd faced in the early years of the state. But the political divisions over the war in ©ebanon, and morale-sapping need ta quell the violence on the West Bank and in Giza had further strained our wity of purpose. Militasily, we wee now indisputably strong enough to defeat aay of the Arab armies, even if they kamehed a joint attacle as in 1973, Our most impartant overseas ally, the Uniled States, was connmiled 10 helping us retain that position — what both we and they called [racl’s “qualitative edge” - in the interest of our security and their own, Buf we were facing a series of new, unconventional chillenges. One of them, which had come on 10 Dan Shomron’s and my radar over the past year. was ian. Though geographically distant, it was potentially the most serious in the longer run, as Dan himself warned [sraelis in his fimal interview as chief of stall. Iran was likely to becom even more assertive regionally now that the Gull War had weakened ifs nicighbor and vival, Iraq. We also knew, from our intelligence sources, that the Tranians were muking preliminary efforts fo develop a nuclear weapon, 241 Yet the most immediate security concerns were right next door. Tn Lebanon, izhollah fighters were being armed and financed by the leanians and by Syria as well, They were mounting increasingly effective operations against the Lane troops wed left nthe scenrity zone. Fven closer To home, Palestinia attacks on both troups and civilians. though on nowhere neac the scale of the fist months of the fntifids, showed no sign of ending. T had my ow views on bah. In Lebanon, sill believed we should pull out all our troops and Focus our sceurity arrangements va what ceally mattered: protecting the citizens of northem Israel. As for the lessons to be leaned fram the intifada, my view that we needed a political dialogue had inadvertently become public, from remarks | made in Moshe Dayan’s honor at 8 memorial event a few months before becoming chief of staff. “We are curently in a struggle with the Palestinians - a Tong, bitter and continuing struggle,” I said. “A people cannot choose its neighbors. But ve will live w talk 10 the Palestinians abou matters, especially about issues that are vital to them.” Still, Iwas the commander of the armed forces. not a politician. Though all hifi of staff had political mfluence, if only ts part of the decision-nalans process on all major sceuwity questions, making policy was for our elected government. My main focus was on how to improve the military's fitness to respond. 0d lived through, and more recently fought in, all of frac’ wars. | felt that we had yet 1 apply some of the editical lessons from those conflicts. Leading tanks into battle against the Egyptians deadly Sagger missiles in 1973, and a decade later watching whole Israeli armored columns stalled and attacked by small bands of PLO fighters or Syrian conuandos in Lebanon, had hardened my conviction that Israel needed a leaner. mote mobile army, with more specialised strike units, as well as more easily targeted, less vulnerable weapons systems. Lywimted to shift the emphists to weaponry that relied on Iseacl’s strengths in new technology, invention and engineering. Tn a sense, this was the macroscopic equivalent of one of the puiding principles of Sayeret Markal: brains, no just brawn, While cost-saving wasn't he catalyst, [ did realize that a change in stialegy would mean a change in how we allocated our resources. When Istael bought its first Mirage ets from France in the 1960s, they cost about u million dollars apiece. he price tag of an 1-16 was now closer to fifi million dollars. The cost of a tank liad increased tenfold. I wasn't going to deprive the air force of state- of-the-art aircraft, key to our ability to fight and win a war. But while we still needed i strong armored carps, it was important To reahiz: that units hike the 242 new aie mobile division we'd planned to use against Saddam's Soud launchers were likely to be a Jol more important than tak formations in future conflicts. Six days into the job, [ called together every officer in the army, from the rank of ficutemant-colonel up. sid we needed 10 remind ourselves of the army's purpose: 10 proteet Israel's sceurity and, ifs war came, lo win it. My budgetary rule of thumb over the next four years would be simple: anything that didn’t direetly contribute to tht mission was expendable, In fact, 1 put it a bit more bluntly: “We need to cut anything that doesn’t shool.” My first attempt failed uterly. I proposed to close, or sell off, the army's radia station, Galed Tzahal, Running it cost serious money. If we were going to cul everything tht dient shou, it was an obvious cindidite. Bat what 1 failed to take into account was its popularity with the listening public. Although other radia stations had opened recently, for many years it had been the only major altemative lo the stite-fimded Kol Yisnsel. [t also provided a Insining ground and employment feeder for futuce journalists. Gale Tzahal’s alumi included some of the country’s top media figures, and more han a few members of the Kessel. Within weeks. a lobbying effort was underway 10 “save” the station. { went lo sce Misha. He agreed that, from a military and budgetary standpoint. closing: it was the right thing to do. Bur in an early lesson in how different polities were from fhe sammy, he fold me tht pofisicadly, it simply wasn’t going To ly. “Drop it, Ehud” he said. So 1 did Sul, T did end up fuadamentally retooling the armed forces during my lime as chief of staff, We developed agile new strike forces and high-precision, high- toch weapons sysiems with “stand-ofT” suitions designed 1 he fired from many miles away. In the 1973 war. and for the decade or two that followed, Saggers, and the US-made TOW missiles that Israel acquired after the war, had the capbility lo transform a battlefield. Now, Israeli developers came up wilh small, ground-launchied missiles that could take out & tank from five 1o 10 miles away, even without a direct line of sight to the farget. Of even more long-term military significance, | pushed head with developing pilotless drones so- called UAVs — making us the first army in the workd to produce and deploy them. Yel for a security challenge like the intifada, even the most advanced stund- aff mmitions or LAY offered no practical answer, The bates stage iv the wiolence involved knife attacks by Palestinians against Israeli civilians. both an West Bale seth and inside [smcl. Days afler | took over, i 26-year-old from Gaza, wielding a butcher's knife and shoutiog Alef Akhbar, killed four people, 243 including a Nindesgarten teacher. in Jerusalem. On the moraing of May 24, 1992, a |5-year-old Tseacli schoolgirl named Tlelena Rapp was on her way lo catch the bus ta school south of Tel Aviv, when anofher Gaz stabbed her to death. To the extent Talis were lookisg for someone to ble, there woe abvious candidates. The amy. the primary defense against Lhe intifada, was one. The police even more so, since many of the attacks were now taking place inside Israel. And in ugly rioting afer Helena Rapp’s murder, bands of Israclis took to the streets, some of them yelling: “Death to the Arabs. Still, most people understood that criticizing the army or the police, or going: on a rampage against “the Arabs” hundreds of thousands of whom were Israeli citizens and had lived among us since the birth of the state — would not help. Mos, in fact, placed the blame, and lodged their hopes. with the goverment. By the time of the next election, in June 1992. the combination of Palestinian viokace and the still-tumatic memories of Saddam's Seuds, left Tscaelis doubuful that Shamir could fulfil the most basic responsibility of goverament: ensuring their day-to-day security. Labor had once again placed its electoral fortuncs in the hands of Yi Rubin, following Peres’s several failed attempis 1 lead the pacty back into power. Knowing that Rabin had a recoed of military command unmatched in Istaeli politics, Labor strategists did not so much need lo convince voters as to reinforce their fears wd Frustrations. One of the campaign slogans. a direct appeal 10 the anger over the stabbing of Uelena Rapp, was “Get Gaza out of Tel Aviv!” Labor ended up gaining five Knesset seats, and now had 44. The Likud Tost eight and was left with only 32. That ment that my bast three years as chief of laff sould be with Rabin back as Prime Minister — and. like Bea-Gurion before him, as Defease Minister as well. He and 1 had been in touch only occasionally since his departure from he turity-coalition government two yeas carfier. Bul | had. of couse, spoken with hin after my appointment as ramaskal, in which he'd played an imporiant pare. Though he was 20 years older thon me. our relationship had become steadily closer over the yes, especially when 1° worked wits him is Defense Minister. In some ways, we were alike. We'd both been forged by Labor Zionism. We were career military officers, uncomforcable with flights of political rhetoric and convinced that Israel's security and its future depended Tess on ywords than on action. In large groups especially, both of us tended 10 be men of a few words. Over the next few years. we would become even closer, spealcing not only in the ya or at Yitzhak's office in Jerusalem. but also, with Nava und .cah, aronnd the dimmer table at Rabm’s apartment m Tel Aviv. 244 HOUSE_OVERSIGHT_011715. PEE But there were times of crisis. and high tension, us well, Only tive months aller the election. Rabin and 1 Faced onc of the most painful periods during my entire time as chief of staff. It began with the gruesome death of five Sayeret Matkal soldiers during a framing exercise in the Negey desert, 1d made preventing such accidents a Lp priority. By the end of the 1980s, they were claiming as many as RO lives a year. During Dan’s tenure, we'd brought fhe number down to about 35. But 1 knew we had to do more, When 1'd addressed the oflicers aller becoming elie of sta, [old them: “Parents are giving us their children in order to allow us to protect the country. They know there is risk involved. But they expect their children not to be brought home in coffins because of our own negligence, or stupidity.” What happened at the military base of Tze’elim in the Negev on November 5. 1992 was not only a reminder of how far we still hud ta 50, however, It occurred during «dry rum for an operation unlike any that (sacl had ever considered, For that and ather resans, it would exupt ini a major political controversy. Though the reason for the exercise was meant to have remained a closely guarded scerel, Corenm newspaper reports in he weeks afler the faimmyz accident made seercey impossible. We wore planning to infilicale a Sayoret Matkal unit into Iraq. and to kill Saddam Ihussein. The Gulf War had blunted any immediate threat from Iraq. But Saddam liad proven he could launch missiles into the heart of Israel. We knew from our intelligence reports that, in addition to his unabated desice to acquice nuclear arms. he retained facilities to produce chemical weapons. [le was frying to uequire und develop new biological weapons. In fact, the [ragis had actually acknowledged a biological weapons progeam 1 UN inspectors. claiming it was for “defensive purposes.” The idea for un attack on Saddim had first been raised a year cadier, when my former Sayeret Matkal comrade, Amicam Levin, asked w see me. He was between military postings, but had come up with the outline of a plan he felt would allow us to isolate Saddam during a public appearance and kill him, With my approval, he andl a small group of oflicers in the sayeret began working further on the idea, with the initial aim of seeing whether it was really workable. Since Misha wees till Defense Minister, | briefed him on whit we were doiug. | 245 also briefed Rabin afier the election. At that stage, there was no discussion of whether we actually would, of should, Lacget Saddam. [asked Misha, and then Yitzhak, only whether such an operation might seriously be cansidered by the sovenment. 1M, 1 sid, we'd drop it. Both replied that we should go ahead with the planning and preparation. The November 1992 excreise was intended as a final test of its viability — before deciding whether actually to do it A few weeks carficr, Rabm and | hud talked through the arguments for and against. The arguments agaist if were obvious. Yes, in the past we had abducted. or even killed, leaders of groups involved in terror attacks. But we'd never contenmplated targeting u head of stite, Crossing that line risked bemy sent nol just as sacking a dictator with 1 record of vthlessness ind murder at home, and aggression towards Tseael. but long-aceepted norms of interaational relations. The arguments in favour begun with the fact that Saddam was a meglomaniacally ambitious dictator. Tle had also fired missiles on our towns and cities. Tle retained the capability Lo arm them with chemical wacheads, possibly biological agents, and conceivably a nuclear warhead in the future. Both Rubin and agreed there were two key tests of whether an attack would be justified: was it was the only realistic way of confronting the threat from rag, and would killing him end, or at least exponentially reduce, that threat. “Though there was na final decision at our mectme, Rabin was elearly inclined to go ahead. An lseacli TV program two decades later uncathed a summary of the discussion, written by his military aide. “The Prime Minister approves the target... This is an operation we should go for when the probability al siceoss is very high” it said. hus, we have to build the operational capability in the best possible way, and continue preparations.” In another par. of the record, Rabin is quoted as having defined the elimination of Saddam as a “meaningful objective” with implications for “the very scenrity of lsmiel.” He added: T do not see anyone similar 10 him in the Arab world” 1, too, was on balance persuaded we should do ic. In the years since, I've sometime reflected on whit happened with Saddam still in place: the 2003 invasion of trad. led by the younger President Bush, the tens of thousands of lives lost. the willions of dollars spent on a war without any clear end. and the near-disintegrition of Iraq. But with the complexities of Iraq then md now, there can be no simple answer 10 how the situation would have changed if we'd Killed Saddam. Our view. based on detailed intelligence analyses, was that the Hikely result would have been a fairly rapid fikeover by a few top security and Baath Party (igures and that, while the new Iraqi leadership might ry to cetaliaie 246 with terror attacks. a major military response was highly unlikely. Saddam's Sucoessurs were never poing 10 be Zionists. Bul we were persuaded that his uniquely central Tole meant the threat to Israel would be dramatically reduced. Frmmueh less sure whether the elder President. Bush, whose election deft 10 Bill Clintwn came just two days before our (inal exercise in the Negev, would have agreed with the attack. After the victory in the Gulf War, Bush had deliberately stopped short of sending American forces on to Baghdad. He was also vice-president, under Reagan, when Israel had bombed Saddam?’s nuclear reactor an attack publicly condemned by Washington. I did ask him some years ugo whether the Gulf War might hive been handled differently if sme! hadnt iken owt Suddam’s nuclear progr a decade earlier. “What if he'd bad & couple of crude nuclear devices,” T said. President Bush smiled in response. He said he didn’t deal with “hypothetical,” Yet amy idea of an [srscli atack on Saddam became mstanily inselevint once foreign media reports liad disclosed the reason for our ill-fated military exercise in the Negev, Inside Israel, the tacus, and the controversy, shifted to the acerdent itself The foreign medi eports of the opertion we were planning proved remarkably accurate. Some of the details still remain classified, bur we were going to use one of our new “stand-off” weapons systems: a camera-tuided missile thi could be fired from a considerable distance away und, in coordination with one of the Sayeret Matkal soldiers nearer in. maneuvered in for the strike. After months af planning and intelligence worl, we were conficlent that we'd Cound a wy 10 get the ssyeret unit nto lag, large! Saddam at an event we knew he would be attending, isolate and kill him with minimal danger of any other casualties, and get our unit out safely again, The Negev excrvise wis i run-through of the entire apeaation. 1 sted needy 48 hours. And it culminated in a simulation of the missile attack on Saddani. Iwas there as an observer along with Amnon Lipkin. my deputy chief-of- staff; as well us the hend of military mielfigence, the head of aperations and Amicam Levin. We assembled at dawn for the simulation of the missile atack. We watched from a few hundred yards away as a group of young Israeli soldiers walked inta a wide area in front of us: posing as Saddam” and his entourage. We — and they — knew that his was just the frst pn of the exercise. In a Land Rover more than five miles away. a member of the sayerer strike unic would be confirming coordinaics und, in rapid succession, “Firing” Iwo of ihe precision missiles. But this was just lo confirm that the targeting system had worked 247 perfectly. No missiles would actually be shot. This stage was for the telemetry Once that was done, the soldier-actors would be replaced with wooden Largets and the real munitions would be tested. The young soldiers skied chatting to one another, and milling abonl, simulating as best we eould the cireumstances in which we expected target Saddam if the operation got final approval. [n theory, within a minute, two minutes #t most, we would get ward that the prelminary mock-firmg sequence hud gouge perfietly — al which point the arillery-range targets would be brought in for the live test. But suddenly, there was an explosion. A split second of silence, Then pandemanium, There was na need to know, and no me to wonder, what exictly had gone wrong, ov how il had been allowed to happen. 11 was obvious tv all of us that the five missiles had been fired. We sprinted forward, When we got tw the group of soldiers, we could see that four of the young men were dead. Another was fighting for his life. Several others were also wounded. A sayeret medic and several senior officers were trying to save the most bracly: jure man, but [knew [needed to get militiry doctors nd medical evacuation helicopters in immediately if we were 10 save the lives of the injured soldiers. 1 had a mobile phone, but couldn’ ret a signal. [ ran toward a slightly higher area « few dozen yards way and mamiged to get through to the kina, 1 issued orders for the neavhy training base in Tze"clim and an air force near Beersheva to dispatch helicopters to treat and evacuate the wounded. We heard the first chopper about 25 minutes later, but it seemed initially wible to see us, because it Oew on before retummye and nding two mnites later. By that time. a medical team from the base in Tze'elin had arrived. Ten minutes later, twa other medevac choppers landed. But the soldier who had heen worst wounded conkl not be saved. Afier the doctors had been there abou 20 minutes. | again retreated to the area where | could pet a mobile signal, aud phoned Rabin ta tell him what had happened. We agreed | should come back to bref lim in detsil, 10 was now about SO minis since the missiles hud ht, The wounded were all being treated. Oue of the helicopters had taken of? for DBeersheva ITospital. Another two, including a heavier Sikorsky transport helicopter, were preparing ta leave, 1 iranized for Amnon, military intelligence chief Shmuel Avad and me lo ret w the kirve. 1 whi Amivan lo stay unil he had confirmed all the injured had been evacuated, and talk to everyone involved 10 get a prefiminary wea of why and how the tragedy had happened. 248 When T got back, we immediately met with Rabin and agreed on the need to launch a formal investigation. Rabin then asked me to brief the “editors club”, a group of about 15 media figures that operated on a gentleman’s agreement that there would be no publicity or kesks. He believed we should nou mike public the [act that [and other generals were there when the accident occurred. At this stage, we still hoped to hide the purpose of the exercise if possible. something Rabin kanes would be harder iit was kaowa the top military leadership had abserved the excreise. When I bricted the editors” elub, 1 did tell them in confidence that I'd been there. Though not specifying the reason for the exercise, 1 told them it was for a major operation. The time-honored understanding was hat this information would go uo further. But it did, presumably at first because of leaks by Israeli journalists. then in a series of detailed reports in the foreign press. Even more frustrating on a personal level, some of the Iscacli reports insinuated that far Geom giving the editors the fll story of who had been at the Negev exercise. that I'd tried 0 hide my presence in order to protect my reputation or shirk responsibility. Twa official inquiries followed: the one we'd agreed with Rabin and a standard army legal investigation. They found the cause of the tragedy to be a mix of fatigue after some of tae soldiers had spent nearly 48 hours awake, pressure, confusion and negligence. Astonishingly, if timed out the codeword for the mock-(iting of the missiles in the fist stage of Lhe exercise was the same as for he live missiles. Formal charges were brought against two Sayers Matkal officers, and reprimands issued to Amiram Levin and Uri Saguy. I was also subjeet 10 eriticisn because, duc to the unique complexity of the plan, I'd put Amiram and senior officers within Sayeret Matkal in charge of different aspects of the preparations. This was viewed as possibly reducing the clarity over wha was ultimately responsible for cach wspeet of the planning. Neither 1, nor of course Rabin, had played a ditect role in what went wrong in the exercise irself. To the extent I'd been involved, it was to make sure the medical teams were helicoptered in, and thit the injured soldiers were cared for and evacuated as soon as possible. But politically, the tragedy at Tze’elim would dramatically resurface for both me and Rabin several years later - after I'd left the military and was on the verge of jominie his goverment, [was petting 1o know Yitzuk mich betler. The Defense Minister's office in the Airy was just down the hall from mine. Almost without fail on Friday aftemoons, he'd ask me in to chat before going home. We would sit around a Tow table in the comer of the room, cach of us sipping coffee. or sometimes ‘beer, and Rabin invariably putting on a cigarefre. He never raised questions of 249 pany politics. But we talked at length about Israel's immediate sceurity concerns, as well as the country's longer-term challenges in finding its place in more stable, peaceful Middle Fast. How, over time, we might manage to exineste oumselves (rom the escalating viokanee with Hizbollsh: reach a land- for-peace deal with the enigmatic President Tale al-Assad in Sysia: and find some form of coexistence with the Palestinians He also spoke ubout international politics. [ remember ane afiemoon in the summer of 1992 when he mentioned the then US presidential candidate Bill Clinton. He'd met Clinton for the first time in Washington. after two days of full with President Bush at his summer home in Maine. Rabin was naturlly more combontable dealing with Republicans. Almost all bis experience in public life — as a military officer, ambassador to Washington, Defense Minister and Prime Minister had coincided with Republican administrations, The irony was that be would go on to forge a much closer relationship with President Clinton than between any previous Israeli and US leader. But bis first impression was more skepical. “Clearly. Clinton is very intelligent,” he said. “Ile is surprisingly stunp politically for someone Ins age. But also, [ Gear, i hille bit foo slick.™ «ore We did not have long w focus on the lessons and implications of Tze"elin. For weeks before the training accident, a crisis had been building in south Lebanon, with a sharp escalation of the now-familiar mix of clashes mside our “security zone” and cross-border rocket attacks. TTizbollah was now armed oot ust with Katyushas but Sagpers, American-made TOW anti-tank missiles and un mereasingly sophisticaied any of roadside bombs. A combination of Tlizhollah auacks and “feiendly fire” incidents or firearms accidents involving our troops meant that Israelis were still dying in Lebanon a decade after the formal end of the war. [L was demoralizmg for the [smack public, for the soldiers who we rotated into the security zone and for he government as well. The difficulty was that it was also a situation that perfectly suited [lizbollah. In Tate October, a Karyusha rocket had claimed the life of a 14-year-old bay in the northern [sracli lown of Kiryat Shoo. Hizbolleh escalated iis rocket fire in the days that followed. forcing tens of thousands of residents into their shellcrs. Predictably. there was pressure fromm Liked politicians to hit back hard 250 Raful Litan, who had founded a small right-wing party called Tsomet, went further. Te called the attacks “an act of war™ and said we should “respond in kind.” We did move troops and tanks to the border, Rut my view, which Rabin shared, was tat a ragjor ground operation would risk wiring onrselves more deeply without fundamentally improving the situation. izbollah was the kind of nonconventional enemy I had in mind when I'd taken stock of Israel's changing seewity imperatives on becoming ehiel of staff. 1 was a small force, entrenched and well armed, increasingly supported by lean and Syia. Its tactics Tested on quick-hit attacks on our soldiers in south Lebanon, Far from tearing military retaliation, Hizbollah knew that short of a 1982-scale war and maybe even then — it would survive. [Lalso didu’L care whether Lebanese civilians died in the crosstire. In fact, like the PLO fighters who had controlled the area before 1982, Hizbollah deliberately fired into Israel from civilian areas. Neither Rabin nor I had abandoned the idea of a large-scale military operation at some point, pasticulacly if the cross-border socket fise didn't subside, which for a while it did. But we were determined that, if and when we did decide 10 strike, we would avoid uny thing on the sealc of the 1982 war. would have to be with a elear, finite and achievable goal. That point finally arrived in the summer of 1993. [n addition to renewed Katvusha strikes, there was a series of deadly Hizbollab attacks m the first two weeks of July inside the sceurily zone. Each used what was becoming the tactic of choice: a remotely detonated bomb by the side of the road on which our military vehicles were travelling, followed by an ambush of soldiers who survived the blast. Six Israelis had been killed im all, making i the largest monthly toll in three years. When T went 10 see Rabin with ow plan for a ‘military response, 1 recognized the risks. It would be {he largest military operation in Lebanon smee the war. Bil | believed we could limit cavilian casualties, and that it was the only approach that might lead to a significant reduction in the missile attacks on norchem Israel. I began with the assumption thigt, fell to 11s own devices, Hizbollsh would bave no incentive 10 stop fing, Since the two Arab governments with the potential to rein in the attacks — Lebanon's and above all Syria's — were showing no interest in doing so, we had to find a way to hold them to account. “The operation | proposed was intended 10 send u message to Beir and Damascus. It would not be a ground invasion as in 1982. Most of the auacks would be from the ar, in two stages. The first would target Hizbullah, both in southern Lebanon and in the Bekaa Valley further north, near the border with 251 Sytia. We could halt al that stage, in the unlikely event Ilizbollah showed signs af de-escalation. But if it didn’t the air sicikes would intensify. The aim was not target the nearly 250.000 |ebanese civilians who lived in the immediate border wee Twas 10 use our ailacks, along: with leaflet drops and radio messages, To encourage then o flee north. My assessment was that this would bring pressure on the Lebanese government and. through the Lebanese, on the real power in Lebaaou, the Syrians. | doubled Damaseus would respond dircely by telling Uizhollal to cease fire. 1 did believe they'd be ready to cugage with American efforts to stop the fighting, and that Rabin and the government could then secure terms we were prepared ta accept. On July 25. we began our heaviest air sivikes since 1982. Fa from producing a sign of a climb-dowa by izbollah, it responded with intensified rocket fire We escalited aver the following 24 hours, but still with na indication of amy change from Tlizballah. So as planned. we expanded our bombing 10 widec areas of south Lebanon. Sadly. some Lebanese civilians were killed. which I'm sure was a much preater cause of concern to us than to izbollsh. Thanldully, however, the wijorsty fled north. In south Lebanon, his meant ihut onr jeis smd artillecy had much greater freedom of uperation against Uizbollah, which had now lost its human shields. In Beinur, a government suddenly overwhelmed with the need 10 provide shelter for the kre number of refugees from the fighting did press Syrian President Assad to help bring it to an end. Critically, the new Clinton Administration, especially Secretary of State Warren Christopher, reinforced that message. Our military operation lasted just a week. 1 diel mor end Hizbollah nitacks on Tsraeli troops in the secucity zone, something I think even most Tsraclis were coming to realize was impossible as long as our soldiers remained in Lebanon Bul the rackel atiicks on northern Israel did stop, will very few exceptions, for a period that lasted neadly two years. The intifada, however. had not stopped. Not, as 1 kaew from my increasingly frequent meetings with Rubin, had the search for a way both lo control the viokuee, and seek oul any realistic prospect of a political path 10 resolving our conflict with our Arab neighbors. 252 Chapter Sixteen Rabin bad inherited a peace process. put in motion by the Bush Administration after the Gult War, But since both Prime Minister Shamir and our Arab enemies had reasons of procedure. politics or principle to resist the talks, merely getting them aff the ground had required the same combination of defines and determination President Bush had brought to assembling his wartime coalition and defeating Saddam. After a formal apening session in Madrid, the “bilateral tracks” between Israel and negotiators from Syria, Lebauon, Jordan und the Palestinians — hud quickly stalemated and stalked Yitzhak came to office saying he was not interested in a peace process. which seemed 10 him a Ticense far endless talk with no set endpoint, but in peacemaking. Smee 1 had the good fortune 10 be part of the mformal inner arcle with which he discussed the potential opportunities. pitfalls and frustrations along the way, 1 know fhat he wasnt assuming we could necessarily achieve i peace agreement with ny of onr neighbors. But aller the twin shocks of the Lebanon War and the Scud missiles, he was concerned that Israel would retreat into a mix of political caution and military deterrence which he rightly believed wis short-sighted. He believed we needed af least ta try lo seize a “window of’ appocunity” with those enemies who were al least open 10 compromise, if only because we were facing: new threats from enemies for whom tall was not even wn aption, An inereasmply assertive Iran, with nuclear smbitions, was ane. But he intifiuda had also thrown up new Palestinian groups grounded not in nationalism, but fundamentalist Islam: Tamas in Gaza, which opposed Tsracl’s presence om ny part of “Muslim Palestine,” and Islymic Jibud on fhe West Bank. And in Lebanon, we were confionting the auisn-backed Shite wilt fighters of Tizhollah Each of us in the small group on who Rabin relied for input on the peace talks brought something different to the mix. bn addition to me, there were four ater generals: Uri Saguy, the heed of military intelligence: Gadi Zobar. in charge of civil administration for the West Bank and Gaza; my own former sayeret depnly, Danny Yalom, who wis head of the central command; ind Rabin’s military aide, Kuti Mor. Also included were longtime political and media aide Titan Taber. and another trusted political adviser thousands of miles away: ltamar Rabinovich, our ambassador in Washington and lsracl’s leading Sytia expert. But I'm suce we weren't chosen just for our insights. Tt was 253 because we were people with whom Rabin fell comforable —a counterpoint, [ suspect, to the old Labor Party rival whom he had made Foreign Minister, Shiman Peres. Though the two men had grown fo respect each another over the yeas. Risbin neither tisted, nor much hiked, Shimon. tn fet, thongh Peres’ support inside Labor had secured hint the foreign ministry. Rabin had stipulated that all peace talks would remain under his control. Yet as 1'd discover nearly u decade later, when | was Prime Minister, even the most carchully planned negotiating strategics were always subject lo setbacks. diversions, or simply what former British Prime Minister Harald Magmullan once ealled “events, dear boy, events,” Rubin’s initial plan was not. to stat with the Palestinians. He did feel if was essential 1 try lo reach a political seitlement with them. Tn one respect, the prospects looked slightly better than before, Arafat's political position had been weakened: first by an intifada driven as much by local insurgeats as by the PLO in faraway Tunis, aod then by his decision to break with his longtime Gull Acab financial supporiecs and support Saddam Hussein the Gulf War. In 198%. as the entry price for a formal dialogue with the Bush Admmistation. he had also agreed to a statment inn which he renounced terrorism and aceepted the principle of a wo-stale peace agreement with Israel. Still there remained a yawning gap between the “self- ule” envisaged in the Camp David accords of 1978 and the Madrid conference, and the independent state the Palestinians wanted. Negotiations w bridge it were likely 10 be fraught and long. So he'd decided to begin with Syria. President Assad was obstinate, and publicly opposed to the ides of making peace with Israel. But he'd been in power for more than two decades aod, crucially (or Rabin, had lived up to the few, indirect agreements Israsl had made with him. The substance in any agreement, though politically difficult, wis also more straightforward. We knew what Assad wanted: the ceeovery of the Golan TTeighs, in cetura for the absolute minimum level of political normalization with Ismael. We kaew what we wimted: seenrity grarnices nd assnrances regarding water resources, and i full and final peace treaty. Vor Rabin, there was an additional atraction in beginning with Syria: if we did reach a deal with our main Arab enemy, the pressure would intensify on the Palestinians ta follow suit, “The dramatic tum uf events that uliimately forced hin to change tack began in January 1993 in the sitting room of a villa outside Oslo. at an ostensible “academic seminar” convened by the Norwegian diplomat Terje 1 arsen, It included two Tsraeli academics with personal Lies Lo prominent Palestinians: 254 Yair irschield, and the historian and former Haaretz jouroalist Roo Pundak Three PLO officials were there, led by Arafat's closest cconomie aide, Abu Alu’a. Thaugh both of the sraelis were friends of Yossi Reilin, 1 protégé of Peres and onr deputy foreign minster, even Paes didn’t know abont the meeting until Yossi told him the following day. Rabin knew an hour eter, I lirst leaned of it from Uti Saguy, after Unit 8200 intercepted Arabic-language traflic concerning a briefing the Norwegians had given their Arab contacts. Al fist, even Peres was skeptical that the paper ageced at the “seminar” — calling for intemational aid ta the West Bank and Gaza on the scale of the Marshall Plan, and an initial Isracli withdrawal limited to Gaza would lead fo serious negotiations. But Rabin authorized follow-up sessions in mid-February, late March and agaia in April. Our intelligence teams continued to provide detail. and occasional calor. Uri Saguy and | even began to use the Arabic shorthand, from the intelligence reports, for the two Israeli acadentics. The busy. bearded Yair irschield was “the bear”. The slighter Ron Pundak was “the mouse”. Yet the main poitical impetus in driving the process forward came from two men who were not there; on aur side, Yossi Belin, and for the Palestinians, Arafat's trusted diplomatic adviser, and eventual successor, Mahmoud Abbas, or Abu Mazen. Since Rubin knew | was following the ostensibly secret talks, we discussed them often. loc quite a while. he remained dismissive. Le believed the chances of a breakthrough were remote. Ie was alsa suspicious of the involvement of Peres and Beilin, whom he called “Shimon’s poodle”. And he deeply distrusted ArafaL The PLO had been founded with the ain of “liberating” every inch of Palestine. The fact that Acafat had agreed to the Bush Administration’s demand to accept the principle of land-for-peace struck Rabin as mere sleight-of-hand. By the third Oslo meeting, it was clear that the Palestinians were open ta an agreement that would fall well short of “liberatig Palestine”. Still, Rabin was leery. Ile tried briefly co return the focus to the stalemated Madrid-track talks with the Palestinians. Yet when, with obvious PLO enconragement, the Palestinian negotiators suood their ground there. hie seemed alist resigoed lo supporting Oslo. When we discussed it, he used a battlefield metaphor. “When you have to bral through, you don't necessarily know where you'll succeed You ry several places along the enemy's lines. In the sector of the front where ¥ou do succeed. you send in your other forces.” It was a matter of “reinforcing success.” 255 “I's the apposite in this case.” [replicd. “In a battle, the eneeny is doing. everything it can to stop you When you break through, it's against theic resistance, Here, the other side will choose to make it easiest for us in the place prefers. UF Avalia thinks bell get more from (he Bes and the Mouse thin from the other talks, it's hardly a surprise we're finding that only Oslo seems to offer a way forward.” Rabin did make one mare move, not so much in a bid to end the talks in Oslo as 10 slow them down aud create a context more favorable Cov ihe kind of agreement he wanted. He shifted his attention to his original peacemaking priority: the Syrians. In an effort to remave a roadblock to even beginning serious talks, he offered the Americans what they wonld later call bis “pockel deposit” Tle authorized Secretary of State Warren Christwpher to tell Assad that Washington s understanding of our position was that, assoming ull our own negotiating concerns were addressed, we accepted that peace with Syria would include withdrawing from the Golan. The formula was agreed in a meetiog in Israel berween Rabin and the Clinton Administration's Middle East negotiator. Dennis Ross. Rabin didn’t tell Peres or other misters about if, though lm Rabinovich did know. 1 did as well. Sinec acceptance of he need for a withdrawal had security implicadions. Rabin and I talked abou it in detail before Ross™s visit, We formulated the “deposit” together. We uscd an Fnglish acronym: IAMNAM, “iCall my needs are met.” The poial was 10 convey Lo the Syrian president that if he addressed our requirements for a demilicarized zone and early warning facilities; non-interference with our critically important water sources: as well as o full peace including embassies, open borders aud joint economic projects. we knew the trade-off would be to return the Golan. It was by diplomatic accident that the Syrian overture went nowhere. The reson even the Americans hid called our proposal a “pocket deposit” was that it was Lo be kept in the Christopher's pocket, 10 be pulled out as an American warderstanding of our position if he felt it might lead to a breakthrough. Our intel hgenee sccomnts of the Chrisiopher- Assi Iafks, however, snggesied it. had been presented as a straight message from Rabin 1o the Syrian president, giving, ic the status of Istael's new, formal opening position in negotiations. The distinction may seem minor. But for Israel, it mattered greatly. In any agreement with Syria — ur, indeed, the Palestinians — there was bound lo un imbalance. Both parts of a “land-For-peace™ exchange were important. But land ws mot Just the more tangible asset, Once given up, short of resorting to all-out war, there was no going back. The “peace” part of the equation was more 256 difficult. Genuine peace. and trust, would inex itably take years to cach fuition That was no mere academic problem in a conflict where, for decades, our enemies had defined Israel's mere existence as illegitimate, The reason for Rabin’s reluctsmoe fo have his “deposit” presented as a sel negotiatmy position was that il meant dealing away our only card — teritory — before the bard questions about peace had been answered. When he phoned Christopher. [ don't think [ve ever heard him as angsy. That wes sof what we agreed, he insisted. Ue said it had spoiled any prospect of serious negotiations on the peace side of the balance. Christopher didn’t agree there had been any real damage. nor that Assad had failed to understand the context. 1 might not have changed things anyway, since by this stage, the Oslo talks had almost completed a drafl agreement. Tn mid-August, Rabin gave Peres the go-ahead to initial this “Declaration of Prmeiples.” It provided for a period of interim Palestinian self-goverament; the start of a phased Israeli withdrawal [rom Gaza and the West Bank with the eceation of a Palestinian police force 1o deal with internal security; and a commitment to reach a full peace agreement within five years. fn early Sepranber, ahead of the fonmal suming of the Oslo declacation, there was an exchange of “letters of recognition” between Arafat and Rabin. Arafac’s letter also renounced “terrorism and other acts of violence” wad declared invahd “those articles of the Palestinian Covenant which deny Israel's right 10 exist” A few days later, the signing ceremony was hosted by President Clinton in Washington. Thus emerged the famous photo of Rabin and Aratat shaking hands, on either side of Clinton, who was beaming, arms ousireiched iu conciliation. They say a picture is worth a thousand words. In this case, you needed barely a dozen. Rabin’s demeanor, his posture, the look on his face, all seemed to say: “[ would rather be shaking: the hand of anyone on carth than Arafat” Soll, the image was on front pages worldwide, The news stories spoke of a new spirit of hope. Now that these old enemies had grasped hands, surely a full peace agreement yas within reach. My teeling, as 1 watched it on TV in the kirya, was more guarded. 1 did hope for peace, of course. | also recognized thal the signing on the White louse lawn was just a beginning, and that my role would be to ensure that Israel's security needs were met under whatever formal peace agreement might eventually be reached. And the sceurity omens were hardly encouraging. Despite Oslo. Palestinian attacks were continuing. ITamas, Islamic Jihad, and other dissident factions saw Aratar’s concessions as treachery, and were sefting out to drive home that point with vialence. 257 woe Yet as 1 approached my final year as chief of staff in early 1994, we were suddenly confionted by an appalling act of Zsraelf violence: mass murder, commited by a West Bank settler. Terrorism, no less than the worst Arab aitiacks on lsuach civilians. The seiller wis named Bauch Goldsicin, a physician. who lived in Kiryat Arba. One of the first posi-1967 Jewish settlements, it sac on a hill outside the West Bank town of Hebron. At the heart of Hebron lay the burial place of the patriarchs and matriarchs of the Jewish Gaith: Abraham and Sarah: Isaac and Rebecca: Jacob and Leah. Since Abraham is also revered as a prophet in Tslam and a mosque had stood on the site for nearly a thousand years, our post-1967 arrangements set out separate times of worship for Muslims and Jews. Goldstein chose to attack during a holiday period for both faiths: Pucim for the Tews and the Muslim holy month of Ramadan, He arrived shortly afier the Muslims” Friday prayers began on the mommy on February 23, He was dressed in his reserve army uniform and was carrying an automatic cifle. Tle upened fire on a group of nearly 800 Palestinian worshipers. He had killed 29 and wounded 125 others by the time several of his intended victims knocked him imconscious and beat him to death. rushed to Sde Dov airport in north Tel Aviv, i few nines from the Kiya, and boarded a helicopter for the old British fort near Ilebron, used by the Jordanians until 1967 and now Israeli headquarters. After visiting the scene of the killings. | sought out local Palestinian leaders, 10 voice my condolences and the sense of outrage I shared over what had happened, and to urge them to do all they could to maintain calm. [ then went to Kiryat Arba and conveyed the same messige. Our immediate lask was to preven moce deaths, on either side. [t was a frustrating. and violent, week. Protests reminiscent of the fist days of the ntafada erupted around the West Bunk, m Gaza, in cast Jerusaken and in several Auab neighborhoods and Lowns inside Israel. While [ had no wouble understanding the Palestinians’ anger, 1 also had a responsibility to prevent the vialence spiraling aut of control. We tumed to the same tools we'd used ar the beginning of the uprising — though with even greater emphasis on the need for soldiers to use the only the necessary force to restore order, and to avoid causing fatahtics wherever possible, We closed off the West Bank. We imposed curfews 258 an the main West Bank and Gaza towns and refugee camps. We also imposed & curfew on Kiryat Arba and, for the fics time, wese given the authority to use administrative detention orders no just against Palestinians, but specific Jewish settlers. We inrested shout a half-dozen leaders of Kisch, Uh Gu-right, anti-Arb political movement founded by the American Rabbi Meir Kahane, of which Baruch Goldstein had also been a member. Sill. there were repeated clashes anyway — and dozens of deaths as a result — before things finally began to subside a week or so later. The massacre had made me feel more strongly than ever that our responsibility to protect the security of fhe settlers could not extend to allowing them to defy the goverment or the kw. The principle woukd be put fo the lest within a few weeks. A settlement near lebron, called Tel Rumeida. had been set up without govemment approval in 1984. As part of the response to Goldstein Killings. Rabin was thinking of closing it down. That prompted a amber of right-wing rabbis Lo issue a formal seligious culing against any such action. Rabin called me in to ask whether it would be operationally possible to dismantle Tel Rumeida and remove the setlens. 1 said yes. by sending in a Sayerel Mathal force aller midnight, as long es news of the operation did not leek ahead of time. “We'll take over the area, close it off aud get control.” Given the tensions m the wike of the massacre, | did add thet 1 couldnt pronmise: that our soldiers would hold fire. “There are people in there with weapons,” { said. “If someone shoots at hem. they will shoot back.” “Should 1 do it?" he asked me. Maybe 1 saould have given him an answer. But | didn’ Reel it wis my place to dd 10 the pressures around shat was chendy a finely balanced call, especially since my inclination would have been to tell him to 20 ahead. 1 said ic was something only he could decide. “What 1 cur tell yous thi we ean do iL” When | lefl, my serse wavs tha bie was sulficicutly angry over what had happened in lebron that he fel. it esseatial to draw a line — the line of law — over what settlers were allowed to do. But the Passover holiday ws now i couple of ebay away. | Think what happened vs tha he realized the operation would uot be possible until afer the holiday period. By then, he was concerned he would have lost the clear political logic for moving against Tel Rumeida. The settlement has remained in place, a flashpoint in the conflict between settlers and Palostinians in Lhe arca around lebron. The wider repercussions. and the controversy. from the massacre reverberated widely. Rubin and his cabinet immediately decided to establish an inquicy. under Supreme Court Chief Tustice Meir Shamgav. IL would look into 259 every aspect of the killings — including any failings by the army, the Shin Bet, the police or other authorities thet might have allowed the tragedy to happen The commission interviewed dozens of witnesses, Israeli and Palestinian, in 31 separate sessions. | knew carly on hal the inquivy would throw up ditfiea issues. 1 was especially upset to kara that two soldicss and thee border guards scheduled for guard duty at the mosque had shown up late on the morning of the Killings. By the time | testified in late March, the inquiry had heard from a range of senior and local commanders and individual soldiers. A picture had emerged of a series of security breakdowns, equipment malfunctions, oversights and confusion around the site where the murders took place. {did not try to dodge the Fact that security lapses around the Cave of the Patiacchs that day had contributed to what happened. Tn addition to the fact that the guard unit was not ax full strenith until after the murders took place, several ol the security cameras weren't working. T acknowledged that if the cameras and the guards had done their job, at the very least some lives might be have saved. Yet I also made the point that chis specific act of mass murder was something the army could nol have mtieipated. | old the commissioners lo remember that they were judgiog things afier the fact. They knew how the tragedy had ended. In the context in which we were operating, the prospect of an Tsrachi settler, a reserve soldier, walking mio # place of worship and deliberately killing defenseless Palestinians had cone as “a bolt ftom the blue.” ‘The commission's report did not apportion blame to any of the army officers or commanders, Rut an inescapable conclusion from the testrmany of the many witnesses was thal the way in which we'd become conditioned 1o viewing the settlers had blinded us 10 the kind of crime Goldstein had commited. Tven before testified. I'd been disturbed to hear soldiers saying that even if they had seen him shooting a Palestinian, their orders were not lo open five on # seiiler, 50 they wouldnt have intervened. When asked about this by the commission, T said it was a fundamental misunderstanding of our rules of engagement. “In no cuse is there, nor eum there be, an many order iad sys it 1 fosbadsden 10 shoot al a settler even iC he is shooting al others... A massacre is & massacie. You don’t need special orders to know what to do.” Yet 1 also knew that the soldiers’ “misunderstanding” was all too understandable. As | acknowledged to the inquiry, ie army on the West Bank and Gaza was predisposed to see Palestinians who were carrying weapons as potential terronsts, especially since the outbreak of the intifada, The settlers, by contrast, were assumed to be careying arms in sell-defense. One lesson T took 260 from the massacee was that the mix of Jewish settlers, some of whom felt they were on @ messianic mission to vesettle all of Biblical [sracl, and restive Palestinians who wanted sovereignty and control aver their own lives was potentially toxic, for both sides. Ileally, The process whieh hae begun with Oslo might stact to disentangle it, though I remained far from confident that anything resembling full peace would come any time soon. ww Rabin, and even more acurely Shimon Peres, believed it was important to press ahead with the opening phise of the handover of Israeli authority mapped out by Oslo. To May 1994, a draft of the so-called “Gaza and Jericho First” agreement wis completed. Once if was ratified, the five-year interim period would begin, with firther wil hdrsvals and pan lel negotiations on the “permanent status” of the tervitories. In this first step, [sacl would transfer civil authority in Gaza Strip and the Jordan Valley town of Jericho to the Palestinians, and local seounty would be in the hands of a newly created Palestinian police force. My primary concer, and my responsibility, was the security provisions in the agreement, since fhe Istach army retained its role in charge of overall sceurily. When [went to sce Rabin a few days before the vebinel meeting 1 approve the Gaza-Jericho agreement, T told him T was worried that it left room far potentially serions misinderstandings, fricnon and even clashes on the ground. “There wis no elear definition of how our soldiers would operate alongside the new local police in the event of a lerror attack, violence by TTamas or Islamic Jihad. or, for that matter. a car crash involving an Israeli and a Palestinian. He agreed this necded to he addressed, wthough it wis clear he intended Lo do so with Asafal, via the Americans, nol by reopening and delaying the formal agreement. Bul 1 had a deeper concern bout the entire Oslo Agreement, whieh [ also now raised with Rabin. [did not doubt the importance of reaching a political agreement. and ideally a peace treaty, with the Palestinians. Buc I'd now read the Oslo Declaration in greater detail, and discussed it with lawyer friends of mine. I'd also re-read the 1978 Camp David framework on which the sel rule provisions were based. The endpoint was pretty clear, just as it had been at Camp David: Palestinian authority over the West Bank and Gaz, defined as a 261 “single tonitorial unit” under Oslo. Tn essence, and very probably in name, this meant a Palestinian state. T wasn'L opposed to thal in principle. if it was in return far a full and final peace. But the Oslo process meant that we would be handing buck land, andl control aver security, m an ever-larer portion of wrmitary before we'd reached any so-called permancnl-status agreement. In fact, before we even knew whether that would prove possible. It wasn't “land for peace.” It was land for the promise. or maybe only the hope, of peace. It was the same problem Yitzhak liad faced over the Americans” misuse of our “pocket deposit™ ou the Golan. [ realized that, having come this far with Oslo, neither he nor the government was likely to back away from approving the Gaza-Jericho accord, But he did say he thought the points 1d raised were important, which | took as meaning he was comfortable with my raising it with the cabinet. 1 spoke near the end of the four-hour cabinet meeting to ratify the Gaza- Jericho plan. The ministers seemed alleative as 1 can theough the security concerns I'd raised with Rabin, even nodding when I compared the agreement's security provisions to “a piece of Swiss cheese, only with more holes.” Bur then sari thi 1 wisnied 10 sy a few words which | recognized were beyond my responsibility as chief of stall. “I'm speaking just as an aracli citizen” [ told the cabinet, “and as a former head of military intelligence.” Referring to specific provisions m Oslo, and in the Camp David framewark agreed by Begin and Sadat 15 years carlicr, | said it was important for ministers to realize thal, even though permanent-staus issues were vet to be resolved. “vou will be taking us nearly the whole way toward creating a Palestinian state, based on the internationally accepted reading of Camp David ™ The reaction lo my comments was a mix of defensiveness and hostility. In the lawer camp were ministers from Rabin’s left-wing: coalition partners, Meretz, who seemed especially angry when 1 quoted from Camp David. The Prime Minister motioned them for cam, “Ehud had a responsibility to talk about secucity questions, and we had a responsibility to listen. As for his additional remarks, they are not a surprise to me,” he said, “He made these poms to me, und 1 said he could repeat them here, Tuis right that he should caise them.” Tle said there was oo need for ministers lo agree with me. but that ic was proper that the points 1'd raised should be heard Many clearly didnt agree with me, ar simply believed the Gaza-Jericho agreement still had to be ratified. which it was. But my remarks did lay the groundwork for my objection to the nex, more far-reaching stage in the Oslo process barely a year later, By then, [ was no longer chief of staff. 1 was a member of Rubin’s cabinel. 262 «ss Tt was still my responsibility ta ensure that Gaza-Jericho was implemented. and that the initial withdawals and redeploymeats went head smoothly. And they did. But [also was soon playing a part in a renewed effort by Rabin to use the momentim of Osto to achieve peace tyreements with onr other Arby aciglibocs: the Syrians, although he know that would be wugh, and fivst he Jordanians. 1 would always have had some role, by virtue of the need for a chief of staff to weigh in on security issues. But as Yitzhak had done from the start. hie involved me and others in his inner political circle in wider discussions on the whole range of negotiating issues. Especially after Oslo, he seemed determined to keep Peres’s role to an absolute minimum. No pesce talks ure ever completely staighiforward, but the process with Jordan was very close to that. The main issues va the Jordanian side involved ensuring a proper share of scarce water supplies; and dealing with Israsl’s dic Jaci conirol of u fairly lerge es wear the southem end of our border. A number of kibbutzim and moshavim were farming the land there. But oder the post-1948 armistice, it had been allocated to Jordan. Istael's priorities were © put in place a fully open relationship of peace and cooperation, and 10 gel assurances Juedan would not allow its territory to he used by Palestinian groups to launch terror attacks. Twas suck by how much more easily compromises can be found it you truly trnst the party on the other side. From my earlier meeting with Hussein in England, before the Gulf War, 1d been impressed by the king's thought and measured, yet warm and open, demeanor. That. in itself, inspired trust. But ever since 1967, even in limes of high tension, [smecl and Jordin had kept open sceret lines of contmunication. and both sides had peaecally demonstrated a shared desire, and ability, to seer clear of conflict. The main trade-off in the search for ia Torna pence wimed out lo be not to diTieull, We agreed To ensure water provision, and lo accept Jordanian sovercignly over the 1949 armistice ave, in return for which the king allowed the Israelis who bad been working the land to stay in place as lessees, On fhe final Wednesday of October 1994, near our border crossing in the Arava desert, | watched as Rabin, King Hussein, and President Clinton formally seal the full “Treaty of Peace Between the State of Israel and the Hashentite Kingdom of Jordin.” 263 Sycia was always going Lo be harder. But Rabin had moved past his anger aver the “pocket deposit”, and we began a new effort via the Americans. Our aim was to Tay out a comprehensive, staged proposal to trade nearly the entire Golin for peace. With Rabin, lan Rabinovich and the rest of the team, we put together a fanework limitig Syria's military prescace oa the eights, We envisaged phasing out the restrictions as Syria took steps toward the kind of peace which iad proved possible with Ligypl and Jordan. But indirect exchanges in the autumn of 1994 produced litle progress. tn December, Rabin proposed to the Americans that | meet with a Syrian representative, and President Assad agreed. Later that month, 1 was sent to Washington for talks with Syria’s anbussedor, Walid Muallom. With the Americans’ Mideast envoy, Dennis Ross. as host, we met in Blair louse across the street from the White Iouse. [began by explaining the security provisions we envisaged for the Golan, which included early-warning provisions. force limitations and otier means of safeguarding Tsrael against any surprise attack. Muallen's response was formulaic. almost icy. with no indication he was ready to discuss any of the specifics, much less offer wus of his own. Bul then Demns led us out mio the garden, where the atmosphese. if sadly not the weather, was a bit warmer. [told Ambassador Muallem 1 believed Israel's issues with Syria ought to be resolvable. Both sides understood the broad terms of an eventual pice. But we needed a context of truss in which tw negotiate. President Assad, and we as well, were always going to be reluctant formally to commit ourselves to a position until each side was he satisfied that the other sule widersiood its core needs. Plitically. both sides also feed constraints. “in formal mcctings, a record is taken and negotiators have to explain and justify every last word back home. T said. “1 think our negotiators can set further in conversations like the one we're having now.” Though Muallem nodded agreement, he did not expheitly say he believed that informal exchanges were the way forwacd. Still, he did obviously pass back a broadly positive message to Damascus. Before the Blair House discussion, our understanding had been there would probably be u kind of micros arrangement for a follow-up meeting: between onr ambassador in Washington, ltamar Rabinovich, and a high-ranking army officer from the Syrian side. Instead, we received word that Assad wanted me to meet directly with General Hint Shihiabi, who was not only my comierpar as Syrian chicl- of-statf bur Assad's oldest and closest political ally and the effective number- two mam in the régime. General Shihaba and 1 met over a period of two days at Blair House. He had greater authority, and thus a greater sense of self assurance, than the 264 ambassador. But not foe the last time in negotiations with Syria. any real progress was blocked by an apparent combination of misunderstanding and ‘miscommunication. The discussions were lively. Shihab had served as Syria’s Hisison officer with the UN force sel np ulong the cease in afier the 1948 wer. “Go cheek with the UN.” he said at our first meeting. “You'll see almost all the exchanges of fire in the late 1950s were provoked by Israel. "I did't sespond dircely. though | did note it was the Syrians who had tried to divert water from the Jordan River in the carly fities, “You did it first” he retorted. So it continued, Only Tater did we leam that while Muallem had sent back a generally encouraging impression from our garden talks, and his conclusion that Lorne was weady for substantive talks, he liad neglected wo convey ous expectation that any early progress would occur in faférmal exchanges. The result was probably to raise General Shihabi's expectations, which made him seluetant 10 show any real engagement. Aller a phone call with Rabin afler our fist day of talks, T became equally cautious. Tle agreed that we wanted tw avoid a repeat of our experience with the Golan “deposit”, We did not want to put concessions on the recard before we gat an indication that the Syrians were genuinely ready for peace talks. Still, the fact that we'd established the precedent of a “chief-of staff channel” was a step forward, My successor is ramaikal, Amnon Lipkin, would meet again with Shihabi in carly 1995. PE Twas confident Amnon was inheriting an army siconge, better prepared and better equipped than at any time since the Six-Day War. We also had peace freaties not only with Fiypl, bl now Jowdm, und none of the sibstantive issues with the Sycians seemed insumouatable. But the main security challenges were the unconventional ones. In the long fermi resurgent Iraq. and very likely Iran, might make strides towards welling aelear weapons. ‘There was every sigu thal Uizhollah in Lebanon; and Lamas, Islamic Jihad and their supporters in Gaza and the West Bank. would escalate violence und terror, As the negotiations with Jordan were entering their Final phase in early October, a further Hanas attack — this one, a kiduapping — hed brought home that tareat. On Sunday, October 9. Hamas men dressed as Onthoduos Jews abducted an ody soldier named Nabshon Wachsman near 265 Lod. Two days later, Iscacli television received a videotape showing the 19- year-old, hands and feet bound, pleading for bis life in retuen for the release of the founder of Hamas, whom we had amested and jailed in 1989, “The group from Hamas Kidmapped me, he said “They ure demmding the wekesse of Shieikh Ahmed Yassin and another 200 people ftom Iscaeli prison. IT their demands are not met. they will execute me on Friday at & pm.” As s00n as we got word he was missing, | spoke lo Rabin, Since we ssumed he was being held in Gaza, 1 ordered a unit from Sayerel Matkal 1o head south and co-ordinate efforts to locate him with the Shin Bet and the southern commun. But it eradunlly beeume clear he might be much closer to where he'd been seized. The Sin Bet got # description of the kidusppers” ca, and found it was a rental that had been picked up and returaed in east Jerusalem. They tracked down the man wha rented it, A little before dawn the moming of October 14. barely 12 bows before the [Tamas deadline, Shin Bel establisled that Wachsman was being held in a village on the road w Ramallah, north of Jerusalem, in a house owned by a Palestinian who was living abroad The hostage soldice’s ordeal was made even worse by fhe faet his mother, Lister, was a Holocaust survivor, born in a displaced-persons camp in Germany at the end of the war. Rabin had been ready to approve a rescue attempt from the outset, assuming we could locate Wachsmun and come up with « plan that wight work. But as with Entebbe, hie said that it we couldn’t be reasonably confident of success. we would negotiate. Now that we knew where Waschsman was being held, [ordered Shaul Mofiz, the commander with responsibility for The West Bank, to prepare for a possible rescue, Before poing to brief Rabin, | aranged for another commando unit 1 begin visible preparations for an operation in Gaza, in an ettort to reassure Hamas we shill beheved he was bem held there. Assnming we could retin the clement off surprise, there were several things working in our favor. The house wees relatively isalated. It was in an area where Israel, not the incipient Palestinian anthontics, still had control. And Sayeret Matkal had expertise und experience iu this hind of mission. Still. no plan could be foolproot. | old Rabin that the fact ITamas was holding a single hostage meant that if our assault teams were delayed for any reason at all, the kindappers mught kill him before we got in, Bul | said we had 1o weigh the risks of nos acting. We were no longer Irying fo find a missing soldier. We knew where he was. We had a unit ready. Unless Hamas relented. he was facing death within hours. In those circumstances, the 266 precedent of doing nothing would, in my view. be very serious. T recommended that he approve the opecation. and Rabin agreed. [attended the final briefing shortly afterwards. [ was impressed by the determined faces of the men in the two sayerel teams, One of the officers was 23-year-old Nir Puraz, whom [ remembered from operational briefings in the kavya on previous sayeret missions. Wachsman was being held in a room on the first floor. The commandos would simultancously detonate explosives on three doars: at the front, on the side, and a third one keading through a kitchen w the 100m where the kidnappers had their hostage. The attack began fifteen minutes before fhe Humas deadline, The explosive charges went off, but only the ane in the front blew open the door. Poraz and bis team rushed in, but one of the Lidnappers opened fire, killing him and wounding six others. The other team had by now made it ta the first floor, But despite firing at the metal lock, they had trouble getting the door tw open. By the time they got in, Wachsman had been killed, shot in the neck and chest. Iwas in the command post a few hundred yards away. I called Rabin and then went lo sce hin in the fire. The head of personel for the smmy had gone 10 sec the Wachsman (amily and break the news 10 them. Now, we had to ell the country. Rabin and I appeared on television together. Rabin insisted wrongly on sayiiz he bore full respansibifity, What had gone wrang, 1 had tried fo impress on him, was not the decision 10 aucmpt the wesene. It was the rescue itself. That was not his responsibility. It was mine. The next day, | visited Wachsman®s parents, and tried fo convey how painful the failed rescue was 10 Te, Rabin und every onc cle involved. [was mspired and humbled by their response. lis father had told a reporter he wanted to convey his condolences to the parents of Nir Paraz, “This added loss has shaken me terribly,” he sail. He fold me he also believed that the Prime Minister had approved the rescue using his best judgement on the information thet bie had available. | spent time separately speaking to Mrs Wachsman. | tried to explain flush wn Fhting an enemy like Hismss, peopks who not just threaten 1o kill but had proven thicy had no hesitation in doing so. U'd lL tere was nu choice but to attenipt the rescue. T admitted we'd known the risks. But we'd wied to do the might thing, both for the country ind her son | think she understood, though 1 knew that nothing could aller the tenible saduess of her loss. The pain would take years to heal. Some part of it never would. Still, T felt it was important she and her husband know that we. toa, felt their loss. For years afterwards. Navi and T continued to visit them. 267 By then, however, T was no longer chief of stall. Tn fact, barely ten weeks after the kidnapping. T handed over to Amnon Lipkin. T let the kirya proud of all 1 had sought fo accomplish during my 36 years in uniform, {also realized there had also been Grilues and setbacks, none more pain fly fresh than ou inability 10 rescue Nahshon Wachsnian. Bul © wes about to find that the area of Israeli life which I now chose to enter — national politics — could be a batdefield as well. And hat when trouble hit, even your allies sometimes ducked for cover. 268 Chapter Seventeen [Lwas an ambush. It came in Tuly 1995, six months afier I'd lef the army and only days before 1 was expected to named as Interior Minister in Yitzhak Rabin’s goverament. 1 he effect, and clearly the intention, was to thicaten my political career before it had even besun by reviving, and lying about, the tragic training accident at the Negev army base of Tze"elim, during our prepirtions for the operation aguins! Saddam Husscin, When the “story” broke, [was neurly Give thousand miles away. | wits accompanying Navas brother, Doron Cohen. on a business trip he was making fo China and savormg my last few divs as a private eitizen between my three decades of militacy service and my entry into politics. I'd got a bial of the storm that was about to engulf me a few days before we left for the Far Cast. It was a letter fram a reparter at Yeidol Achronol, Israel's largest-selling newspaper, with a list of questions about ‘Tzi"chm. The thrust of the questions mde elewr the case Yediot seemed intent on building: that after the live missile strike which killed the Sayeret Matkal men, | had abandoned the injured and immediately “Ned 16 Tel Aviv. 1 probably should bisve answered the letter, But Tassuned even rudimentary checks would reveal the story to be false. I'd had similar questions from a TV journalist a fes months earlier. 1 did phone him back. 1 explimed the ue details of whit had appened. 1 suggested he talk to atbiers who were there, like Amnon Lipkin, the curcent chief of staf and my former deputy, to confirm my account. The story was dropped. But ¥euiot evidently decided not to let the facts get in the way of the “exclusive” il vm in its weekend edition on July 7. Gnder a baer headline — un undeniably clever Hebrew pun. End Barut, “hud Ran Away” - it accused me of having stood by, paralyzed with shock, when the missiles struck and then, us other officers tended lo the wounded, msted away by helicopler. Doron and T were having dinner in Beijing when Nava phoned. She'd just seen the newspaper story, and read it to me. I'd never been angrier. As best | could work out, it hud been concocted from a patchwork of accounts kong after the fact. To the extent the notion of my “fleeing” had been raised. T could only imagine that Yedior's “sources” had misunderstood the arrival of the first medical helicopter, when the pilot was unable to see us and flew on before setucning a couple of minutes later. Bul in every single detail about my activns after fhe tragedy occurred, it was a pure and simple lie. 269 Twas not just angry, but frustrated at my inability to rebut the story in person. Doron and | immediately made arrangements 1o vetwen w Israel early, which, since there was no direct wir connection, meant finding the first flight out ttnongh London. But before we lef, Nava phoned agin, almost spullering in Tuey. She wld me that she'd just ceeeived a call (rom Aliza Gocen, Rabin's media spokesperson. “Does [hud know about the Yedior story?” she'd asked. When Nava said yes, Aliza told ber: “ILis important that Lhud knows thal we are nol aiug 10 get involved in getting hin out of this” Weicome to politics, 1 thought. Rabin knew that the story was untrue. I'd still been in T7¢ elim when 1°d phoned im about what had happened. He knew 1d remained there to order in the medical helicapiers and wnange for the evacuation of the wounded before fewening to brief him. Sill. he did not say a single word in public nar, for that matter, speak to me as the controversy continued 10 gather force. During our stopover in London, | sal with Doron and talked through how wo get my voice heard. | relephoned Yoni Karen, the officer who'd been my top aide m the kirva andl whom Pd asked 10 work for me in the Inferior Ministry, assuming | now actually got there. 1 told him to phone Anion Lipkin and say that 1 had expected him to answer the fabrications. Not only had he and [ been ut the site of tragedy together, We'd Jeff together, on the same helicopter, Ammon did now issuc 3 statement saying that he knew Yedior's allegations were wrong. But the story had been allowed to stand for too long. TTis rebuttal caused barely a ripple. As red the latest Israeli newspapers before himding in Tel Aviv, | found that at least I wasn’t totally on my own. Reporters had been phoning politicians far comment, Most responded like weathervanes, going with the prevailing wind, which was gusting aginst me. Bul three Knessel members dissented. One was Ori Or, a friend even before we'd both gone into the army, and who had now joined Labor, The other two were leading members of Likud: Dan Meridor and Benny Rein, Memichem Bewn's son, All three siid they were sure the allegations were false. Did they know the details abou the accident, they were asked. No, they replied. they didn’t need to. They knew ime. Now all [ had to do wus convinee fhe rest of the country. It had been nearly a week since the Yedion's “expose”. 11 wis Yoni Koren who pissed on a request from Channel | television, our equivalent of the BBC. They were proposing that Lipps with Nissin Mishal, the san sho had fnviewed me 10 years eatin, at the urging of Rabin's political aide. on my ficst TV appeacance. lor Mishal, 270 the interview would be a journalistic coup. For me, il was a isk. ITe was a [famously eombative questioner, a bit like Sam Donaldson at While louse briefings, or Jeremy Paxman and Jahn Humphreys in Britain, On the night of July 13, 1 drove to the television studio m Tel Aviv. Mishal confronted me with Yedion's version of events. | was angry, and showed it. “This report was not some night editor's mishap,” [ said. “It was authorized by the highest levels of a mass-cireulation newspaper which 1s pawsr-drunk, camupled by power, and manipulative. The so-called “story” was an amateusish and distorted depiction of a chief-of-staft who sees wounded soldiers, turns his back, deserts them and flies away, That is an evil, vain falsehood.” As Mishul pressed me whout the allegation hat 1 had fled, | cited, by sume, olher officers who had been there with me and had confirmed precisely the opposite. T had lel Tzeelim, akong with Amnon |ipkin, a full $0 modes after the missiles struck, said. And only after the helicopters had artived. the injuies had been treated and the choppers were evacuating the wounded. “A chicl of stalls job is not lo rear the wounded. when others are daing thar already,” I added. My sespomsibilily wis “Io keep my head, and ensure a safc snd speedy medical evacuation” Thal was what I'd dove. “['ve given years of my life lo serving this country,” I said. “I have been shot ac. I have shot men dead from as close as I 20 10 you now. How did the hand thal wrole thes: things agaist me nou wemble?” Tt was certainly high drama. But it was not an act. The way that I'd gone after Yediol prompted some pundits to suggest my skin was toa thin, One commentator even said [was obviously nol suited 1 polities. Yeu what matiered Most 10 me was what the rest of Tssael felt: people who were aol reporters or editors, commentators or politicians. Opinion polls the day afterwards showed thst something like 80 percent of traclis believed what 1°d said. § think this was only partly due to the details of the argument T made. When you're under such close, direct scrutiny. I'm sure viewers have an innate sense of whether what they arc hearing 1s the uth, Almost as soon as I'd got hone from the interview, the phone rang, [L was someone who. of course. already knew it was the truth: Yitzhak Rabin. “Thud,” he said, “you did well, Lets move forward,” «ee 2n Tater worked out why he'd wanted to steer clear of the whole thing. Yedior had been planning the story for mouths. IL had been ready to go with it earlier, when it was assumed [ would be joining the government as early as April. The editors had hele it To coineide with my anival as a minisier. Tht, | suppose, wes simply what newspapees did. Bul it turaed out that at least two influential Labor politicians had played a parc in steering ¥ecdior coward the story, and urging the newspaper Lo fun with it: Lain Ramon, a veteran party figure and cabinel minister. though he'd quit the government the year belore over the party's failure to follow through on health-policy reform; and Shimon Shevess, one of Rabin’s top advisers. Raman would later say that they hadn't wanted to “Rill Barak” a9 a new minister. “Just fire sone bullets at this legs, so hell cates politics with a limp.” It was a way of cutting me down fo size. 1 suppose thar was understandable. [was by no means the only former general Lo enter Iscaeli politics. Other chiefs-of-stalf had gone va to play promincal soles in government: Dayan, Mott Gur and, of couse. Rabin. Bul the fact that I was going directly into the cabinet. and so soon after leaving the my. was seen hy the smal media anes umber of Labor policies — asa reflection of my close relationship with Rabin. Some commentators had even been speculating I might eventually be a candidate to succeed him as party leader and Prime Minister. 11 was rue that Rabin had persoually urged me to juin he government, starting with a lighthearted remark oaly days after I'd ended my term as chief of staff, It was ata firewall arganized by my staff. The event began with film chps from my years in lhe wriny, ind a series of entertaining cameos rom men 1d served with and led. Rabin spoke at the end. Tle said he'd recently besa on an official visit to South Korea. He'd met the president. who told him he was the first Korean leader nol to have been an anny general. Rubin sid he'd replied that he was the first Tsracli Prime Mioister who was a general. Thea. smiling and looking straight at me. he added: “Nit, Ehud?" 1 did want fo in bis government. But [had been in the army since the ae af seventeen and was now in my carly fillies. Vor my family’s sake, 83 well as my own, Thad figured on taking 2 year or twa to explore other things. Two optians appealed to me especially. One wis business. My brother-melaw, in addition to having successful iw practice, was involved in a number of business ventures. and we'd discussed aseas we might jointly explore. But T had also received offers from think tanks in the United States. 272 Despite Rabin’s quip about ex-generals and Prime Ministers, was sucprised when, a couple of days later, he asked me wo come see hin Ile smiled as 1 entered his office. Then he said: “Fhud, now that you are out of uniform, 1 would be whl tw see you come ino polities, Together with us, and be s member of the government.” Te said he'd discussed it with Peres. “It's a joint invitation.” Though I did, of course, say yes, I also told him [ was planning to take some time ofT, probably at fist with a think tank in the US. Though [ wasn’ exactly sure about the legal provisions for officers leaving the amy, | reminded him that there was a set period of time during which they could not enter palitics, He replied. a bit enigmatically, that he would be sending an “operative” w talk 1 me farther about he Liming. The operative was Giora Liny. a uniquely important (igure in Labor because he was trusted both by Rabin and Peres, | liked him immediately, Throughout my years in politics, IT would come to ely on him foe his experience, good Rumor and good judgement. Tle did know about the rules for former acy peaple going ino politics: there was a 100-day moratorium. “Rabin wants vou inmedintely,” he sand. “1 guess well el him that “mmediaicly” wall have Lo mean sometime in April.” In fact, [ told Giora that ['d hoped it would be much longer. So we agreed tha in order to give me at least a few months in the US, he'd tell Rabin he could gel m touch at any tine from March 1996 wath his invitation to join the cabinet. As soon as le did 50, | would formally cut my ties with thie military. meaning I could join the government in the summer. Nava, the girls and [ left for Washington in January. I joined the Center for Strategic and Iniernational Studies ad was given the delight fully overwronght title of Distinguished Visiting Statesman and Senior Associate. The reason the CSIS had invited me was to write and speak on the Middle East. About two months in, | presented # paper. | began by welcoming the constellation of changes which seemed to offer at Least an apportunity Coc stability, seowsity and peace: the unravelling of the Soviet Union; the Oslo Agreement; the peace treaty with Jordan amd the continuing talks with the Synans. As long as we had partners committed Lo reaching an agreement, | believed Israel would be ceady “to consider major compromise and to take upon ourselves significant calculated risks.” But with a frunkness which seems surprising even to me in serospect, [ delivered much the same message as | had 10 ministers on the potential dangers inherent in the Oslo process as we moved forward. I pointed out that Arafat had made no move ta rein in groups like Hamas. and that more Israelis had actually been killed by tecror since Oslo than in the 273 year before. “We signed a three-phase contract with Arafat” [ said. “Try w imagine ane of you selling me three pieces of property. [11 fail to pay for the first one on time, you might not immediately cancel the contract, You might even bie ready 10 help me collee! the necessary money. Bul you would never proceed w deliver the second property before 1 paid for the first anc, unless you were a fool.” [also warned of longer-term dangers: “terrorism. radical Islamic fundamentalism, the proliferation of surface-lo-surlice missiles aud weapons of mass destruction. and threats to the long-tevm stability of the more pragmatic Arab regimes.” 1 singled out Iran, because it was determined to export its brand of fundamentalism Islam, spensor terror and develop a nuclear weapon. Tulse sceampnicd CSIS colleagues on speaking cngagements 1 other American ilies. [ was about to board a flight 10 Seattle in April when 1 gota messige sayy Rabin wanted to talk ta me, After we took off, | used the an- board phone facility and, with a swipe ul a credit card, was soon on the line lo the Prime Minister. Since the exchange was io [ebrew, Pm fairly swe anyone overhearing me had no idea what we were talking about. “I need You to come biuck is soon as possible,” Rabin said. | uly knew, from CGiora, that he was anxious Lo find a long-term replacement as Minister of Taterior. The leading light in the Sephardi religious party Shas, Arye Deri, had had to leave the post under allegations of bibe-tiking. A fier Rabm bid ken on the port foha himself four 18 months, he had placed Labor's Uzi Baran there, but ouly as a temporary arrangement. I dida’t feel T could refuse outright, Buc I reminded him that under army rules. “as soon as possible” still meant another 100 days. And ideally, [said [wanted to finish the best part of & year in Washington. | asked whether it would be possible to join the cabinet in the middle of November instead. “What difference will a few more months make?" Rabin said he needed me naw, and that mid-November would be too late. “Thu. in politics, you can never predict what will happen by then.” Neithee of us could have known how terribly prophetic his words would mur out fo be. owe Iwas not only new to cabinet politics. 1 wasn't even a member of the Knessel. Bul in addition wo naming me as head of a major minisiry — in charge of everything from citizenship and immigration to planning, zoning. and the funding of local goverment — Rabin made me a member of his “inner cabinet” 274 an security and foceign affairs. Barely three weeks after 1 joined the goverament, we had to decide on the most important agreement with the Palestinians since Oslo. Dubbed Oslo 1, it involved a major transfer of anthony sd pearitory. The process wonld begin with our pulling oul fom more than a quarter of the West Bank, including the major Palestinian towns and some 430 smaller towns and villages. After that, there would be three further sedeployent phases, at six-month intervals, in so-called “Area C” of the West Bank - a mix of unpopulated land, setclements and a number of points we'd desigmated as strategically important. Under Oslo, and its parent agreement Camp David, it was all part of ensuring the Palestinians could exercise their “legitimate rights” in the “single terrilorial entity” of the West Bank and Gaza — in other words, a path to statehood. But oaly by the time the final three phases of redeployment were complete were we required to begin the “permanent- status” talks on issues like land ind borders, Itachi seulement, the future of Terusalem: the real core of a peace agreement By the time I joined the discussions on Oslo II in August 1995, the main points hal already heen sured. Ralyin was in favor, as were vinually all the cabinet ministers. Whatever scant influence | might exercise would have to come at the decisive cabinet meeting, set for August 13. From the objections I'd saised to The Gaza-ericho deal as chief of stall, Rabin knew I'd be concerned not only to ensure the security proisions avoided potential misunderstanding on the ground. but about the longer-term implications. especially since the scale of the Iscaeli withdrawals was much larger his time. In fact, the agreement could be interpreted as requiring us to cede Paketinian control over virtually all of Gaza and West Bank by the end of the third redeployment phase ~quite possibly before talks on the permanent-status questions had even hcg. [went to see Rabin a few days before fhe cabinet vate, | explained why | thought the ageeement was flawed. T argued we should cither delay some of our redeployments or bring the permanent-status negotiations forward. Ile listened tome. He barely spoke. He knew Ud be against Oslo 11, and knew the seasons why. Bul we both knew something else: having been brought into government by Rabin, I would be expected, ona vote of this importance, to be in his comer. The cabinet vote wasn't happening in a political vacuum. Likud's defeat in 1992 had meant the end of Yitzhak Stiamiv’s leadership. | he new Likud leader was the former Sayeret Matkal officer with whom I'd shared a newspaper cover in 1986 predicting that he and | would end up facing each other ut the ballot box: Bibi Netanyahu. Positioning himself as the fresh young face of Isracli 275 polities and vowing ww defeat Labor, Bibi had seized on Oslo 11 10 accuse Rabin of “surrendering” w Arafat, and by extension to lamas terrorism. [ couldn't sleep the night before the cabinet mesting. I had no desire to be disloyal ta Yitzhak, 1 certainly didn’t want to ad to the pressures an him, much less add further impetus 1o Bibi's rhetorical vuslaughts. But the more | thought of it, the less I could see the point of entering politics if [ wasn’t going to vote with my conscience, The cabinet meeting listed for hours. [1 was near the end tht 1 spoke, calmly and in detail, boul my reservations. Many of fhe ministers seemed barely to be listening. They'd long since made up their minds. But when I'd finished, two ministers passed me notes, Bath sad fhe same thing: Ehud, don’t do anything crazy. Don’t vole against it. So 1 didn’t. But J couldnt vous for it either. T abstained. Rabin was bitterly upset. He didn’t tell me directly. Bur when the meeting broke up, his longtime political wide, Eitan Haber, took me aside 10 tell me how that what I'd dove was “tersible™. Givea Liny came to see sue the next day, afer Rabin had phoned him in a mix of anger and disbelief. “What fs this,” he'd asked iors, “The first big vol, and Bark abyiins™ 1 wasn't until a (ow weeks later that Rabin and | spoke alone, over a beer in his office. He dida’t raise the question of the vote. So 1 did. “Yitzhak, I understand it’s caused you pain,” suid. “But | think vou understand | was acting out of what is genuinely my belief aud my position.” {asked him why, unlike the other ministers, he hadn't passed me a note before we'd cast our votes. “Thud.” he said, “T never Write requests ar orders on how to vate. Ministers must vote according fo ther conscience.” He didn’t mean what I’d done was right. He meant my conscience should have old me. given Lhe importance of the issue, 10 vole yes. The tension between us did ease somewhat in the weeks ahead. But the tension aroused us eseabited aller the cabinet vole, Opmion polls showed the country split down the middle. Seulement leaders and extremist rabbis launched a campaign against the legitimacy of the government, and of Rabin as Prime. Minister, Ruzht-wing religious leaders issued a decree rejecting the planed sedeployments ou the West Bak — “the evacuation of bases aud their ransfer to the Gentiles” — as biblically prohibited. A new group called Zu Aizen orgamzed a campaign of evil disobedience to try to bring the government down. The sheer venom bit home during a pair of events [attended with Rabin, to ward of Ure status of “ily” w lowns which bid crossed the required threstiold iin population aud ceonomiic activity. By tradition, this was macked by a 276 ceremony with both the Interior Minister and the Prime Minister present. The first was in Ofakim, near where I'd worked in the fields with Yigal Garber in the 19505, Shartly ater we arrived, a group of profestors started shouting at Rabin. amvac they yelled “muniac”. Hoged: tranor. Al lhe second even, near ite, busloads of protestors from right-wing religious schools shouted abuse at Rabin when he rose to speak As the Knesset vote on Oslo 1 approached, the hatred reached new fevels. The day bofire, thousands of protesters packed into Jerusalem's Zion Square. Some shouted “Death to Rabin!" Others burned pictures of him, or passed out photos of him dressed in an Arab keffiyeh, or even a Nazi uniform, Ribs had publicly declised thet opposition to the agreement must versio within the bounds of the law. Yet as he addressed the baying mob fiom a hotel balcony, he uttered not a single ward of reproach, In fact, be called Rubin's government “illegitimate”, because it relied in part on the votes of Iscacli Arab Knesset members. The day of the vote, the mob descended on the Knesset. Rabin had called a goverment meeting beforehand. When | got there. the crowd was so large (hal Uveass taken in through special sceurity entrance away from the front of the building. But the Housing: Minister. Binyamin Ben-Eliezer, arrived late and tried fo drive through the mam gute, Protestors pounded furiously on bis cur and ried 10 break the windows. Our mecting had alicady begun when he airived. He had spent nearly as long as T had in the army, but he was shaken. Interrupting Rabin, he banized his fist on the table, “I"ve been on battlefields.” he said. “ve heen shot at. 1 know how fo read uw situation. {saw their Faces. 1s insane! 11 is beyond anything rational. this kind of hated.” Pounding the table again, he shouted: “I warn you. It will end with a murder! It will end with a murder!” Rain motiomed for calm. He, woo, wis concemed by the rhetorical violence, even more so now thal it was becoming physical violence. But as he would tell an interviewer a few weeks later, lie simply didn’t believe that “a Jew will kill 2 Jew.” Nor. at thal pom, dict 1. Afler the Knesset vote, which passed by a margin of 61 1 59, plans got underway for a rally in defense of the peace process. and against the tide of hatred on the right. It was the idea of two people: Shloma Labia, a 1.ikud mayor al Tel Aviv who now backed Oslo, and a French Jewish businessman wamied Jean Frydman, a friend of Shimon Peres whom I had got to know and like. But in several of the carly planning discussions m which 1 was involved, Rabm was against the rally, which was to be held in the huge Kings of Tseael Square in the 277 heart of Tel Aviv. Ile was worried that not enough peopk: would show up. and that those who did would be [rom the left: Merete, not Labor, people who would be there mainly to criticize him for not going far, or quickly, enough in pulling out of the West Bunk. In the end, he was persuaded it should go abicad. In fact, by the time the date approached Saturday evening, November 4 he seemed to be feeling more energized, and upbeat. 1 wouldn't be there, because [was going to New York as the government's representative wl a fundvaising dinner al same night for the Yad Vashem Holocaust memorial. A few hours betore leaving, however. I met with Rubin, We'd found a 15-minute window in his schedule, but we ended wp talking for an hour. He said he knew that, in some ways, the difficuliics surrounding the peace talks were likely i gel worse. Tamas would not abandon temor. The kind of intolerance we were seeing from fhe right wing was not going 10 go away. Tle was fucious at Bibi, who in his view was hypoeiitically going through the motions of calling for restaint and pretending Lo be unaware that the mobs were full of Likud voters. “They re his people.” he said, “and he knows it.” But he was relishing the idea of taking on Bibi in the next election, duc in about a year's time. Though Rabin was trailing in the polls, he was confident of turnings that around ene the camprign began, >The main thing is that the party isn’t focused. We have 10 gel serious shout preparing,” he said. He was worried about the effect of inevitable tensions between his supporters and Peres’s over how ta rum fhe campaign, “Bring hack Haim Raman,” [ sugested, 1 knew by now [hat Haim had helped orchestrate the false story which Yediot had van about Teeelim. But T also realized he was a Labor heavyweight and that. although he'd left the government, he remained personally close to Yitzhak “Yes,” Yitzhak replied, nodding, sugsestimg that we talk through the ides in detail whea Tceturaed fiom New York. Iwas in my room at the Regency Ilotel. on New York's Upper Last Side, when the phone rung on Saturday aflemoon, | was dimly aware that the Tel Aviv rally had ecu going an back homie, but was more focused on preparing my speech for the Yad Vashem event. “Ehud, Ehud!” It was Nava, her voice barely imdenstandible through the sabs, “Rabin has been shot!” PEE 278 Danny Yatom called me a couple of minutes later. le said Rabin was still alive. But fiom the details he gave me, T knew it would take a miracle for him to pull through, “Three shats, from close range,” Danny said, “From an fsracti, a Jew.” Like Rabin, like me 00 until this bad selually happened. it was something Denny was struggling to believe. le said that he'd call me back when he knew anything mote. But Thad the TV an in the room. Before he did, 1 watched Titan Usher announce that Yitzhak Rabin was dead Although [hadn't known it until Id arrived, Yossi Beilin was alsa in New York, tor mestings and a speech of his own. Though he was a Peres protégé. and 1 was seen as closer to Rabim, the two of us had become fends, We inmmedintely made plans to ge the next flight home. But before leaving for the airport, T phoned Leah Rabin. lowever inadequate T knew it would be in helping her even begin to cope with the loss, 1 told her that my, and Navas, thoughts were with bier. Thal Yitzhak s death would leave & tremendaus hole, in all of us. in every single Israeli. “They shot him. she kept nuumuring. “They shot him. They shot him. They shot hin." 1 called Peres, too. “Shimon, you have i mormiznn on your shoulders.” 1 ssiel. “But your ask is fo cary on. All of us will be with you, supporting, helping however we can.” It was the saddest flight I'd ever taken. Yossi and [ barely spoke. Each of us was deep in thought, 1 found myself lost in memories of Rabin from the very first tine Pd met him, in the ssyeret, to that hast, long tall we'd bad in his office a couple of days earlier. Tor some reason. T kept wondering whether, whea the shots had been fired, he'd been turning to look behind him, 1t wis an idiosynerasy he hud, whenever hie was leaving a meeting or an even! — even, as | now recalled vividly. when the wo of us were Jeaving the muaicipal ceremony in Ofakim. I was behind him as we left. “Ehud,” he said. turing back, “are you there?” 11 was senseless detail. 1 wouldn't chinge anything. Bu 1 sill fell wom up inside thinking about it. After we landed at Ben-Gurion. [went with Nava to the Rabins” apartment in Ramat Avy, There were hundreds of people outside, and nearly a hundred crowded inside the Tat. Leal looked exhausted, her face ashen. “They shou him,” she said over and over as Nava and T hugged her. “Three shots. In the buck, Why?” [said there wis no sinc answer, but that with Yitzhuk’s death, tse] seemed different, the world seemed dierent, and emplir. Before we lef, we added our candles to the forest of Nickering memorial lights outside the apartment block, Then, we drove the Kings of (sruel Square. Thousands of people were huddled in small groups throughout the plaza, sitting around 279 thickets of candles and chanting, almost prayerlike, anthems of mourming and of peace For reasons [ couldn't explain, 1 felt the need ta see the place, near fhe front of the square, where Rabin bid been murdered, by 4 25-year-old Orthadox Jew and settlement activist named Yigal Amis. Standing there with Nave, 1 felt even more strongly what I'd told Leah by phone from Nes York after hearing Yitzhak wis dead: his munfer would leave a huge hoe m me, in all Israclis. He was an extraordinary mix of qualities: a brave officer, First in Lhe pre-siaie Palmach and then the new Isracli army; a chief of statf and defense minister at critical periods in our hustory. Shy, even at times ineertain or hesitant, und naturally cations. Decisive, Loo, when he fol that bie, ad sacl, ceded to be: whether on Entebbe, oe the prospect. with all its risks. of launching an operation to kill Saddam Hussein. Humane, toa: ready to negotiate with terrorists to save he lives of those they were planning to Mill, uoless he was confident our soldiers could save them fisst. Underpinaing it all was a dedication w fighting and defeating Isael's enemies. yet a mindfulness that the real victory, if and when twas possible, would be renin peace with our niighbors. He and 1 bid had differences over pactioular policies: leaving our troops in Lebanon. for instance, or more recently the architecture of Oslo. But I never doubted that we were ueky lo hive Yau leading rach on the inevitably faught rod 10 a negotiated peace. | ever ceased 10 believe there was no politician more suited to the role: that he would do everything he could to achieve it, yet would step back if he saw that ie was putting Israel's security at isk. On Sunday evening, Peres called i cabinet mevting in the Kirya. He said ous task wes to continue what Rabin had begua. and that at Jeast for now he would fill Rabin’s shoes not just as Prime Minister but Defense Minister as well. The whole country stood still, shocked, mil the state funcrl two days afler the assessination. Tt was attended by dozens of leaders from around the world. My tole was to escort King Hussein and Queen Noor. Ou our drive into Jerusalem, we passed the OI City walls. We were harcly 1 mile from the stone lemsce, above the Western Wall of our ancient temple, where the golden Dome of the Rock and the Al-Aqsa mosque stand. knew Iussein had been there as a bay when his grandfather, King Abdullah, was shat and killed by a Palestinian amid sumors hie was contemplating peace with Isracl. Now, Rabin had been murdered, by an Tscaeli. “To me. ic’s like the closing of a circle,” Tlussein said. “Those who are murdered because they are not extreme enough, Because they look for nomaley, and peace.” 280 Yitchak's mueder had acted like a kind lighting surike, freezing Israelis ina mix of disgust over what had occurred and awareness of the dangers this brand of hatred and extremism posed. 1 was concerned fhe moment would be allowed To pass. My hope was [hal we could seize the opportunity To bring together ull those Israclis — on Jefl and right, secular and Orthodox, Ashkenazi and Sephardi — who were prepared to stand up against the fanaticism. the violent messianism. af which Yigal Amir was just a past. | hat was the main reason | wanted Peres 10 call an carly cleetion. au issue that would be discussed, off and on, over the next few months, [ felt the time was right to present the country with a choice: not just between those for and against specific compromises being: contemplated iin pursuit of peace, but between those who wanted a tolerant, funclioning democracy and those who were ready to use demagoguery and violence to get their way. Peres's first onder of business was to pul in place a new cabinet, Ite did, briclly, consider giving up the Defense Ministey and putting me there. Bul instead, he made me Foreign Minister. Like Rabin before him. Shimon stipulutcd that he, as Prime Minister, would relam wathority over the peace negotiations. Still, with his agreement, [ was involved in all the discussions around the peace talks, and in meeting many of the Arab leaders we'd have to negotinte with i0we were 1 (md a lasting resolution of the Arab-lsrachi conflict. Justa few weeks after the assassination, | represented Israel al a Liuro- Mediterranean Partnership conference in Barcelona. Its only real diplomatic work consisted of ironing out the wording of the communique. The real value was in the corridors, and at the dinner lield au one of King Juan Carlos’s palatial estates, and, for me, a first opportunity to meet not only Arab foreign ministers but Yasir Arafat. My first, brief encaunter with Arafut begun a bit embarrassingly, 1°d arrived 2 few minutes carly for the confecence dinar and was led into an impressive Tall that was almost empty except for a wonderfully cared-for royal Steinway. [ sat down 10 play. Lost in the beauty of a Chapin sonata, | wis completely unaware of PLO leader's approach behind me. A bit awkwardly, | rose to groet him. I grasped his hand. “I¢'s a real pleasure to meet you,” said. “I must say I have spent many years watching vou by other means.” He smiled. Our hosts liad set aside time after dinner for the two of us Lo talk at greater keugth, with no aides present. But my hope was to begin by establishing simple. human contact: fo signal respect: to begin to create the conditions not to ty to kill Arafat bur, if he shared the sume roa, 10 mike peace with him, “We camry great 281 responsibility,” T said. “Both of our peoples have paid a heavy price. The time Tas come to find a way ww solve this.” In the halt hour we spent together later, [ could see that, physically, the Fatah leader from Karamch was not just older. He had a frailty about him, His skin seemed almost translucent in places. His hands shook slightly, with the carly signs of Parkinson's. He spoke softly. But despite this ostensibly vulnerable exterior, | could see how damting, and frustrating, he must be a negotiating partner. Hemy Kissinger has described how Mao Use- Tang. rather thay engage directly in discussion or debate, tended to wrap his remarks in parables. Without stretching the parallel toa far, Arafat wus like that, While | tried to engage him an how cach of iss might help cement the Oslo process, aud crsuse thal the interim agreement indeed led to a full peace. he responded with stories, oe off- topic remarks, which [ was left to umyrap and decipher. He begin onr discussion by saying thirt now thal 1 wis Forenm Mimsier, he was glad w meet me. Le said that he'd beard “reports” trom bis intelligence people that when [ was chiet-of-staft. | had organized a kind of dissident band of generals who were working tw tormedo The Osto sgreements. He compared hig 1 the OAS. the military cabal in France that had opposed De Gaulle. | could anly laugh. I told him 1d actually spent two months with OAS men years earlier. in Mont | ouis, but that Isvael was different, Fven ut times of the Toughest of disagreements, we were a family. An “lsuachi OAS” would never work, even if T had been crazy enough to contemplate such a thing. Which. T hastened to add, [ was not. There was another idiosynierssy | encountered in Arafidl. He was constantly “writing notes as we spoke. I didn’t mind that. But it did strike me as slightly diluting the kind of frankness and openness 1 would find in most af the one-on- one mectings | went an to have with Torin fesdens is Peres’s Forenm Minister Maybe he did it just as a kind of aide-memvite. But certainly in later meetings | had with him, it did have the effect to making me choose my words more carefully, That, I behieved, reduced the prospect of exploring more ereatively the boundaries of cach of our official positions. 11 also helped Arafat to argue, as he did on more than one occasion. that Rabin. or Peres, or whatever Israeli interlocutor he chose to name had promised him such and such. He always implica this was based on his writien record, though he never produced wy evidence to that effect. Ile also never seemed w have recorded anything that he had promised [sraclis. 1 tied, with only partial success. Lo engage sume of the other Arab forcign 282 ministers when we'd arcived in the banqueting hall. Tdid have a good talk with Ceypl’s Ame Moussa, and the foreign ministers vf Morocco and Tunisia. When {tried 10 start a conversation with Syria’s Farouk al-Sharaa, hawever, he pointedly, though politely, said he fell hut would nol he appropriate. President Assad had broken off Lalks with us earlier in the year, insisting that we first commit explicitly to honor Rabin's “pocket deposit” an the Golan Ileights. Still, in my formal remarks at the dinner, [urged bath sides to resume our elfort lo negotiate an Isracli-Syrian agreement. Sharaz’s response was. again. unencouraing. But 1 did notice, and take heart from, the fact that it was neither polemic nar overtly hostile towards Israel When | retuned to Ismael, | found that Peres, wo, wanted lo restart the negotiating process will the Syrians. The effort wok on fresh momentum after a meeting at Peres’s home in Jerusalem m early December, ahead of his visit ta Washington for talks with President Clinton. Hamac Rabinovich and T had cach met with hi separately a few weeks earlier to brief him on how the talks with the Syrians had gone under Rabin, and why they'd reached au impasse. We cmphizsized Assad’s insistence on a preemplive agreement on our leaving the Golan. Peres now came forward with a plan. 1 was the diplomatic equivalent of what the Americans. a few years later in the second Gulf War. would call “shoe and awe.” This was “dazzle and befiuddle.” As Peres explained it, we would flood Assad with proposals: not just on land vr security, but everything from water and electricity to tourism and industrial zones. Assad was in personal control of the Syrian side of the talks. The mere volume, range and complexity of the simultaneous cugagement Peres had in mind would, he hoped. dillce his focus on the Golan. “The best results are extracted from confusion,” he said. Having watched President Assad operate for vears, when 1 was head of intelligence und chief of staff, {said | was skeptical. 1 used the image of a bulldog. “Tt comes into your liviag room with one aim: t lock oa to your ankle. You can throw fireworks, cookies, balloons, a tasty bane. Butit's a bulldog, 1's still going to move another step toward your ankle.” For Assad, the ankle was the Gola. Tunderstood why Peres wanted to make a new effort to get peace with Syria. Obviously. it was something ta be desired in itself. It would transform the terms al our conflict with the Arabs, and maybe even bring within tach the hope of ending it aliogecher. But there was a political consideration as well. For all his other accomplishments. Peres had a record of repeated electoral defeat as head of Labor, This nex! lection wonld be the first held under a new set of rules. Instead of merely chosing lists of Knesset candidates, Isracis would cast two 283 votes: one for a party list and one for a directly elected Prime Minister. This would be a personal test, an opportunity for Shimon to build on the still-teauous achievement of Oslo and finally secure the endorsement of the Israeli people, It seemed, for a while, | muzht even busve i role. A few days later, Peres and | met again. In lsacli elections, the campaign manager is called head of hasbarak media and public-information planning. He told me he still didn’t know exactly when he would call the election. But he asked me to take on that role. Both Peres and [ proved to be right sbout the Syrians. The negotiations did resume, and two rounds of talks were held at Wye River. on Maryland's eastern shore, in December 1995 and January 1996, They did focus on the whale range of issues in an evential peace, just as Peres had hoped. and some progress was ade in identifying arves of poleatial agreement. Bul the bulldog never look its eves of aur ankle, There was no escaping the fact that without addressing the question of our silhdrawal from The Golan Heights, we werent going to gel to the next stage. Sv a decision had w be made. Peres. no less than Rabin. knew what the trade-off would be. Israel needed a series of ironclad security arrangements, and a genuine peace, Tather than just agreement 1o x cessation of hostilities. Syria wonld dennand w gel buck all, or a1 least virmually all. of the Golan. Peres now focused on clarifying, in his own mind, whether we should be willing to agree to trade the Galan for a peace treaty. Our key mecting look place in carly February, in the underground bunker in the 47rya. Peres asked Amnon Lipkin, as chief of staff, and our other top srenerals for a presentation an their view of the security arrangements required with Syria under u peace deal. They recommended thal Tract insist on keeping a sizeable part uf the Golan, as well as a range of demilitarization provisions which reached pretty much to the edge of Damascus. Id been asked tor my view by Rabm when | was chici-of-staff, Obviously. from a purely military standpoint, the ideal situation would be to keep the whole of’ the Golan Heights. No chief of staff was going to recommend pulling out. But I'd always added der: to withdsiw as pant of a peice agreement, wath ull its other likely hencfits, was nol a milifury question. 11 was a decision for the government. The relevant question for a chief of sufi was whether we could ensure the security of Israel if the government decided on a withdrawal, lo which answered yes. 284 T suspect Amnon would have said much the same thing. But that wasn’t the question he'd been asked. As the proceedings wound down, Peres looked glum. Maybe he was anticipating the potential leaks of army concerns about a Golan withdrawal if wee die get closer 10 a deal, amd the venomous political allacks he could expect from the eight. Bibi’s stated view on a deal with Syria at the lime was that we could get peace and keep the Golan. It was classic Bibi, spoken with verve and conviction es if simply saving it would make it true. When the presentation was over, Peres called us ino a small room is the bunker reserved for use by the Defense Minister. As Foreign Minister, 1 was the only cabinet member with him ulong with Un Savir, Peress senior deputy for peace: negotiations and several other Peres aides. 1 there had been i discussion, Twould have told him that as long as he felt the talks were progressing, he could ignore Ammon’ presentation, [F we didn’t get a deal, it would be irrelevant, If we did, the miliary could find ways tw deal with the securily issues. Bul he just looked at us and said” “We're going foe elections.” A few days later, the dae was set for May 29. 1996. Yet that would turn out not to be the end of Peres’s doubts ar difficulties. 11 wis only the beginning. 285 Chapter Eighteen The frst attack in the wave of Tamas suicide bombings destroyed & Jerusalem bus at 6:42 a.m. on February 25. 1996, 1t lef 26 people dead. and nearly 80 injured from nails and shrapnel packed into the explosive charge. The second wes nea Ashikelon. The bomber, dressed in Tsracli uniform. joined & group of young soldiers and blew himself up, killing ane of them, A week later, u third suicide attack blasted the roof of bus on the seme Jermsaler commuter roe, leaving 19 more dead. And on March 4, a 24-year-old Palestinian walked up to the entrance of Tel Aviv's busiest shopping center, on Dizengoff Street, detonated 30 pounds of explosives. and killed 13 people. At the bomb scones. bloodied survivors nd crowds of pedestrians surveyed a hellseape of twisted metal, shards of glass aud mangled body parts. While most Israelis were too shaken to worry about the immediate political repercussions and Bibi was careful, at least in the immediate aflerath, not 10 tey 10 score political points —Peres’s reelection campaign seemed to lie in tarcers almost before it had begun. ‘The attacks were nor a surprise. As ['d argued to the Washington think-tank udicnee before joining the goverment, the peace promise of Oslo had been assailed from the start by a new alliance of Islamist Palestinian violence: nizinly Mamas. and Islamic Jihad on the West Bank. They saw Arafat as a traitor ho had sold onl 10 smc. For them, the iss wasn’ just Iszacl’s capture of the West Bak and Gaz in the 1967 war. IL was 1948: they opposed any Jewish state, anywhere in Palestine. In a campaign of terror that made the first weeks of the intifada seem atmos easy ta deal with, they began sending sel styled holy warriors to murder Iscacli civilians, and sacrifice their own lives, in the expectation of Allah's rewards in the world to come. During the tio years following Oslo. they'd mounted ten suicide atacks, leaving nearly 80 Israelis dead. The attacks had actually stopped since the summer of 1995. Bul when the election date was announced — wilh Pores holding a roughly 15-per-cent lead in the polls — political commentators both in Israel and abroad began speculating about a resumption of terror. For Hamas, the election presented not just an opportunity fo kill mmacent Ismaclis but, by helping defeat Peres and Labor, perhaps to kill Oslo as well. Tiven before che bombings, our campaign was struggling for focus, energy and even purposes, beyond The wim of getting move voles han Bibi Netanyihu. Despite 286 BARAK £1 Peres’ assurance that I'd be the campaign manager. that hada't happened. 1 wasn't really surprised by that, however. When he offered me the job. [ wondered how he'd managed to clear it with much more established Labor politicians. It tamed au he hads’L Hamm Ramon, the veteran whom Ud urged Yitzhak to bring buck for the election, was pu in charge. Shimon did ask me 10 head a small advisory team which reported directly to him, but all the key decisions were taken at weekly strategy sessions chaired jointly by him and Ramon. 1 still hoped ww make the campaiga a eferendum on Yitzhak 's murder, and on the need w recommit Israel Lo democracy and dialogue over vitriol and violence, But Haim began with the assumption thar, given Peres’s lead in the polls, we should simply play it safe, ignore the issue of the assassination, and Uy to iguoe Bibi, loo. Le described it as asoceer match. We were leading by two goals, he 101d our first strategy meeting. The other side was never going to scare unless we serewed up. “To win, we do what all good teams do. We play for time. We kick the ball around. We kick the ball ino the stands. We wait for the final whistle.” wed, without success. to argue that we were underestimating Bibi. “He may be young and inexperienced in atsanal politics, But [ know him from when he was even yaunger, He knows how to analyze a task, break it down, work out a plan and execute it systematically and tenaciously. If we play it safe and don't define the campaign. he'll seize on every error we mike and he will define it.” Twanted us at least 1o comeel with Yilzhak’s legacy. 1 argued to both Peres and Ramon that we should promote Shimon as the candidate with the background. experience and vision fo tale forward what he and Rabin had begun. | also wanted us 10 echo a core assumption in all that YiLk did as a military and political leader: that peace was achievable only if Israel and ifs citizens felt secure. Even before the renewed terror attacks, 1 argued that we had to recognize that, much as Israchs yeamed for peace, many were conflicted and fearful about the Oslo process. T said our central campaign message should be bitachon ve shaton. Security and peace. “In that order,” I added. “We should tell vorers openly that we expect groups like Hamas to try wo launch uttacks. But they don’t was 4 secure Tscacl. They don'L want peace. Doi t play their game.” Yet the scale and intensity of the bombings threw everything ino crisis. After the bomb in the Dizengoff shopping mall, Peres called an emergency cabinet meeting at the Airy. Le knew that we had wo find a way to reassure Israclis we were getting a pip on the situation. We had got a start in our regular Sunday 287 BARAK £2 cabinet meeting the day before, by reviving an idea I'd supported under Rabin: to build a sceurity fence all aloug the edge of the West Bank, with a series of cantrolled erasing points for peaple and goods. Yitzhak had said no at the time, because he wis worried 1 would be seen as a de facto horder and undermine the idea of building coexistence. My view then, and even more 50 now, was hat we would never get to the point of negotiating a final peace with the Palestinians unless vee could stop at least most of the terror attacks before they happened. Peres, 100, had been worried about “undermining coexistence.” But now, he and the rest af the cabinet were so shalcen by the carnage Hamas had left that they approved the idea of a security barrier. At our kirya meeting. hours aller the latest bomb had exploded less than i mile away, Peres recognized we had 10 go futher. Under Oslo, we had begun giving the Palestinians control over internal security in Gaza and parts of the West Bunk. Since the new Tamas attacks, Arafat had been saying the right things. Aller the first bomb in Jerusalem, he'd phoned Shion Lo offer condolences. telling reporters afterward that this was “a terrorist operation. [ conden it completely. It 15 mol only weainst civilians, bus against the whole peice process.” Yet when it came lo action, we Saw 10 sign that he was willing, ready. ov perhaps able Lo crack down on the Islamist terror auacks. So Peres now announced that, if necessary in ander 10 detain known lerrorists, we would for the first ine send lsmuch oops back into areas where control had been handed back. If Arafat dido't act, we would On the political front. Peres did rer some pood news: President Clinton, anxious 10 preserve the progress he'd worked so closely with Yituk 10 achieve, organi a0 unprecedented show of international condemaation of the tersoe attacks. With Tgypt's Hosni Mubarak, he co-chaired a “Sunni of Peacemakers” in Sharm al- Sheikh with the purticipation not just of m equally concerned King Hissin, and of course Arafat, but leaders of Arab sates from North Africa to Saudi Arabia and the Gulf. The only significant holdout was Syria's [atez al-Assad. Ile objected became he said the conference wins too focused on Isael. As Foreign Minister, | accompanied Shimon tw the summit. A single day's meeting was never going to end terror. But it was unprecedented in the breadth of Arab engagement in an initiative that, as Assad had anticipated, didn’t just condemn terror in general. It specilically denounced the attacks being launched inside Isracl 288 {HARAK {3 T'd met President Clinton briefly once before, when he received Sycian chiefof- staff ikmat Shehabi and me after our Blair louse talks in 1994. But the Sharm conference provided my first opportunity to spend time with him face-to-face, When Peres and our delegaion were about 1o leave, a Clinton axde approsched and said the President had asked whether I'd like w join him on the Might back lo Israel. Though as surprised as I was by the invitation. Shimon nodded at me to signal it was okay, so | headed of for Ais loree Oue. Lspeut most af the brief Night talking to the President in the office space carved int the middle of the plane. 1 would later discover that he quite often tried to engage with foreign Teaders’ colleagues or advisers on overseas trips, and not limit himself to summit negotiations. IL eas part of bis voracious appetite for information ur insights which he believed were essential to get a rounded understanding of the complexities of the issues he was trying to address. Still, it was an extraordinarily fascinating 20 minutes. | got my first veal look at Clintons natal gifl for person-lo-person politics, as well as his mastery of both the detail and nuance of Tsrael’s predicament, and of the wider contlict in the Middle East. Looking straight at me, almost never breaking eye contact, he encouraged me to feel | ad something of value and importance to share with him. In fact, he created the impression that T was the first sentient, incelligent human being he'd ever met. Ie made no grand policy statements, Mastly, he asked me questions: what were the prospects of Arafel reming in Hamas aud Islamic Jihad? How were our velitions gomg with King [Iussein? What was my view of the chances of concluding a peace with Hater al-Assad, despite his boyeatt of Sharm al-Sheilh? 1f Shimon did go on to win the election, what new diplomatic opportimitics could he as president, and we, exploit in the search for peace? And, finally. what if Bibi won? I dare say this first meeting was more memarable for me than for the president, But it would turn out 10 provide a fonndation for ou jot effarts, ma Fes years time, W resolve the very issues we'd talked about on Air Loree Ove. PEE Though the summit restored a small opinion poll lead for Peres, that merely reinforced Haim Raman’s soceer-game stategy. | was more convinced than ever it wis wrong. Haim still wanted 10 ignove Bibi, bit | pointed ont this Gor al kes) one 289 HARAK 4 ceason, that was absurd. Near the cad of the campaign, there was going be a hoad- Lo-ead television debate. Tn the meantime, though Bibi might be many things, he wasn’t stupid, He was already telling vaters that while Peres was making deals with Arafat, orlinary Isractis were being eft to wonder where the nex! wronist would strike. Ue would surely ramp up the accusations that Peces was “weak on security.” especially if there was more violence. To assume that if we just sat back we would win seemed Ww me complacent and risky. Yet when | mentioned Shinton that a couple of our internal polls still actually had Bibi slightly ahead, he just laughed. “I have good polls,” he said. “Why should 1 believe the bad ones?” “Then, however, violence intervened again. It was not Hamas this time. Beginning on March 30 and escalating sharply 10 days haler, Katyusha rockets cained oni towns and settlements in northern Tscael by Iizbollah — the first sustained attack since the cease-fire in 1994, [¢ was pretty obwiaus that, like Tlamas, the Icanian-backed Shi'ite militia in Lebanon was not just lacgeting Israeli civilians, but Oslo, and Peres’s chances of winning the election. The last thing Shimon wanted was for tens of thousands of people in the north of Israel to be cower in sheliers during the final sieetel of the campanm, So mm April 11, he ordered a major military operation in Lebanon 1 wasn't party to fhe discussions about the operation. But the model chosen was similar to the one 17d drawn up im 1994: a limge-scale air and amillery wssault designed Lo hit Hizbullah hard, force civilians to flee and persuade the Lebanese and Syrian governments to commit to a US-mediated end 1o the rocket attacks Again, all of that happened. But not before a tragic accident which brought 4 storm of international criticism and hastened the end of the uperation. Au Isruchi special Forces unit was ambushed while providing laser tacgeting support for an air force strike. When it called in artillery support, four of the shells fell on a UN compound mesnr the 1.cbamese village of Quna, killing more thi 100 civilians seeking shelier inside. Peres phoned me a few hours later, distraught not just because the wayward artillery stike Bud laid us open to charges of “targeting” avilians in an operation designed Lo try 10 avoid doing so. Also. because the accident seemed likely to deal a further blow to his efforts to convince Israel's voters that he. rather than Bibi, wits the man best placed fo lead the country, “We're in trouble,” he said. Yet within days, it became clear that our basic campaign strategy — igaoe Bibi snd “Kick the ball into the stands” — was not going to change. T did make one last 290 BARAK 5 attempt to help put us on the political offensive, alter I was asked to record on of Labor's TV campaign messages. | knew what [ wanted to sey. I'd talked it over with the small group of campaign experts Peres had asked me to assemble alongside Rasmon’s main eam. Rather than ignore Bibi, {was poing 10 nse my position as his former commander in Sayeset Matkal, someone who kaew him well, to explain why Peres should lead Isiael. “How many of us can really understand what if means to be a Prime Minster?” 1 began. “As head of intelligence, and chief of staff, 1 have seen, close-up, what it takes to be a Prime Minister. It is not a game. We've had good Prime Ministers. Ben-Gurion, Peres, Rabin, Begm,., Ribi, we know each other well, from the days when yon were am officer under my command. A young officer, aud a good onc. ‘Prime Minister is the most important and serious role in this couawy. Bibi, it’s not yet you, We need an experienced leader, who will know haw to guide us with wisdom, strengil and seositivity. Shimon Peres is that man.” Ye we were never going Lo be able wo avoid cugaging with Bibi altogether. The face-to-face television debate between the two candidates was set for May 27, two days before the election. By Amencan stindurds, the format was fairly time. No direct exchanges were permitted, only a series of questions directed at cach candidate by a leading political journalist, Dan Margalit. Still it would place Shimon and Biba side by side. We spent two days prepping Peres, with Avraham Burg — an carly Peace Now supporter, former Peres aide aud Knesset member — sanding in for Bibi. Aveaham played the role well. anticipating the lines of attack Shimon would fice. But as [warched, {wornied that even he couldn't replicate one of Bibi's key advantages. During his tine at the enbassy in Washiugion, smd especially as UN ambassador. Bibi had become a [requent presence on American television interview shows. Always articulate. he was nov also an experienced. amd completely comfortable, television performer. In our debate rehearsals, Pees sounded well versed on all the issues. Yet T sensed his problem wasn't going to be the message, bur ce medium. Ie sounded a bit distan, unengaged. almost as if the IV debate wins something he knew he ad 10 go through, but which he thought slightly sullied the proper purpose of politics. Ta the real debate. Shimon seemed to convey the sense that merely being in the sume studio wath y pretender as raw and untested as Bibi was offensive. When cach of the candidates was given the opportunity at the end to ask a single question of the other, Peres didn’t even bother. Tle did come over as the man with much more 201 {TARAK i 6 experience, gravitas, substance. TT also had what was probably the best linc in the debate, saying that if Iseacli voters vere choosing a male model and not a Prime Minister, Bibi might indeed be their man, Yet Bibi was much the more polished perfonmer, and the more fooused. No aller what question Mangal ssked him, be almost invariably answered with the driving message of his campaign: that because of Peres. Israeli citizens were living in few, wondering where the next suicide bomber would sirike or the nest Katyushia would land. And unavoidably, there was another contrast as well: Bibi. who. aller all, was 26 years younger. projected greater youth, energy and confidence, When it was over, and Peres asked us how Te’d done, we all hemmed and hawed. Only Avraham Bury was prepared to offer a elon verdict. le old Peres that Bibi lind been the clear wiser. Still, it remained possible that Ramon's football-game strategy might work “Though Peres’s pall lead had been narrowing by the day. he was just ahead With 2 large number of voters undecided, however, Bibi pulled ane final wick out of bis campaign bag. Under Tsracli law. election spending is tightly regulated and nearly all campaigning is barred during the last 48 hours before polling day. Yet with ihe backing of wealthy overseas supporters, the Netanyahi campaym suddenly Mooded lsacl with blue-and-white banners under the slogan: Bibi. Tov la Yehudi. “Bibi is good for the Jews.” Would it swing tens of thousands of votes snnang he Onthodox. voters who were the mam tinge? 1 was impossible to say. But it seemed clear it wes going tw he a very close election. Thad worried for some time we might lose. That was why Nava and T had persuided Michal, our eldest daughter, to bring forward her wedding, She was marrying her teenage boyfriend, a wonderful young mn named Ziv Lolenberg, They had originally planned it for a week later. But we did want 0 tisk having it overshadowed by an election defeat. The wedding took place in a beautiful area of Tawrs uel gardens called Ronit Farm, north of Herzliya. 1 was how weddings are eant 10 be. full of smiles. good food and dancing. Near the end. Shimon showed up. As he walked over to greet us, one guest after anodher shook his hand. patted Im an the back, higged hiro, wished him hk. It was as iF all the presse and tension of the campaign had suddeoly Nowed out uf lit. Tle smiled, retuoned the ‘embraces, even joined in the dancing. When he left, T told him that he'd doe all he ould fo secure victory. and that | hoped the voters would make the right choice. “Ihe first exit polls suggested he was going to win. But our internal polling wis less clear. As more and more voles were counted, Shimon's margin inexorably 202 {TARAK i 7 aarrowed. Tt wasn't until the next morning that the final result was clear: Bibi Netanyahu had won. By 29,000 votes. Ifa mere 15.000 of the three million ballots cast had gone in our column instead of his, Shiman Peres would have remained Prime Minisicr. J kiiewe he'd be feeling crushed. Not just on a personal level, because this latest electoral defeat had been in was a direct, head-to-liead vate for Prime Minister. He, ike all of us who had campaigned for im, knew what was at stale for the country. 11 had bee barely six months since Rabin was gumned down in Tel Aviv's main square, by a fellow Israeli riding: a tide of hatred so blinkered that it could paint Virzhale who had worked all his lif fo create, defend and help develop the Jewish siate — as trailor, even 1 Nazi. All heesuse he hid decided 10 Tey 10 make peace with the Palestinians, at the price of ceding control of part of the biblical and of Israel. Bibi had gane through the motians of urging restraint, But politically, he had ridden their wave. Tt was hard nat w see his victory uver Peres as a triumph foc the ugly inwlerance and the venom that had claimed Yitzhak 's life. In policy terms. it was in large part a rejection of both men’s vision of an smal thal, while sil] ready to fight iC necessary, could explore compromise mn ihe search for the ultimate prize of peace. The last time Yitzhak and [ had talked, he'd been confident of defeating Bibi at the polls, and I do believe he would have won. But despite his differences with Peres, I'm equally certain he would hive wanled Shimor 1 win, not just for his sake but for Iscacl's. Thad got to know Shimon, 100, during my years in the Arye. Tn fact, be was the Labor leader who first spoke fo me openly about one diy movi inta politics. something Yitzhak wes always pusctilious in nou brouching before Ud lef the army. Shimon had also taken to including me — usually along with Yossi Beilin and Shlomo Ben-Ami. a bright young historian who would become cur smmbissador 0 Spain before entering politics himself in u coleric of “youngsiers™ he would bring along to meet visiting digaitacies fiom abroad. Tle occasionally invited me to chat about miliary and security issues in his and Sonya’s flat in Rana) Aviv. My personal es lo Rabin were stronger, of course. Aller joined the government, Shimon's and my relationship became slightly more circumspect. But since the assassination, some of the old warmth had returned. Not just as his foreign minister. but in discussions on wider questions of security as well, we worked closely together. 203 BARAK £8 Within days of the election, however, there was a new source of potsatial friction between us: Shimou’s futuse, and possibly mine, in leading our opposition ta Bibi and bringing a | abor government back fo power. PEE “The question of Peres’s ludership wis univoidable. Labor's constitution mandated a vole for pay chairman within 14 months of an election defeat. Bui the widespread assumption was that Shimon would run again. A little before midnight an election day, with the retums begmnmi: to show we might lose, | was invited to 4 moming-afier break fast by two scion Labor ministers: Fad Ben-Elieer, the an who bad delivered the table-thumping wasoing that the hatred un the fac-sight would lead to a murder, and Avraham Shoehat, Finance Minister under both Rabin amd Peres. Both had heen in the Knossel since the 1980s. Both were part of two of Peres’ cadicr. failed. election campaigns. Both now said that they weren't prepared to see him lead us into electoral batdle the next time around. “Everyone in the party nndlerstamids the meamngz of this defen). Shimon is done,” Shochat said, us Fuad nodded his ageeement. “You will have 1 go for the leadecship.” Though their endorsement was a surprise, it would be disingenuous ta pretend 1 Inadn™ been thmkmyg, at some stage in the future, of rummy far the party Iesdership. Bul my clection-campaign differences with Ramon and Peres were nol just for the sake of intellectual argument. T badly wanted us 10 win: both for Peres’s suke and the country’s, and to redeem and contmue all that Yitzhak had sacrificed. Despile my misgivings shoul some aspects of the Oslo process, {did belive ther: was a possibility of achieving peace with the Palestinians. T knew, rom my invalvement in the talks with the Syrians, that the outline of a possible peace agreement with Assad was sheudy in place. rank ly wasn’t confident that Bibi was the man to lead it forward. Yes, he was smact. Tle was ocganizationally astute. 1e'd been a good sayerec officer. Yer as I'd said it my TV spot, being Prime Minister required mie more than that. [was now an elected Knessel member. But 1had gone into politics in the hope of making a difference to how Israel confronted its defining challenges of war and peace. The prospect of spending the next few as a mere apposition foot soldier, making: speeches and sifting in committee sessions, 204 {MARAK 19 seemed to defeat the puepose of going into politics in the fest place. Still. bad no appetite for rushing into a challenge to Peres's leadership, both because it was bound to be difficult for both of us, and frankly because it seemed rash, premature and maybe ven umceossary. Bibi was beginning the negotiations to farm a government, and that process was likely to take at least a few weeks. Shimon had yet to signal whether he did intend to stay on. Still. when he invited me for u late-night chat at his apartment a week after the cleenon, 1 was concerned Jie might raise the leadership issue and [knew thal, iChe did, | would have 10 be ‘honest and open with him. “The conversation went very differently than I'd expected. After he'd poured ich oF us 1 whass of Armusgre, and offered me a plate of Sonii’s eikes, be spoke for a while about Bibi, though he could not even bring himself to utter the name. This man, he said, knew nothing about leadership, much less about running the country. He would be ontmnenvered, overshudowed snd ultimately controlled by the “real strongman” in the Likud: Arik Sharon. said I thought we were again underestimating Bibis strength, as well as the etfect of the country’s new electoral system, He was the first Prame Minister fo coy dircet, person mandate. That wned upside down the balance of power and influence in uur politics. As he assembled his coalition, the other parties. if they wanted to be in government would have fo deal with him on his terms, So, fo a much greater extent than before, would potential internal rivals. As we talked, T was struck that Shimon seemed cesigued Lo the election defeat, relaxed, more af ease with himself than at any fime since the start of fhe grueling campiig. hen, quite suddenly. he suid: “Rhu, [understand the mening of the election result. “You will have to take on the leadership. and lead the party.” Ile suid he didn’t plan to spend the rest of his years hanging around the apartment, He would remiin acave “worldng (or peace” but no longer in the party political arena. “1 understand the meaning of what has happened.” he repeated “1 will pass the Labor leadership forch to you, We should find a way fo da it quickly, and in the Tight way.” 1 was mesrly three in the worming when | lef. [was nol just swprised, but touched, by what he'd said. Shimon was new nearly 73. He'd had a life in our countrys politics, and in Fubor, stretching back to before the state, when he'd been a Bivored protéac of Ben-Gurion. Walking sway was going 10 be hard, was 295 {BARAK 10 touched a3 well by the fact that he had decided Lo “pass the Lorch” Lo me, someone more in the mold, and closer to, Rabin. But [ remained cautious, wo. When 1 pot back home, Nava, knowing where I°d been, was still awake. [ fold her everything that Sharon had sail. | old bier how extraordinary it fel to have the prospec, at least, of leading Labor in opposition 10 Bibi, without the need to confront, of to inflict personal hurt. on Shimon. But I added: “Tt seems a bit too good to be true.” It was. The nest mom, 1 joined other ministers and pity officials with Peres in lis office. 11 was as il our conversation & few hours before had never happened. Shimon set out his strategy tor Labor going: tarward. And the first thing he said was that the party needed to push back any leadership election beyond the mandated 14 mouths “1's toa carly,” he suid. He said we needed wo focus an lwo other strategic imperatives: 10 reconstruct the party. and consider the issue of Joining a possible “unity” government with Bibi, “Fough Bibi wen on lo form his government without us, in alliance with a aumber uf smaller Orthodox pasties, the idea of a Labor leadership chauge seemed off the agenda, ar least for now. In early August, | was standing next to Giora Finy the “political opertive™ Yitzhak bid sent to help bring me info his government, and a [riend of Peres as well = when Shimon rose Lo speak 10 the dozens of well- wishers at his 73" birthday celebration in Tel Aviv. He was at his old, self- confident best, Wath just a few thousand extra votes, we would have won the lection, bie said. He wes sure Bibi's coalition = coalition against peace” — would not survive for long. Giora, smiling, twrned tw me and said: “Tt doesn’t sound like a farewell speech. It seems like he's ready for the next round, He lost Iwvice: 10 Begin. He lost ounce to Shami. And only once lo Bibi. He's nol going to stop without giving it another go.” Another of Peres’s old friends. a few weeks later, urged me to press him on the mized lo step aside. 1'd become closer 10 the French Jewash biusingssmin Jean Frydman during the clection campaign. Since he had helped organize the fateful peace rally at which Rabin was shot, he felt wrongly, but powerfully a sense of responsibility for what hid happened. He wanted fo do everything possible to ensure that Rabin's political legacy, and Shimon’s, survived. He invited Nava and me to visit hin for a few days. When he asked about the birthday celebration, T told him what Peres had suid. “He's making a huge mistake,” Jean told me, “After every election, he gous through the same process. Always, he’s canvinced that nest time he will win.” said how I dreaded the prospect of being part of an effort to 206 BARAK 11 force Shimon out. But Jean said he'd been giving a lot of thought to everything that had happened since Rabin was killed. Tle fell T was the only poteatial Labor Teader who could defeat Bibi in an election and “bring back sanity ta Israel, lead it 10 peace.” He sand ie wins convinced that Peres’s lime had passed. “1 can say thet. Pm from his generation. Aud as a very close friend of Shimon, T will be the fisst in line to help you.” Farly in September, having let Shimon know through Giors and then phoning him dirculy. | declared publicly that | would he sunning for the Libor leadership. Though he'd thanked me for telling him beforehand, he said he thought 1 was ‘male a mustuke, and was still against huving a leadership election af all, That ‘madd his public respons fo my announcement puzzling. He went on fsrachi 1¥ and said he would wor be a candidate for Prime Minister in four years’ time. “The time fs come for u change,” he said. But while everyone toals faut to mean he was ceconciled to a change of party leadership as well, if luened out that we bad jumped the gun. Te intended Lo stay on as chairman. During the early months of 1997, Shimon and T held a series of late-night mectings a his apartment to thrash ant an agreed course. was a process hat wos hard for both of us, and hurtful for him. 1le was now al least reconciled 1 the inevitability of an election for a new party leader. it only because his protégé Yossi Beilin had also put has name forward. But he kept proposing to push back the vote. insisted that since the deadline under party rules was June 3, it was only sight Ural all of us abide by that. T do remember a particularly poignant moment from one of’ aur sessions, Pers had left the roam for a minute, and Sonia came in, “Ehud,” she sid 10 me, “keep your nerve. You're the only one who can tlc lo bim this way. Tle should have reticed from politics years ago. You'te the only one around him who tells him the ruth.” We ended np with a compromusc. Shimon acecpled that the keadership election would be held on June 3. 1 agreed that in the unlikely event Bibi decided 10 invite us into his coalition during the three months affer the leadership vote, Peres would sleet the Labor ministers, Our last meeting ended at nearly four in the moming, He old me he'd arranged a reception for the party leadership at 10 an, in barely six hours” time. Tle suggested we meet in his office an hour beforehand. didn't know what to expect, After months of discussions. 1 hoped he understood that | had wanted the process to go dilferenily. [had heen open aud honest with him throughout. But T kaew that, deep down, he still wanted to stay on. that he believed 207 BARAK 12 that his loug record of service should have cared him tha right, and that it would be painful for him to aceept that, by June, there would be a new Labor leader. He was relaxed and gracious when | arrived, We went through the details of what we'd agreed, and worked oul what cach of ns would say 1o reporters, What wane nes, as the party faithful filed in, was simple human nature, [ suppose. Seeing some of his oldest supporters. he had second thoughts. His comments to reporters afterward were mare hedged than what we'd discussed, Giora told me that aller all of us bad lef, Peres wemed to him and said: “Look wht Barak is doing: to me. What have yu been doing?” Giora, who had been a conduit between us at the very beginning of our discussions, replied: “You asked me ta bring Barak 10 you." Al which point, Shimou said: “OK. So probably [ made a mistake.” Ala convention of 3.000 pay activists in mid-May. a fow weeks before the leadership election, he made a final attempt to mitigate that “mistake”, Nissim Zvi, the secrctury-gencral of the party and i hmgime Peres ally, introduced a motion Lo vote hit into a tev post of party president. A couple of Shimon’s friends urged me to back the idea, describing it essentially as a ceremonial role. But [ feared it was a recipe for prolonging the agony. Whistever powers “President Peres” would have, the idea of two captaing va a ship would almost certainly mean trouble. [ was especially reluctant to go along with it because our particut ship had been in rough witers for so lang, Libor needed to steer a alm, decisive course toward the next election if we were going to defeat Bibi. What followed was one of the most painful spectacles I've ever witnessed. When Peres rose fo make his case for becoming party president, he said; “1 don’t wit powers. | don’t want honors. But Ualso don't want insuls. | anounced my decision to resign fiom the position of parcy chairman. Did someone push ine into it? Am | trying ta hold on to my job?” “Yes? many hindreds of the delegates shouted buck at him, Stung, he reminded the meeting thal it was he who had led Labor back from the battering it took in the 1977 election against Begin. In 1981, he'd helped us recaver i dozen of our lost seats. Fven so, becuse he hadn't succeded m forming a Labor government, people had called him a loser! “8al? Ani los?” he asked, using the nglish word. “Am 1a loser?” “Yes! Yes!" came the shours. 208 BARAK £13 Yet the saddest note came at the end. “1 apologize for being healthy, for not geting old according to plan.” he said, adding that even without the title of resident, he wauld keen working for peace. “There were three other candidates for party chuirman: Yossi Beilin; Ephraim Snch, the friend who'd heed the paratioopers” chief medic when we'd fought at the Chinese Farm in 1973, and at Entebbe to0; and Shlomo Ben-Ami. the academic and diplomat whom Shiman had raken along with Yossi and me to meet visiting Foreign politicians, and who was now also 1 newly elecied member of the Kaesset. When the vote came, it was assumed by most political commentators that I was omy to win, The anly question was whether 1°d et the 50 per cent of votes needed 10 void a man-off, where he outcome might be loss predictable. But 1 gol 57 percent against Yossi’s 28, with the remaining 15 percent split between Fphraim and Shlamo-Ren Ami, oes Now, we had fo put ourselves in a position to defeat Bibi and the Likud. Policy priorities were ultimately what would matter most: strong and credible steps to contiont terror and safeguard our security, allied with the leadership and will to try to negotiate a peace with Syna and the Palestinians: and, wl home, a recommitment 10 the values of sn open, Loken demacracy. But in al least one important way. | approached my new role as if it was one of our operations in Sayeret Matkal. or the need to reshape our armed forces when | was chicf-of-staff, My first prionty was to pu in place the practical foundations for a successiul election challengs: agains. Bibi. Through Jean Trydman and other business supporters with the means and the desire to help, my brother-in-law. Doron Cohen, assembled sufficient funding for us lo begin engaging with the stmicgists who had helped deliver leetorl sees for a trio of other centre-left political leaders overseas: Bill Clinton. Tony Blait in Britain and later Gerhard Schroeder in Germany. My main carly political focus wis on holding Bibi and the govermnent to account in the Knesset, shove all on Lhe torturous process of ensuring our sceuily while implementing the West Bank redeployment agreed in Oslo IL We'd made a small stat under Rabin and Peres, but the three major withdrawal phases duc in the 209 BARAK 14 five-year interim period had yet 10 begin. Tn vo respect, [had some sympathy for Bibi's predicament. The reason Id ried w get Yitzhak to slter the terms of Oslo 11 was that it required us to hand back control before we knew whit a “permanent statu” pea deal wonld look like. Bul where my sympathy ended was in how Bibi handled the situation. Despite my concerns about the way the Oslo process had been designed, I never doubted thar killing it off would be by far a worse aliernative. Bibi had been elected to fead Lssael. lstcad, be acted as if he was playing some sort of pinball match, Tipping the ball fist one way, then the other, with 10 abyious aim beyond keeping it im play and. where Oslo was concerned, simply stalling for time. Rather than setting: our any vision of where he hoped to move the negotiating process, he seemed mare eoceried with keeping the right- wing of Likud and the smaller, even more extreme parties from turning against him. In late September 1996, Bibi and the Likud mayor of Jecusalent, Bhud Olmert, decided 10 go ahead with the festive opening of an archeological tunnel that provided access to a larger portion of the Western Wall of the ancient Jewish empl. 11 wns i decision that, under both Rubin umd Peres, we'd delayed out of concern about inflaming teagions with the Palestinians. As Shimon rightly said publicly after the three days of violence that followed, we understood that, ata minimum, it wonld need to be coovdmated beforehand with Arai. As the nest spread into the West Benk and Gaza, there were media warnings of a “ew intifud," the difference this time being that the Palestinians newly established police liad entered the fray. By the time urzent US diplomacy, our efforts and Arafit’s, brought it wo a close. 25 [sracli soldiers and nearly 100 Palestinians had been killed. Tle did not stam the brakes altogether on the American-led efforts to ‘mave ahead with the Oslo. In early 1997. in fact, he and Arafat reached a separate agreement on the eriically important question, and potential flashpoint, of Hebron, Tt stipulated that about 80 percent of the area would be under Palestinian authority, with Israel retaining: control and responsibilicy for nearby settlements and key security points, Despite right-wing and settler opposition, it was approved by a wide margin in the KnesseL, with Labor's backing. Buta few months later. in the spring of 1997. Lamas launched a new campaign of suicide bombings in shopping. areas of Jerusalem and Tel Aviv, leavmiz 24 people dead. While not suggestmg that Bibi tak the hussian cost of tenor Fighily. he did nse the wack fo drag out further US-mediated talks on the details of implementing the Oslo I redeployments. 300 BARAK £15 By November, even his Foreign Minister. David Levy, was making noises about quitting. Tle said it would be a waste of time to stay in the cabinet if it was going; to bring the peace process to a ult, 1 warned Bibi, hoth in the Knesset and in i senes of specehes, about the slemative on the Palestinian sid if those who wanted a negotiated peace had nothing but stalemate to show for it. And lives, { insisted, were at stake. Both through closed-door sessions of the Knesset's security and foreign 2laics committee, and my own contaets in military intelligence, | was convinged that the result would be a second. much more deadly, intifada. Not with Molotov cocktails, but guns, and suicide bombs. Iwas not out to score political points in keeping the pressure on Bibi to move forward. In Fact, | snnounced that if Bibi did go ahead and tualize the lems for our Oslo redeployment, Labor would once again provide the extra Knessel votes needed for him ta get it approved. Farly in 1998, he sent word that he waned Lo Talk. The message came through Yaakov Ne'eman, his Finanee Minister and & prominent lawyer whom | knew and liked. He and [ held an exploratory meeting at which he proposed talks with Bibi an the prospect of ity govermnent thal would help moves the peace process forward. | said I'd talk, wil one proviso: the discussions would be genuinely secret, with no leaks. 1 was not prepared to engage in political gamesmanship. In May, Bibi sent un assurance of confidentiality through Ne’emun, The first of about a half-dozen mectings came a few days later at the Prime Minisier’s residence in Jerusalem. Then, we shifted venue. meeting at a Mossad-owned villa noth of Tel Aviv. 1 brought along Baugie Herzog, a bright youny lawyer, and Labor Party member, sho was working in the same law fin ind Neen. [wes by no means clear we'd agsee on a unily goverament. To my amusement, if not altogether Lo my surprise, 1 got word that Bibi was putting out separate political feelers to Shimon Peres. Bul before long, it became clear these was a specific political motivation behind his approaching me. Tt was indeed the peace process. But il wasa't the Palestinian peace process. something Bibi still clearly wanted to avoid as much as Iuananty possible. 11 wis an aitemp lo engage with Syria. He asked me about the talks under Rabin aud Peres. and my views on the possibility of a deal with President Assad. Tle lso wanted my assessment about whether fhe nny could work out amangements to sifeguard the country’s security if we handed hack most. if nol all, of the Golan Heights. 17 so, what kind of security arrangements. with what timeline? We met through the summer, as the 301 BARAK {16 talks with the Americans oa the futher West Bank redeployments meandered ahead. We also discussed in detail how a unily government would work. We agreed it would be presented, like the Shamir-Peres partnership in 1984, as a cross. pay response lo un important challenge for the country: in this case, security and the peace process. | would be both Defense Minister aod “Viee-Prime Minister”, with the understanding that Bibi and I would jointly discuss all major issues before jointly agreeing to bring them to the full cabinet But in August, the talks ended, afer news of our talks finally losked. 1 immediately phoned Ne'eman. I reminded him that at the outset, I'd said that would mean the discussions were over, He did call me buck later in the day to say Bibi insisted that he'd had nothing to do with the leak. My ness was thal the source was my old comrade from the Chinese Farm, Yitzhik Mordechai, who had Dresumably heard tht Ril was ready to make me Defense Minister as part of a unity government. There wes, of course, already a defense minister: Yitzhik. 13ibi's idea to reopen efforts 10 pet peace with Sydia dida’t last either. Although 1°d learn of this only a few years later. lie’d approved a visit to Damascus by the American Jewish businessman Ronald Lander to meet President Assad. The visit made it elear to Bibi wha sucecssive Israeli leaders had learned: a deal might he possible, but only if Ista] was willing to commit in advance to pulling out of the Golan, Assad told | ander to come buck to him with u detailed map setting out Bibi's view an defincating the lsracli-Syrian border under a peace agreement. Though no one in the cabinet kaew the initiative was underway, Bibi realized that before sending back the map Assid wanted, he would need to tell the two senior ministers directly affected: Arik Sthron, who had replaced David Levy as Foreign Minister: and Yitehik Mordechai. Both of then: said no, with Yithik pointing out that a signed map would inevitably become part of the negotiating record. It was a step tha mn unre negotiations, could not be undone. Bibi's coalition was now creaking. 1 he Syrian option was off. David Levy had already jumped ship. Yitzhik, increasingly concerned about Bibi's delay and drift an Oslo 11, seemed to be think of leaving ws well, Right wing ministers and Kuiessel members were uo happier: they opposed even the slightest prospect of movement on Oslo. Tn October, Bibi did finally try 10 seize the initiative, ITe wrapping up the redeployment details in summit with Arafat and C lmton snd Aral in Wye River. Bul as soon as he got hack home, he started backtracking, rather than risk facing down his right-wing critics in the cabinet. Implementation of 302 {BARAK 17 the deal was due 1 begin in cacly November, but he kept putting off a vote in the cabinet. When the vote came, on November | 1, Bibi squeaked through by a margin at 8 104, but with five abstentions, That meant less fhun half of his ministers had vaied for it The casy past fo his was Kuesset ratilieation, since [had commiued Labor to supporting Bibi on any move towards continuing the peace process. The day afer the Knesset's vote, Bibi won the cabinets clearance for actual implementution to begin, But it didn’t. With hard-liue ministers threatening 1o bring down the ‘government if ir did. Bibi again stalled. That was the turning point. I'd made it clear our parliamentary support would remam far as long as itn moved ahead with what had been agreed wl Wye River. 11 was not intended ws a blank check, or an offer tw prop up a Prime Minister who now seemed 10 be looking for any way possible nor to implement the agreement, My key ally in what came next was Haim Ramon. Despite our differences over the disection of the Peres election campaign, we had become effective parliamentary parmers. He had a depth of political experience and knowledjze T still lacked. While | found fhe detisils of how the Knesset operated arcane and often tiresome, Haim knew all of iL instinctively. When it cane 0 the need for discreet discussions or bargaining with other parties. not only could he draw on his personil relationships with Knesset members across the party divide, He hud the additional advantage of being able 1 avoid the seruiny that would follow a direct approach from me. Before Bibi had gone to Wye, ITaim and T had discussed how we might move fo force early elections. The peace process, and the country, were drifting. "There seemed no point in wailing, if we conld be confident of lining up the necessaty votes among the growing aumber of others who were also convinced Bibi should go. After the Wye summir apreement. 1 put all that on hold. But now that Bibi had shifled nw reverse, | told Haim 1o resume his eiTorts, In carly December, he told me he had enough votes for a no-confidence motion, under his name, to dissolve the Knesset and pave the way for early elections, The axe fell on December 20. Bibi hud lost the support of the nght-wing, who winfcd Oslo ended altogether. Le liad now lost me, too. 1 felt his approach to the peace process was leaving Israel rudderless. The way we were heading. we would not Just forfrt ny potential benefits from Oslo. We would be leaving u political und diplomalic vacium #1 a time whe a serious new explosion of Palestinian violence was becoming ever more likely. In the Knesset debate, Bibi made one final bid to 303 {BARAK 18 save himsell: by suggesting a delay of 72 hours for talks on a “unity” government 1 said that [ was all for unity. But 1 ceminded him that, time afler time, we'd saved his government in order to continue the peace process. We could no longer help out a gavenmment thal is nol interested in upholding he Wye agreement, but only in its political survival.” The vote of no-confidence went against him by the yawning margin of 81 t 30. with nine Knesset members abstainmg or staying away. A few days later, the date Tor the election was announced: May 17, 1999. 304 BARAK {19 Chapter Nineteen A few hours before Haim Raman introduced his no-confidence resolutian, he came 10 see me ia my office in the Knesset. Ue was worried. Not about the vote, ut about what would come after. “Ehud, I'm sure we can topple the government.” he told me, “But anly you know whether we're ready whether you re ready to defeat Bibi in an election.” “Tm ready.” T said. “We are going to win” Few agreed. In fact, there had been times during my first year-and-a-half as Labor leadee when I wondered if I'd be able to hang on w the job. 1 was in charge ola party whose grassroots were on the lefl. 1 was, by intellect and instinct, a pragmatist and a centrisc. I did share Labor's vision of a socially just and demoeratic (sracl. Especially afler secing far-right rabbis cg on [he Ganaticism that ultimately killed Yitchak Rabin, 1 fel stroagly that we needed to separate organized religion from our day-to-day politics. But I'd been raised with a deeper respect for aur Jewish traditions than many on the left. Right afer Yitzhak's murder, I'd gone 10 sce Zevulun Hammer, the leader of the National Religious Party. It had been part of both Labor and Likud governments ever since 1948, though not Rabin’s. The NRP, too, had been drifting steadily rightward. But it still basically subsetibed the idea of # strong. democratic Israel under the cule of law. | wanted to briny: the NRP back into the government under Peres, as part of the widest possible political alliance against the assassination and the campaign of hatred thi had fostered it, Sadly that didn’t happen, in part because of the anger against all Orthodox politicians after Rabin’s murder. Yet in my readiness to engage politically with Orthodox leaders who did not reject the very idea of peace negotiations whether in the NRP, or the mereasingly influential Sephardi religious party, Shas — | was outside Labor's mainstsan, and its comfort zone. On my approach to peace as well. differed from many on the left. Though I was determined to pursue any realistic avenue fo negotiations, | was convinced that security considerations had 10 be paramount in what we were prepared to give up or accept in negotiations. I was cautious about ceding too much too soon, in case the Palestinians or the Syrians proved either unequal to. or uninterested in, making the hard decisions required for peace. That was am approach with, Hike Yitzhak 305 BARAK 20 before me. provoked more lefl-wing parties ike Merete Lo suggest that I(T really wanted peace, I'd be ready 10 give away more, and more quickly. My position wasn't helped by the way 1 had come over in the media during my first months as Labor leader, A number of newspaper commentadors wrote thal while they found talking with me stimulating. | seemed to be operating in a world af my own, either unable or unwilling to give straight answers and a single, clear message. They were night about that. If asked a question, especially one which abviously involved in issus of nuance, ny instinct was nol Lo come up with sound bite. It was. as best 1 could, to answer fully and accurately. The difficulties that could sometime cause hit home in an inferview with a leading lsrachi journalist in the spring of 1998. He asked how uy life might have wrned out if 1d been bom and raised not as a kibbutznik, but a Palestinian. 1 answered: “Al some stage, T would have entered ane of the terror organizations and fought from there, and later would certainly bave tried Lo influcace from withia the political system.” 1 did hasten 10 add that T abhorred Lerrorists, describing their actions as “abominable... villainous.” But that was lost in the political stom that followed. All I'd done was amvsawer as honestly | could. What iF 1 bad been one of the Palestmim babics in Wadi Khawase, but with the same mind and same impulses that had defined my life as an Israeli? I assumed that instead of becoming an Istaeli soldier and politician, | would hisve become the closest thing to 1 Palestinian equivalent. Sull, as even my brother-in-law, Dorou Cohen, Wold me when he phoned a couple of hours later. it was not the most astute thing to say as a potential candidate for Prime Minister. None of this might haves matiered if 1d ben able 1o show 1 was bringing Labor aearer to defeating Bibi. Bul the only measure of progress that the media paid attention to was the opinion polls. Briefly. in late 1977. 1 id pull ahead, during the period keding up to Bibi's agreement to pull out of most of Hebron. nt for mich of 1998. T wes suaniog behind, and questions about my leadseship surfaced publicly by the summer. The media commentators spoke of the need for a Labor “Nol Why, fier i full yeu ws leader. had {filed 1o deliver a? FE 308 BARAK /21 There was a part of polities for which [ was natally suited aller my life in the acmy: Lo plan an operation, prepare and execute it. An ability to get the lic of the Tand, assess your own and your rivals’ strengths and vulnerabilities, and to win. And he lic of the and” sinuck me as more cneowging than nny beach commentators believed. When | became Labor leader, [didnt expect Bibi w fall anytime soon. Bur I believed it was inevitable that at some point he'd have to make tough choices about the peace process, and | doubted his coalition with the more right-wing Orthodos partics would survive. | also tok encouragement from the fact that the political winds in other develaped democracies seemed to be blowing in our direction. Bill Clinton had won in the United States. In Britain. which had a parliamentary system uch closer Ww [sracl’s, Tony Blaic, as keader of a party renamed as New Labor, had ended eighteen years of Conservative rule and swept ta victory. Behind the scenes, | immediately made sure that, wich financial help from Jen Frydman and other supporters, we began the practical work of leaning from the experience of center-left parties in other counties. Within weeks of my election as Labor chairman, 1 used my acquaintance with a Bratish Jewish businessman named Michael Levy lo see what lossons our shor pacty might lear from Tony Blair's. Levy had been an carly supporter of Blair and persuaded che Prime Minister to welcome me through the famous black door of Number 10 Dovwnmg Street. Aller chatting in the font hallway, the British Prime Minister led me into the back garden 10 discuss how lie had refashioned his pany and brought it back into government. In addition to modifying or abandoning rigidly lefl-wing positions that most British voters had rejected, he had created a formidable campaigning team usider au ally and adviser named Peter Mandelson. When I asked Blair whether it would be possible to meet Mandelson. hie said he couldn't “give me Peter.” But he did put me in touch with Philip Gould. the polling expert and strategist who had parmezed Mandelson in designing and running the election campaiga. ‘We met at Labor headquarters in Milbank Towers so Philip could show me the “ir room” — snodelled, in part, on Bill Chinlon’s campaign operation — from which the victory had been planned and exceued. IL was a lage, open-plaa space, nothing like the warren of offices and conference rooms from which Labor in Israel operated. Pride of place went to an advanced computer system, fhe heart of a “rebuttal unit” whieh charted every statement fiom the Conservative Party 50 il could be answered, neviralized or used to adjust Labor's ow campaign. I was 307 {BARAK [22 steuck by bow diffevent the approach was from our campaign for Peres. As T filled my notebook with the details, Philip added a final bit of advice. “IF you want to win, have it run by the best professionafs you can tind, Not politicians. They always hive personal agendas. Focus is everything. Distractions md arguments and infighting can be fatal > Philip recommended one professional, in particular. to get us started: Stanley Greenberg, the pollster who had advised not anly Blairs campaign, but Clinton's, Duron used his coutaets in New York to put us in touch nol uly with Greenberg Tut the straregist behind the Clinton victory, James Carville, and another leading Democratic Party consultant and speechwriter, Rob Shrum, We begun working with all of them well before the no-confidence vote in the Knesset. Philip bad » wondeufully British understatement and reserve. Stanley. with his eyeglasses and demeanor foo, came over as slightly professorial, With Rob, it didn’t take long to understand why he was such a gilled specchwriter. TTe loved words, especially the way they could be used Lo inspise a connection with important campaiga themes: above all with the idea of hope. and new beginnings. Carville was the human quivalert of a volcano. 1 he badn’t been a campaiin shdegist, he conld lis made a living as a hybrid of a cowboy and a stand-up comedian. But they all shared the easy. infectious self-confidence of people who were very pood at what they did, nd knew il. Whe 1weut to New York with Doron to meet Carville in Feburary 1988, my confidence as Labor leader was taking some [airly hard knocks. But from the moment he walked through our hotel-room doar, it was impossible not to like him. He showed up in a T-shirt and lenis sneakers, walked straight seross the room, slouched iato a chair and said: “General Barzk, [ don’t get it. You're a kaown public figure, with a erear mind and a great military record. It's already been a yeur-andachial sine lsrael gol Netanyahu What hive you done To go afier hin? Why haven't you gone on the attack?” Te said it was Lime (oc me o wake up. and change tack. “Can you run through your stump speech for me,” he asked. molianing me foward the center of the room hke a film director. “1 don't have one” Usaid. To which be replied briskly that | should have had one months ago. When Stanley paid a prelimmary visit with Philip to Israel, they. too, urged me. 10 sharpen my message and py more wiention 10 my ime with The public. 308 {BARAK 123 Stanley was worried by polling data that suggested most Tscaclis saw Bibi as “trong” T argued that strength was one area where we wouldnt have to worry “No way, in a campaign, he'll end up coming over looking stronger than me. Stanley seemed not entirely convinced Both in “streaglh” and other ways, 1 think my background did prove au advantage. The 33 years ['d spent in the military had given me a singleminded determination ta set goals, follow throngh und achieve them, After Haim Rimon came 10 my office before the no-conlidence voi lo ask whether | was sure | wanted to go ahead, and 1 answered with an unhesitating “ves,” Haim had told a couple of reporters: “Barak bis bulls of steel.” In feuth, 1 was puzzled he'd even asked me. As when | was in uniform, it would never have ocenrred 10 moe 10 ask him 10 try 10 line up the necessary votes if T hadnt thought it through and intended ta go ahead with it, Still, my military buckground was not always an asset as | found my foc! as party leader and prepared w take vn Bibi in the election campaign. In searching for the fools. the structure, and the people [ felt would give us the best chance to win, sometiniss fife lo pay dic atlention tw the pirty’s existing apparatus snd instiwtions. | his alicnaied 2 number of established Labor politicians, eventually including Haim himself. So as the campaign approached 1 tried to shore up my ties with the party establishment, | deaficd in Bougie Herog fo act as my regular liaison with keading figures in the party. | was carcful to clude a number of Labor politicians in our campaign team as well, though, as Philip Gould had recommended, | made sure they didn’t actually run it. “The closest equivalent fo the role Haim bid played in Peres’s campiign went lo a young businessman. PR professional and Labor supporter named Moshe Gaon As spokeswoman, we brought in someone wha, though she'd been a messenger of doom during the Tre chim controversy thal engulfed me before joing Rubin's government, had undeniable experience and ability which | valued and respected: Yitzhak’ former media aide Aliza Goren, As campaign coordinator, 1 chose Tal Silberstem, who ul the time was in charie of 2 citizens” group called Dor Shatent Aoresh Shalom: “A Whole Generation Demands Peace.” [relied on frequent, less. formal input from political friends whose judgement I had leaned to trust, like Fitan Haber and Giora Eim, Also playmygz a key role wis a gronp of four young women, led by Cina Angel, a successiul architect and # former soldier in Sayeret Matkal. She built from scratch an army of nearly 20,000 volunteers who helped 309 BARAK £21 organize events and contact voters duding ihe campaign. We outfitted ous own war com in an upen-plan floor of offices on the edge of Tel Aviv. Philip called it “Milbank South.” As arganizational head of the campaign, | chase Chagai Shalom, An industrial engineer by training, he was a reserve amy general who, when 1 wis chief of stall, had been in charge of the logistics beach of the military. | gave him Sayeret Matkal backup as well. in the person of Danny Yatom, my longtime friend and former sayerel deputy. vee But all that was process. Winning ov losing would come down to how our message, our ability 10 forge alliances, and my own personal and political appeal. ‘measured up against Bibi, “The new system of separate elections for party and Prime Minster meant thal in arder 10 win a majority. | would need the support of voters outside Labor as well. set aut to establish a broader movement, a biyg tent under which a majority of Israchs could coexist politically. {realized this tisked provoking ager mony some Labor activists. But [wanted 10 convey lo voters that | was reaching out Deyond my core party constituency: to “soft” right-wingers nearer the political center; lo the Sephardim who since 1977 had overwhelmingly voted Likud; to the rowing number of Russian immigrants who had helped Bibi defeal Peres: and to those among the Orthodox who still subscribed to wlerance and moderation in the mold of the old-style National Religious Purty in the first few decades of the state. “Though the candidates on our Knesset election list would all be from Labor. | ran the Prime Ministerial campaign under the broader banner of Yisrael dai = One Israel 1 envisaged it as an alliance of at least several differen parties with Labor at ils canier, began with Bibi’s jeuisoned Foreign Minister, David Levy. Te was a Moracean-bom 1950s immigrant whose career had begun at the jrassroots, in the narfhern town of Beit Shean, but who went on to become a key prt of Begin's victory in 1977. The leading Sephardi figuse in the Likud, be was at one poiat mentioned as a future leader. Many Israelis, especially on the lef, now portrayed tm us i figure of ridicule, But I'd always had a higher opinion of him, During the 310 SMARAK 725 1982 Lebanon War, with two sous fighting va the geound, he'd been a rare voice of common sense, aod caution, in the Begin cabinet. Pd also seen him operate in Shamir's inner security cabinet, when I would come, us deputy chief of staff, to present military operations for wpprovl. {remember one oceasion when an air Torce general laid out the details of 2 planned helicopter-borae mission into Lebanon. 1 added a few remarks in summary. Raful Litan and Arik Sharon were both ministers. Within seconds, they were peppering the general and me with questions. Why were the airerafl taking one route north instead of another? Why nat closer to Mount Hermon? Shouldn't they fly lower? Levy interrupted. “Gentlemen,” he said, “we are not in company commanders’ course. We're in the inner cabinet of the government of Israel. We have a chief of staff and other ‘generals and military professionals. It's their job to decide the operational details. Our jab is to balance the reasans for doing: an operation against the risks as presented W us.” Tet with him in the Kaesset cafeteria before Bibi went off to the Wye River summit. Levy now headed a small breakaway faction trom Likud called Gesher, Hebrew for “hridge.” Withont explicitly smggesting we join Rees, | explained my hope to run my eventual campaign foc Prime Minister in alliance with & few other parties. T told him 1 wanted to make my candidacy a legitimate choice for voters Trom the center-right, the Orthodox, as well ws the Russian community. 1 took napkin and drew a big umbrella Lo illustrate what | had in mind. He said he understood — though he did tell me to make sure I tore up the napkin. There came a paint, at the end of November when it looked like my overture had failed, Scampering for a way 10 shore up his coalition, Bibi ried to lure Levy into the fold back by offering him the Finance Ministry. But with resistance fiom other ministers, Bibi broke otf the talks with Levy. leaving him humiliated and furious. [ met with him several mare times, and we brought in Gesher as our first “One Tscael” partner. The second to join us, early in the new year. was a small religious party called Meimad. inspired by an openly pro-peace Orthodox rabbi named Yehuda Amital und melodie a farmer Chief Rabbi of Norway, Michael Melchior, By the end of January 1999, several moaths before the real campaign. | was feeling better about where we stood, in part because of a series of hits Bibi was taking from former friends and allies. The first salvo was fired by Misha Arens, who had helped engineer Bibi’s nove into vational politics. le announced he was ‘going to put himself forward for the Likud leadership before the election, saying 311 {BARAK 126 that he and others were convinced Bibi couldnt win. A couple of weeks later, Yitehik Mordechai seemed on the verge of becoming the lawest of Bibi's ministers ta resign, He was openly flirting with the idea of joining a new centrist party thar Tised been fovmmed by Likud’s 1am Meridor. Bibi struck buck wath iw nxinre of subtlety and venom. Le [iced Mordechai. accusing him of being driven by personal ambition. Then he offered the Defense Minister's job to Misha Arens. Yitzhik did join the Center Party. as did Amnon 1.ipkin, who had ended his term as chict-of-stalT and with initial opinion poll numbers suggesting he'd do well, even briefly entered the race for Prime Minister. Now, he endorsed Yitzhik Mordechai mstead: 1 man not only with strong mulitary credentials, but of Sephardi backgrond und religiously observant, aud a proven politician nd cabin! minister Tt was clear that he would be going aier many of the same votes [ needed 10 win That situation wasn’t ideal, fo put it mildly, But all [ could do at fhis stage was 10 pus onr own campann house in order. | hoped iat ie ran the campaign expected, there wouldn't be a nuw-ofl PE At the start of April, the final list of candidates was set. There were five. [n addition to Bibi, Yitzhik und me, Benny Begin had decided to rm on the right, Alsorin the contest was Knesset member Azmi Beshara, the first Israch Arab citizen to se<k national office. ‘When we chose “One Israel” as the name of our campaign alliance, it was not meant just as a catchy phase. Though now a half-century uld, the country had rarely seemed so diverse, and in many ways divided. Tt was not just the old fault line between Labor and Revisionist Zionism that defined our politics, or even the Ashkenaz-Sephardi yulf that had prodammated since the late 1970s, There were new, younger, more assertive. more right-wing and more pro-setlement voices among the Orthodox. There was the contrast between the overwhelmingly secular, nalitically and socially fiberal, and culturally Western Tel Aviv, with its ively cafés and restaurants. and the constellation of wealihy suburbs to the north: and smaller Israeli towns and cities in the interior, Jerusalem as well. not to mention 312 {TARAK i 27 the settlements on the West Bank. Since the fall of the Soviet Union, hundreds of thousands of Russians had also flowed into Tsracl. Most were Jowish in culture mare than religious observance, but they were instinctively inclined to support wndidiatos — Rabin in 1992, und Bibi the last tine around — who they felt were likely to take a tough line in any peace negotiations with the Arabs. Twas never going to get the backing of many West Bank settlers. or of core supporters of the Likud and parties even further 1o the right, But would need to make al least some dent in Bibs hold on Le Russian voters who had supported him by a wide margin in 1996. 1 focused first on Yisrael Ba “Afivat, the main Russian immigeant political party. 1t had been set up by the iconic Soviet-era reficvenik Nata Sharansky — or, as he was then known, Anatoly Sharansky. He'd been an ally of Andsei Sakherov. an outspoken human rights advocate and, until be was finally released and allowed to leave in 1986, a political prisoner in the gulag. Though Natan's pacty was not going to offer 2 formal endorsement for any candidate, T met with him to press the case for “security and peace.” the message Td tried to advance with Shimon three years earlier. and co emphasize the need to bring unity and stired purpose back lo the conniry. Though © think he world have been receptive anyway. it didn’t hurt that he. like me, was a mathematics graduate ~ from Moscow's Physics aud Technology Institute. Ile was also a chess alicronado. When 1 was rash cough lo face han eros the board, as [recall i took him all of five minutes, and seven moves, to checkmate me. But Talso made dozeas of visits to Russian community groups, and met with dividual families whenever [ could, Often. 1 found myself talking ta older men snd women wong the immigrants about the military details of the Grea Patriotic War, as the Russians called World War Two. On a number of ocessions. accepted the invitation to sit down and play on a sitcing-room piano. I think the first time [ ont sense tha ny of this might be having an impact was in quote from 1 Yisrael Ito’ Aliyah official in ao Tssacli newspaper. Though still stopping short ofa fornal endorsement, the official was quoted as saying: “A month ago, young. Russians thought Barak wees a boring, keN-wig soctalist party leader who docs’ Took good on TV and mumbles a lot... Today. they see him as a high-ranking Israeli general who knows how to play the piano. The Russian immigrants like strane, cultured people.” Except far the bit about mumbling, 1 couldn’t have wished for more. 313 {BARAK 128 The aes key moment in the campaign involved something T did sos do. This Lime, the Israeli television debate eame earlier in the campaign, a mouth before the election, Bibi, Yitzhik Mordechai and [were all invited, as the three main candidates. But 11old the TV people had a conflicting personal engagement. | figured 1 had nothing to gain by going. To join a three-way debate risked creating the impression this was a gemine three-man race. and I still held out hope it would come down to just me and Bibi. Besides, | thought a debate between the other two would help me. Yithik knew Bibi well. He had served in Bibi's government Though nat a natural orator, he was always forthright, and often pugnacious, in making his points. And he couldn't stand Bibi. Unlike the 1996 debale, this time there was a knock-out blow. and Bibi was the ane left on the canvas. Tt was a bit like Senator Lloyd Bentsen’ killer riposte when Republic vice-presidential candidate Dan Quayle compared himself to John F. Kennedy in their debate, a few months earlier: “Jack Kennedy was a friend of mine. Seoalor, you're no Jack Kennedy...” Bibi entered his Lelevision showdown with Yiczhik Mordechai with much the same strategy he'd used against Peres. [le went on he offensive. He fried 0 poriray bimselCas an indispensible bub against those, like YiLzhik or me, who he said would cosy up to Arafat aod Assad and endanger Israel's security. But Yiczhik was up for the fighe. Tle also knew that anly months cinticr, Biba hirself had been exploring the idee of giving up the Golan eights to the same President Assad. He didn’t actually refer 1 the seerel ‘mission by Ronald Lauder, or explicitly accuse Bibi of hypocrisy. But his reply — and Bibi's visible discomfort were just as eftective. Smiling sardonically, he said: “1 kuow your outbursts, and they won't do you any 2ood.” He challenged Bibi to just “look me in the eye” and admit what he really thought about the future of the Golan. The media verdict was unanimous. Mordechai had won, Which meant | had won, Though my American and British brains” trust had litte input into our day-to- day campaign, they did play a role in the thrust and strategy. 1 wied to drive home wo Things is we entered the twamwock homestretch m May. My firs, bowl message was an echo of James Cacville’s central theme in the Clinton Presidential campaign: “change. versus more of the same.” It had worked in the US not because it was clever, but because it resonated with large numbers of voters. T sensed from the start of the campaign tha it was Luc of Isracl as well. Different groups had different pripes, and different ideas of what they hoped I would provide as Prime 314 BARAK 129 Minister. But fewer and fewer Tsraclis were enthusiastic about four more years of Bibi. Bu I also was keen w convey the subsiarce of what my premiership would be about. Damestically, I spoke of the need fo narrow gaps in education and apportunity ticular, thongh not only, the contiouing disadvantige oP many in the Sephardi communities who bad acrived in the early years of the state. 1 wanted to try to build bridges between the secular and religious as well. My hope was 0 begin to reercate the “One lsracl” of uy youth. Ia terms of policy, [ believed my primary job would be deliver “sceuity and peace” in that order. I declared my commitment to continue. and build on. Oslo and fo male a new push in negotiations with Syria, Deliberately following the model Philip Gould had used in ‘Tony Blaiz's election campaign, we also distributed nearly a million copies of a six-point policy “pledge card”. Tt included a promise to hold a referendum an any peace deal we reached with Syria or the Palestinians, as well as several domestic policy pledges. including an end to discrimination against Russian imuigrants whose Jewish religious status had been called into question. Yet the most widely reported promise was tat 1 would pull out all tract troops from Lebanon within a year. | realized that even among those who knew that made sense, voices would be raised both in the Knesset and the fire against withdrawing, As with the Bar-Lev Line before the 1973 War, the longer the “security zone” was in place, the more difficult that politicians had found it w say it was a mistake. Yet it had now been there foc nearly two decades. The main argument for keeping it that it protected the security of northem tsracl was undermined by the Get tha thousands of Katyusha rockets had been fired over it. And in the low-geade war we wese fighting against Hizbollah inside the security zone, around 20 scaeli soldiers had been dying each and every year. When I'd first visited onr positions in sonth Lebamon in the cay 1980s, chad with the troops and asked them how they were doing. the invariable response was: we're OK. We're just worried about our young kids back home. Now. those children were army the same outposts. fein the same danger, in a sliver of band on which we had 10 elain, which we had uo desire 10 hold. and which was, at best, of questionable security value. vou 315 BARAK £30 Id tried not to pey wu much attention 10 newspaper polls during the campaign, perhaps because even the “good” ones, ta use Shimon’s phrase, had me with just a narrow lead, with Yitzhk Mordechar's 10 or 11 percent still likely to prevent outright vielory in the first round. Bul in the secoud part of May, our intemal polling showed things were moving in our direction. In mid-May. they had me above a0 percent. A final batch of intemal polls, on the Friday before election day, had me just short of SO percent. But | wld our pollsters thal under no circumstances were they to divulge the results to anyone in the campaign team. This wasn't just because | wanted to guard agamst complacency. If was because, deep down, still 1 didn’t rust th numbers. retreated to Kochay Yair on Friday evening. On Saturday, twa days before the election, | had a surprise visitor, sameane | knew from Yitzhile Mordecai’s team, He sd he ad letter for me, with fens of s proposal under which Yitzhik would announce 2a elevent-hour withdrawal trom thie race. 1 still could not be absolutely confident I'd win, at least in the first round. Yitzhik’s pulling out would help. But A did win, | wanted 10 stat the process of assembling i coalition with a blink slate and an open mind. Doing 2 deal was uot the way to begin. {didn’t aceept or pen the envelope. “Go back to Yitzhik,” I said. “Tell him, as he knows, that | havea lof of respeet for him. But his is 1 decision that he has to make on his own,” “The mest day. less thin 24 hours before the polls opened, ull of the three other candidates announced they were pulling out. Benny Begin and Azmi Beshara were never going 0 affect the outcome, But Yitzhil's withdrawal very possibly would, When he spoke fo reporters, he said it had been one of the most diffieul decisions he'd had to make, but that he'd concluded he wouldn't get encugh vores t reach Tis “primary goal” of defeating Bibi, “The prime minister was given a chance and he failed,” he sand. “We must give Barak uw chance.” 1 ol up early on May 17, confident wed done everything we could to pul ourselves in a position to win, but also aware, trom Shimon's defeat, that the smallest of details, and the narrowest of muriams, might determine the outcome, Aller the 1996 election, T'd learned of cases where Peres volunteers owside polling scations in the Negev or the north of the country had left early, in order to make sure they'd be back to Tel Aviy in time for the “moment of victory.” Now, | sent ou word that all our volunteers musi stay in place until the polls bad closed. Afer 316 BARAK 31 Nava and T voted, we attended an event for Labor supporters north of Tel Aviv. before flying lo Beersheva to spend the (inal hours in the Negev. I'd arranged for Shlomo Ren-Ami fo za fo Kiryat Shmana in the north emphasizing, as throughout the campangm, one determination to broaden our snpport beyond Labor's heartland. The polls closed at 10 0'cloch. 1 knew Bibi would be staring at the same Chanael One newscast as 1 was, each of us ready to pu tae best spin on things. especially if there was no clear sign at this stage which one of us had veon. But the exit poll findings came us a shock: Barak, of Oue Israel. 58.5 perce: Netanyahu, Likud, 41.5 percent. It was a landslide. ‘The full impact hit me oaly when [ got to the fifth-floor suite in the Dan Hotel in el Aviv, our election-night headquarters. My thee brothers, and Nava und ous daughters, were waitiag for me. Leah Rabin. too. Our eyes leared up as we embraced. My parents were by now toa frail to came. But Id promised ta phone thee, whatever happened. “We did it,” Told my father, who seid mazaltov with & depth of feeling which had become rare as bis health began to il. My mother had always been a bit conflicted about my going into politics. despite her lifelong bilicl that the ixsaes of polities mattered, expecially afer Yall had been cul dow and killed for following the path on which T hoped to continue. Sill, | could hear the pride, and relief, in her voice when [ said: “Remember. fm. I did promise you that ran, at least 1d make sire to win.” When we'd (inished speaking. Bibi called. He had conceded publicly ss soon 2s the exit poll was out. Tle liad also stunned the Likud crowd by inmediztely resign as party leader. “Congratulations.” he said, sounding, more than sything, tired. “1 aceep! that the voters have spoken.” | thanked him for taking the trouble Lo call. T said T appreciated the contribution he’d made to Lhe country. and that we'd meet in the next few days to discuss how best to handle the political transition. Thanks,” Bibi said. “And again, mazaliov.” By the time | got uf the phone with Bibi. the TV was showing pictues of lens af thousands of people celebrating the results in the central Tel Aviv square, now renamed in Rubin's memory, where he hud been murdered ney four years aarlicr. Before leaving to joiu them, | fielded a steam of calls: from Gricnds, other Israeli party leaders and leaders from abroad. including Tony Blair and Bill Clinton, bath of whom nat only offered warm congratulations but said they looked forward lo working with me us fried to move Israel forward and to finish the work Yitzhak had begun 317 BARAK 32 AL the start of my brief remarks at the hotel podium befoce going Lo Rabin Square, T had to call for quiet when T mentioned the phoue call from Bibi. “No.” I suid, raising my voice to be heard above the boos, “we will not boo an incumbent Prime Minister of Ismael... A short ime ago, | spoke with Prime Minister Netanyahu and thanked hint for his serviee to the State of Israel.” Then with both Leah and Shimon Peres at iy side — I paid tribute to “thar one special person who had a unique role in our reaching this moment — somebody whi was my commander and guide, and the person who led me into politics: Yitzhak Rabin. | Wledzzed to fulfil his legacy, and complete the work he'd started. And | extended a hand to “secular and religious, the ultra-Orthodox and the residents of the settlements, 10 Israelis of Middle Faster origin and Ashkenazi extraction, 0 immigrants from Tithopia and the former Soviet Union, to the Arabs. the Druze, the Circassians, the Bedouin. All, all of them. are part of the Israeli people.” Te was aot long before sunrise when T ceached the square. As the ecowd shouted and sang. T began with a line borrowed from Bob Shum. Tt seemed particularly ape: “Iti the breaking of a new dawn.” I said. But was {17 As | paid irbulc to Rabm in this place where anr beasts broke” and dedicated mysel 10 completing the work he'd begun, 1 eould feel the thousands in the square willing me on. Even in my more nuanced comments on the talks with the Palestinians: the need to nchieve peace, but at lest for now by discagging rather than joining hands with the Palestinians, cusuring we had military and border provisions to safeguard our security, and with the stipulation that Jerusalem would remiin our undivided capital, under Iscacli sovereymty. But some in the crowd were crying posters saying “No io the charedin® — the stricly Orthodox. Others were chanting. in anticipation of the negotiations needed Lo put together a coalition: Rak fo Shas! Anyone but Shas! It was a reference to the Sephardi Orthodox party, which in addition lo being more mumeed and flexible thao other religious parties vn the issue of peace talks, had been the big winaer in the election. It had pained seven seats and now had only twa fewer than the Likud. 1 dud not specifieally mention Shas. But | sad: “Cell you here tht the time has come to cud divisions. The time las come to niake peace among ourselves. whether we are traditionalists or secularists... We ust not be enemies of each athe,” Paying tmbute to all those in the square who had worked for our election victory, added: “1 know it would not have been possible without your support. But Talso know it would not have been possible without the support many in the 318 BARAK / 33 Likud. T appreciate that as well. And 1 undertake to be rash hasmenshalide shel Aulam: Prime Minister for aif Tsraclis Yet as fervently as | hoped to be able deliver an that pledge, | knew. even as | spoke. tha actually ful ilfing it wes going to be much, much longher. 319 BARAK F341 Chapter Twenty As Prime Miaister. T would sometimes be oriticised as emotionally buttoned up, even stoic, and there was some truth in that. It was partly just a reflection of who 1 was: a kibbutznik who'd grown up in the early years of the state, and had then spent most of his Hie in the army. Bt while if may not have shown, 1 fells chim af emotions when | formally presented my government to the Knesset in July 1999 as Nava, our three daughters, her parents and mine looked on proudly from the alkry. Even more so, when |entered the office of the Prime Minister. I'd been there before: as head of military intelligence. ehief of staff and a cabinet minister. Yet to sit behind the vast wooden desic and know that the buck now truly stopped with me to become just te tenth person in Israel's history to ive tht honor was very different What T felt most powerfully, however, wasa't the honor. Tt was the responsibility. 1 knew that srael faced two deepening crises. The first was domestic. Thongh Yitzhak Rabin’s wssassin wis now in jul, the divisiveness and hatred of which he was a product aad symbol liad not gone away. Not had other ifts; between the privileged and disadvantaged, Ashkenazim and Sephardim, and, erhaps most of all seentar md religious. The second, more imneduate challenge was ou our borders. The peace process was stalled. 1 we were going (0 revive iL, we were running against the clock. President Clinton, a key player in any hope of inmming the promise of Oslo into seal peace. had only 18 months remaining fn fice. Tu terms of [sracl’s seeuity, the Limetable was even less forgiving. Irom my very first incelligence briefings as Prime Minister, T was even mote convinced of what 1d been warming Babs for manths: without a political breakthrough, a new. uch more deadly intifada was only a mauer of time. That wauld have been reason enough to make peace efforts ny fisst priority. Rut even as | was addressing the victory rally in Rubin Square, I sensed tha the simple arithmetic of the election results would eave me no other choice. 1 wis catering office with the largest electoral mandate in our history. But that was because of Israel's new voting system, with separate ballots cast for Prime Minister and party. 1 hat sysiem hud had precisely the apposite effect on party voting. In previous eleations, most scaclis had chosen une of the two main parties. knowing. that only they had a realistic chance of farming a government, Now they could direcly cioose the Prime Minister, giving them the fusary jo vole m much greater 320 SHARAK 35 umber for an arcay of small, issue-specific parties. The result: though I'd won by a landslide. and One Tseael had the largest number of Knessel seats. even with aur nacural left-of-center ally, Meretz, we would have only 36 Knesset seats well ston of the 61 needed for a jority. Even if we melded a Gow smiller parties, thece was no choice but to bring in one of the two larger ones: the Sephardi Orthodox Shas. with 17 seas: or Likud. which after Bibi's sudden resignation, was uow led by Acik Sharon, and had 19. Tt wasn't just a math problem. It had a critical policy implication. IF | wanicd 10 tackle the domestic challenge to reassert the values of secular-led democratic government over increasingly assertive religious involvement in our day-to-day politics — that would men choosing Likud over Shs. But it would also signal the effective end of the peace process. Even though Acik assuced me privately that be understaad my determination to reopen peace efforts with Arafat and Hate al- Assad. 1 hnew Arik. The path toward peace agreements, assuming they were even possible, would be Lough. Soaner oc later — and certainly if we faced the need to consider painful compromises in the negotiations I was certain that Arik would set as a kind of opposition from within. That was why, over the angry opposition of Merete leader Yossi Said, 1 decided Lo go with the Sephardi Orthodox pany. | realized that even Shas might walk out if the scale of any land-for-peace comessions proved foo Ingh. But it was the leas! extreme of the major religous patties on the question of peace with the Palestinians. In uy conversations with the party's spiritual leader and guide. the 79-year-old rabbi and Talmudic scholar Ovadia Yosef, 1 was struck by his intelligence, erudition and subtletly of thought but, above all, his commitment to the cure Jewish principle of sauctifying human life over the specifics of Oslo redeployments, where his inclination seemed to be to trust the judgment of those with the experience and expertise to evaluate the security implications, To Merete's additional consternation, included two smaller, right-of-center Orthodox parties in the coalition. It was not just to make good on my pledge to be Prime Minister for aff Israchs. Knowing that [ was going to pul top parity on the peace process, | wanted to avoid an undiluted lefi-of-centre, seeular thrust 10 the ‘government. When I'd stood in front of the tens of thousands of cheering supporters in Rabin Square after the election, [ thought ta myself: they fhinlc that wilh Bibi gone, peace is around the corer. | wanted a coalition broad enough w keep Meretz. and Labor ministers as well, from forgetting a crucial fact: the 321 {BARAK [36 compromises thal we might have to contemplate during peace negotiations were still anathema to many other Israelis. + 0s a Syria was always my first negotiating priority. as it had been for Rabin and. for a brief period, Bibi as well. This was not just because the shape of a final agveemient with the Syrians was clearer, 10 both sides, than with the Palestinians. It was because 1 was determined to make good on the main specific policy pledge of my campaign; to bring our troops home from | ehunon. No matter whl the increasingly emboldened fighters of Hizballah ssid publicly, our withdrawal would be bad news (or them. IL would deprive them of their “anti-vecupation” rationale for firing Kutyushas into towns and settlements in northern Israel, and free us politically wo sirike buck bind if thal proved necessary. 11 was clear lo me that Tlizbollah would Ley Ww make the withdrawal as difficult for us as possible. Bul the real power in Lebanon rested with the Syrians, whe, along with Iran, were Hazbollah's main backers. 10we conlel get a peace agreement with Assad, there soemed every reason Lo hope be would rein in 1lizbollab, and perhaps apen the way to a peace treaty with Lebanon as well Still, there was no way of hiding an additions] atraction in getting a deal with Syria first: it would increase our negotiating leverage with the Palostinians. | hat would certainly not be lost on Yasir Arafat — one reason that 1 realized the importance of an early meeting with him, to convey my commitment fo keeping the Oslo process alive, snd, i possible, achieving u full sud fal Israchi-Palestinian peace Twent to see Arafat a few days after taking office. We met for well over an hour at Erez, the mam crossing point mio Giza, 11 was swelteringly hot inside. At Teast J was in an ordinary business sui, but | couldn’ help wondering how Arafat 322 {TARAK / 37 was coping in his trademark military uniform. Still, the mood music going into the meeting was encouraging. Aller the election, Arafat had tried Lo use his ties with the ayatallahs in Iran to get them to release 13 members of the tiny Jewish comity in Shia: who bod been aited on patently absurd weeusations of spying for the “Zionist régime.” Iran had told him no. Given its support for Tizbollah, and its serial diatribes about destroying the State of Israel, this was hardly a surprise. But it was a gesture nonetheless, and 1 wld him [appreciated it. 1 also arrived with a gill: & leather-bound volunie with both the Lichrew Bible and Koran. | began our meeting with what I felt 1 most needed him to hear: that both of us were trying to achieve something hugely important, nothing Tess than a new relationship between sractis and Palestinians based ou trust. As would discover in the mouths shoed — 25 Yitzhak had found as well — Arafat cesponded warmly to such geaeral appeals af principle. He replied that he viewed me a5 a partner, and a friend. But the key ssc of substance — the difference between how [envisaged taking Oslo forward and what he wanted — was impossible to avoid. T emphasized that 1 was committed to the further Wye River summit redeployments Bibi which hid agreed, although not mplamented, as well as 1o celease of Palestinian prisoners agreed aL Wye. Yet then came the more difficult part: explaining ny view of how we could best move toward a full peace agement. | sand [was convined the prospects would be much beller if we delayed the sedeployments and brought forward the start of the weal negotiations: on “permanent-starus™ issues like final borders. setdlements. Jerusalem. refigees. In any case. | said, ['d need a few months for a thorough assessment of the issues involved, and to reach a seuled view with my negotiating team ou how w proceed. Arafat seemed to accept the idea of a pause for reflection and planning. But be held firm in his opposition to any further delay in the Wye redeployments. More worryingly for the kmyer=ierm prospects of un agreement, he imored lagether my suggestion that we move ahead toward the permanent-status talks. Speaking to reporters. [ was careful to accentuate the positive. 1 said the reason Pd come fo see Arif so soon was because of the importance | attached to his role in “shaping peace in the Middle Last” I said [ would nal wever in conlinuing oa the path which Rabin and he and begun. And while the security of Israel would be my paramount cancem in negotiations, “1 also want each Palestinian to feel secure.” Buth sides, { said. had suffered enough. The open question, however, was whether Ziad done enough to persuade Arafat that his exclusive focus on 323 {BARAK 738 cedeployments — on anly the Jand part of a land-for-peace deal — meant we risked ignoring the core issues that would determine whether a full peace agreement was achievable, More urgently, | knew from onr diplomats in the US that the Americans would nol necessarily be receptive 10 a futher dely in moving ahead with Oslo, even it it meant focusing: on trying to make peace with Syria. That made my first visit to see President Clinton as Prime Minister especially important, PE Twas billed ss a “working visit” and work we did. Aller a gals dinner for Nava and me in the White Ilouse, we helicoptered to the presidential retreat at Camp. David. President Clinton and 1 spent more than 10 hours discussing shared security chillenges in the Mickle East, especially terronst groups and states lke Iran that were backing them, and. of course, low best lo move forward our efforts lo negotiate peace, These face-to-face meetings set a pattern that would last throughout the time he and | were in office. On almost all key sues, my preference was lo deal dircetly with the President, something | kuow sometimes frustrated other senior US negotiators like Secretary of State Madeleine Albright and Mideast envoy Dennis Ross, This was nat out of any disrespect for them, 1 was because the decisions on which negotiations would suceced or fail would have 10 be made at the top, just as President Clinton and T would ultimately carry the responsibility, or the blame, for errors, missteps or missed opportunities. Our first meting ran anil three in the moming. When the President asked me how [ saw the peace process going forward, he smiled, in obviously relief. at my answer; | wanted to move quickly. He had only a limited time left in office, und 1 was detenmmied Thal we not waste 1. Much is often made about the personal “reliemisiry” in political relationships. Tou much, [ think, because the core issues, and the trade-offs of substance, are what truly matter when negotiating matters of the weight, andl longelerm nplicanons, of Middle Fast pice. SHll, chemistry does help shen moments of tension or crisis arise, as they inevitably do. My first few days with President Clinton laid a foundation that allowed us to work together even when things wot tough, | benefited, 'm sure, simply by nat being Bibi, The 324 BARAK {39 president and his negotiating team had spent the previous few, frustiatiog years Lying aliernately to urge, nudge and cajole him — and, of course, Arafat — toward implementing Oslo. Clinton did finally succeed in getting the Wye River spent. Bul il, loo, remained to be implemented. Navas presence, and Uillary Clinton’s, contributed 1 an informal, familial atmosphere. Before my first round of talks with the President, we joined Bill and Hillary for dinner, Though | would work more closely wath Hilliry in later years, when she was Secretary of State under President Obs, this was the frst time ['d had the opportunity to engage in anything more than small talk with her. She was ess naturally outgoing than her husband. Yet not only was she bright and articnlate. She was barely less informed on the ins and ows of Middle Fast peace negotiations than the President. She, and Bill as well, also spoke with us about things well beyond the diplomacy of the Middle Fast: science, musie, and our shared interest in history. What most struck Nava and me, however, was the way the Clintons interacted with cach other. The scandal surrounding Monica Lewinsky was still fresh. [ suppose we expected to see sigus of tension. Whether they were there, we had no way of knowing. But what the twa of them did palpably hive ws a deep respect for cach other's intelligence. insight and creativity in looking for solutions where so many others saw only problems. It was inypressive. Sill, there was fitrle smull talk in the long discussions | hud with the President From the outsel, 1 wanted hint to know exactly what 1hoped we could accomplish and how, in my view, we were most likely 10 get there. Twasa't tying to impose “ground rules” on the President of the United States, something [ neither would nor could do. Bu | ves explicil with him about my own approach te negotiations. | assured hit [ was prepared to be flexible. But T said I'd be relying on two critical assumptions. The first was that when we and the Americans apreed a position on a specifi fssie, there would be no umilateral “surprises” — by which | me, though didn’t say, things like the unfortunate American redefinition of Yitdhak's “pocket deposit” assurance regarding the Golan. The second assumption. I know. may seem avealy legalistic. 11 was thir, until and unless we reached a full nd foal agreement with either Sycia or the Palestinians, any Iscaeli negotiating ideas ve proposals would nor be binding. If no agreement was reached. they would become null and void. | wanted to avoid a situation. as had happened so often in past negotiations, where an Isracli proposal was ejected by the Acab side but then treated as the opening position ia the expectation of further concessions in later 325 {BARAK 40 Lalks. T did realize that, “all and void” of not, our proposals or suggestions would ool simply disappear from memory. But T felt the point of principle was essential if Israel was going to be uble to consider the kind of far-reaching concessions which Final presce deals might require. In the end, 1 realized thal we might simply discover thal Assad, and certainly Arafat, were not willing or ready to make peace. We might, initially at Jeast. have to settle for i mare incremental step. “Right here in Camp David, Bem, Sadat und Carter couldn’ complete the process.” | poinied oul. “They signed a “framework agreement’ and it cook months of further diplomacy to reach a peace treaty. Maybe we'll end up doing the same.” But | told the President [was convinced that if we didn’ sry 10 got agreements, we'd hve no way of knowing whether the will lo make peace was there on the other side. Assad, T suspected, was the more likely lo reciprocate, That wis a major reason [wanted to start our efforts with him, Rut so Far, his ee intentions had never been tested, beyond his obvious determination lo et back the Golan. Nor had Aralau's, beyond his focus on the detail and exient of West Bank redeployments. President Clinton did not objeet fo an carly effort fo reopen our efforts with the. Syrians. Bu he was worried abou the effects of ignoring the already-creaking prospects of fulfilling the promise of Oslo. [t we were going to delay focusing on that, Clmtan told me, he needed to be able to assure Arafit the wait would be worth his while. What could we give the PLO leader in returu for putting off the Wye redeployments further, he asked. And then, the real question on his mind: “Ehud, when we get to the final redeployment and a pesce deal, how much of the West Bank are you prepared o band back?” 1 simply didn't know at this stage. Much would depend on whether we could be sure Arafat could or would deliver a final peace. But even if 1 had known, 1 would Iusve been reluctant to name a precise percentage. Though | bd full trust in President Clinton, | knew that everything lie and 1 said would be shared with au Teast a few of his closest palicy aides and negotiators, Sooner or later, ward would get 10 Arafat, When we did begin negotiations, he'd take whitever number | give 48a mere starting point. Sul, 1 knew | had to signal the President that [ was serious about negotiating with Arafat when the time came. I also knew the main source of Ins cance, In order to et the agreement at Wye, the President had sumed on to a provision that the dimension of the third aud fival redeployment phase would be determined by Tsrael alone. By that stage, when we got there, Arafat would have 326 BARAK /41 control of something like 40 peccent of the West Bank. That meant - at least in theory — that Teac] could limit phase-three to a mere token pullout, leaving the Palestinians with less than half of the territory. “1 dont know what percentage, exactly.” | replied. “Rut one of my cabine! ministers thinks that a formula of 70-10-20 would work, meaning 70 percent for the Palestinians, ten percent to allow us to retain and secure the largest of the settlement blocs, and the rest to be worked out in further talks.” When he nodded, 1 added: “Peres thinks it could end up ai 80-20, and says be thinks Arafut would find it hard to wal away from geting control of four-fifths of the West Bank. But it’s nat about the number, It's about the area needed for fhe major settlements, ind whatever else is required lo safcgnard ow security. Beyond thal, we don’t need single inch of the West Bank, and we won't ask for a single inch.” I replied in much the sume vein when President Clinton urged me to help kick- start mew talks with Assad by Formally reaffirming Yitduale's “occ! deposit” an the Golan Ucights. As with the Palestinians, | was ot going lo cede a major negotiating card our only real negotiating card before we had any indication Assad was serious about making peace. But | did feel 1 wis necessary to reassure Clinton tliat £ was serious. 1 wld him that, i and when the Syrians showed real sigas of readiness to address oir needs in a peace agreement, | would reaffirm the “pocket deposit.” 1d cone to Washinglon hoping that President Clinton would be with me on the ‘main issuss of substance. Buc what [ needed most at this point was his support on the procedural decisions [d made in order 10 et fo real peace neatiations: ngnging with Syria first, and shifting the cmlissis on the Palestinian track away from the redeployment toward the core permanent-status issues we'd have © resolve in order to get u peace agreement. What emerged from my first meetings with President Clinton was essentially # trade-off. He knew | wanld be ready lo make concessions in pursuit of genuine peace. [ was confident that on the route that [ was proposing fo take, he would have my back But what | couldn't be sure of was whether my own govemment would have ty back. On paper. we had a comfortable Knesset majority: 75 out of the 120 seats. But 1 knew it was inherently vulnerable. both ro friction between the Orthodox parties and assertively secular MK from Meretz and inside 1 abor, and 10 possible defections over the concessions we might have 10 consider in peace 327 BARAK / 42 acgotiations. The ist stirrings of discontent had begun even before T went to see Clinton. On the basis of my commitment merely to #5 for peace, Arik Shacon had presented a no-confidence motion in the Knesset. If was never oing to pass. But any diay ler 1d mde him Dterior Minister, Natan Sharansky let 1 be known he was going 10 vole against us. TT didn’t. Le stayed away (rom the chamber, in effect abstaining. Bur I'd been put on notice. 1 dd lose my first coahnon parmer in September; the small United Torh Judaism prsty. with five Knesset seats. 1 wasn’L over land-for-peace. In an echo of a similar crisis that brought down the government during Rabin’s first spell as Prime Minister in the 1970s, it was over a violation of the Jewish Subbath, It wre out hat Israel's state ekoctric company hid boon transporting i huge siam- condensation machine from the manufacturing site near TTaifa 10 a power plant in Ashdod. The unit was the size of u small apartment. It weighed 100 tons, I couldn't be driven across the country without bringing weekday traffic toa standstill. The obvious solution was to do it when road use was lightest, on Shabar. Precisely the same procedure had been followed — 24 rimes — under Bibi. But when [asked a United Torah Judaism leader why he'd seemed happy when Likud had waved it through. he replied: “Past sins cannot pardon future ones.” Eli Suissa, one of the Shas ministers in the cabinet. took his side, saying: “Tvery hour 1s aod for the keoping of Shabbat” Most other misisters agreed with me that we should stand firm. So 1 did. But U1 walked out of the government. Shas did remain. Buc I was now increasingly certain that at some stage its ministers, too. would leave. Ia the midst of the Sharanksy rebellion, Haim Ramon, who was the minis in ehacge of liaising with the Knesset, insisted T “punish” him for his political erandstandiag. “You should fire Sharansky. Act like a leader!” I just laughed. “The conlition docsn’| need a leader.” | ephied. “10 needs therapy.” In truth, [suspected tha if we ever gol near 10 a peace agreement with Assad oc Asafa, even Lhecapy ‘might not help. But that was a main reason that 1'd promised a referendum on any Tina pace deals. | believed that in the choice between concessions, even pamful anes, and a genuine peace deal with Sytia or the Palestinians, by Gar most [sraclis would chocse peace. relied on a strong. close team around me, people | knew well and who shared my determination 10 stay focused on the central goal: tw put lsraed in a position where ifs citizens could be given that choice. T made Danny Yatom, my former 328 {BARAK 43 sayeret deputy. my chiel of stall. The aceotiating team also included Uri Saguy, former head of military intelligence: Gilad Sher, a gifled lawyer I'd known for a quarter of a century and who had been a company commander in my armored brigacke fu the 1970s: ancl Avmman Lipkin, the pansion commander at Chinese Farm and my successor as ramatkal when 1 lell the army. Also, Shlomo Ben-Ami, the Morocean-born. Oxford-educated historian and diplomat who had run against me for the Labor leadership. Shlomo liad a gif for systematic anelysis and keen judgement, especially on scourity issucs, which | highly valued Tt did not escape the attention of Israeli commentators. or other politicians, that almost all of them were former soldiers whom °d known from my time in uniform, But thal observation missed w more important point: we were all members of the “generation of 1967 and 1973.” We had been soldiers ducing the Six-Day War. Tn the years immediately after it, Tike almost all Israelis, we had allowed ourselves ta believe that our victory had been so comprehensive, and so quick, that any thecal Irom the defeated Arab states was gone for good. We assumed that inevitably. inexorably, they would realize they needed to sue for peace. and that there was no puticilar urgeney on our pert fo do anylhing more tan wail. Then, on Yor Kippur 1973, all of that had been turaed on its head. We had not only learaed the lessons, of 1973. We had internalized them. Even had we not known of the danger oF new Palestmim campaign of terror, the option of simply walching and waiting — and assuming that our military strength, which was now even greater, could ‘make events around vs stand still - would not have made sense to us. Besides, as T remarked to Danny and others, to do so would run against the founding purpose of Zionism: 10 establish a state where Jews would no longer be vietims of events, but would take control of their destiny and try to shape them. Pr Yer making peace, like making war, takes two. Much as I'd wanted to begin with Syria, nnlil well into the autumn of 1999 President Assid was holdmyg firm on bis insistence that without our “deposit” without a prior agreoment that he'd set back the Golan, there could be no substantive progress. This was particularly frustrating because [ was getting reports from our intelligence services, and 329 BARAK £41 Western envoys who had seen the Syrian president, that Assed’s many years of health problems had le him almost skeletally frail, even at times disoricuted. Even my own negotiating team urged me to concentrate on the Palestinians stead. President Clinton kept stressing the importance of showing Arafat ul feast some movement on the Oslo font. In September 1999, 1 took a first, signilicant step in that direction. | agreed to a timetable that would deliver the We redeployments by the end of January 2000, while alsa committing us 1o negotiatmg 4 fesmework agreement, on the model of the Begin-Sadt Camp David accords, on the “permanent-starus” peace issues. In early November. I joined Clinton and Arafat for tall around un event in Oslo a deliberate echo of the optimism with which the peice process had began, held on the fourth nniversary of Rabins assassination. Both Leah Rabin and Peres came with me. Tis centerpiece was a memarial service, at which | eah spake very mavingly of the need for both sides to finish the work Yithak bad begun, a responsibility [ pledged that we would do everything in our power wo fulfill. Only Acafat struck a discordant note. Tle paired a tribute to Rabin with a polemic call for an end to “occupation, exile and settlements.” After the ceremony, lie, President Clinton and I met at the American ambassador's residence. [ was still struck by Arafat's public comments: by his apparent desire. ar need, fo play to hardliners back home in what was supposed to be a time lo remeber and honor Yitk. {didn’t raise his remarks direely, bu | told him that each of us was approaching a moment of truth for the future of our people. The decisions required wouldn't he easy polinically, for cither of us, “But if we don’t have the courage 10 make then, we'll be burying thousands of onr people.” Worse, T said. those deaths would not advance his peaple’s position, or mine, by a single inch. When future Palestinian and [sracli leaders did finally prove equ to the challenge of making peace, they’d be looking al the same conflict, cequiring the same compromises. “The only differsace will be the size of our cemeteries.” Arafat nodded occasionally. Bur he said liale, beyond saying that he considered Rain to bie been a friend, und repeating his now-fanmibir, aonspecific, pledge tw “do what is necessary” for peace “The hardest part won't be the tough decisions in negotiations. I continued. “Te won't be ficing each other. 1t will be facing our ova people.” We would need to make the ese openly. honestly, strongly that the peace agreement we reached was in the interest of both Tscaclis and Palestinians. And in this, each of us had a 330 {BARAK [45 cesponsibility to support the othe. With President Clinton looking on, 1 steered Adal wward the window of the ambassador's filth-Nloor apartment. “Look dawn,” 1 said, “Tmagine fhat we euch have parachutes, and we're gaing to jump together. But [have my hand on your npeond, and you are holding mine. To bd sally we have to bielp each other... Aad if we don't jump, many, many innocent people who are now walking the streets of Gaza and Ramallah and Ilebron, Tel Aviv and Jerusalem, will die.” Arafat again just nodded, leaving me, and the President, unsure whether anything 1°d said had struck bone. The true test of that would come only when we got to the stage of negotiations when the “difficult decisions” could not be evaded. Yet anly weeks atter 1 returned from Oslo, the focus did finally shifl to the Syrians. President Assad suddenly signalled bis willingness to resume talks without any preconditions — a message he delivered first to my British Labor Party friend Michael [.evy, who was visitmg Damascus as Tony Blair's roving Mideast envoy, and then lo Secretary of State Madeleine Albright. Assad said he would send Syrian Foreign Minister Farouk al- Sharaa to meet me for initial talks in Washington in December. ahead of a full- seale, US-mediuied attempt 10 negotiate peace al the start of the new year. ose “The broad terms of a potential deal had long been clear, both 10 us aud the Syrians. The danger was always that the process would get derailed. or never really et started. due 10 damestic palitical opposition. Syria had « tightly state-controlled media and am intelligence serviee concerned mainly with crushing any signs of dissidence. That meant Assad’s main concern was lo ensure broad support. or at least acquiescence, from top military and party figures. In Israel, however, every sign of 1 concession would risk igniting charges that we were “selling oni” fo Syria. The Likud and the political vight would abviously denounce the idea of eiving up the Golan Ileights. even though Bibi had been ready to do just that when Ie was Prime Minisier. Bul even on the fel, there wis lik: enthisiasm for returning the Golan. There were (ar fewer Israeli sellers there than on the West Bank. not even 20,000. But most of them, far from being religiously motivated ideologues, were |abor supporters. And almost no Israel, of any political stripe, 331 BARAK (46 viewsd Tafez al-Assad as a vatueal partaer for peace. For years, he'd been a constant, sneering presence on ous northern border, denouncing nat only Sadat but any Arab leader wha'd shown willingness to engage ar negotiate with Israel, Amos Ov, ane of our finest writers und a cultural icon for Labor Zionists, probably put i best. Le said the Syrians seemed Lo thiok that “we will give then the Golan, and they'll send us a receipt by fax.” The consensus was: forget Assad. Keep the Golau. In Fact, before [lef for the US, the Knesset voted un whether it supported my attempt to negotiate an agreement with Syria. We could muster only 47 votes. 14 shart of a majority. An opinion poll found only 13 percent of Israelis favored a full withdrawal from the Golan. Tie message | dew fom this was nf Hal we should give up on the elnces of a peace agreement. Aflec all, before Begin and Sadat went to Camp David in 1978, am almost equally tiny minotity of Israelos had been m favor of withdrawing from the Sinai. Yet ance they had seen the other side of the equation — ul, formal peace with our most powerful neighbor — Lhe opposition all but evaporated. The problem 1saw was that if we and the Syrians couldn't find a way to insulate our negotiations from leaks, speculation and «swirl of opposition to our efforts at home. we'd never get to the key issucs of substance 1°d been making that point to the Americans for weeks. At first. | tried to persuade them to hold the talks at Camp David, ensurmg the same, media-froe isolation thet had yielded the historic Isracli-Lipypl agreement. But Dennis Ross teplied that the very association of Camp David with that breakthrough meant it would be i non-starter for President Assad. { then sugested we consider sites ouside of the US: NATO's neerlik air base in Turkey, for insiame, a British base in Cyprus, an American naval ship in the Meditercaoean. Even, hal jokingly. an abandoned missile silo in South Dakota. Yet the point I was making was serious, ia act eritical, | believed if the talks were gong [0 have # chance. Ia the end. the Americans settled on a beawiful, and undeniably remote, town in West Virginia called Shepherdstown. But from the outset, | was worried it couldn’ provide the kind of environment we needed. As soon us our phn linded at Audrews Air Force base outside Washington, 1 got a call fron: the head of our advance team. Tle old me the news media were already there and that reporters — Israch, Arab, American and Furopean could be seen chatting with American, Israchi und Syricn officials in the town’s coffee shops. {knew the press would have to publish something about potential concessions as the negotiations proceeded. 332 {TARAK i 17 Whether the stories were true wouldn't mater, They would still make the real bargaining necessary for peace far mose diffieult, pechaps even impossible: also had doubts whether Assad was ready for real peace: embassies, open borders. personal contact between Syrians wc Israelis, and ideally an internationally backed free-trade manufactucing area on the Golan 10 give Syria a tangible stake in ensuring the peace lasted. In earlier talks, under Shimon Peres, Syriin negotiators had at ane stage brought a message from Assad, What did we mean, he wanted 10 know, with all this cruphasis on peace. peace, peace? Sytia had peace with Lf Safviudar, but without any of the trappings we were insisting on Peace, in Assad’s mind, seemed to mean merely an absence of war, Plus, of course, ting bck the Golan. did, however, come ready to negotiate. Though I was still nol prepared to vecantirm Rabin’s “pocket deposit” as 4 mere ticket of admission, my position remained essentially the one [had worked ont with Yitzhak in formulating the deposit: TAMNAM, “if all my needs ase mel.” Meaning that if Assad showed a readiness to deal with fsrael’s requirements in a peace deal. 1 did, of course, recom we wonld eve the Golan Heights, In addition lo curly-wamning Racilitics. we envisaged an open border with a demilitarized area ou cither side, as well as guarantees that important sources of water for Israel would not be blocked ar diverted. As Assad knew, despile bis presunsbly feigned puzzlement about Syrin’s srangements with 1 Salvador, we also necded the agreement to embody 1 mutual commitment to real peace: through elements like an exchange of ambassadors and the establisament of the free-trade zone. As with the Begin-Sadat pence, we assumed that our Golan withdrawal would come in phases, parallel 1o the implementation of the other provisions of the eaty. In our initial meetings in Shepherdstown, Foreign Minister al-Shataa showed no mchnation even to talk about these ther ists. So on fhe sceand aflemoon we were there, [suggesicd to President Clinton the Americans try to break the logjam by dratiing a paper of their awn, It would detail all the issues in an eventual angrecment, with parenthetical references fo those an which we and the Syrians still differed. Then cach side could respond with a view loward narrowing fhe gaps The President liked the idea. So did Al-Sharaa. Three days later, the President presented the eight-page American draft. With hs customary eloquence, be emphasized the need for us 10 use it as a springboard for peace, not 10 score political points. and each side agreed to take a couple of days to look through it. Tt 333 {BARAK 748 seemed to me we might finally be ou a path lo substantive negotiations. There was obviously not going to bea deal at this round of talks, but T agreed with President Clinton that when they ended, he could phone Assad and tell him that [had confirmed Rubin’s “pockel deposit.” Yet by the time we left for home, the prospects suddenly looked much worse — for the reason ['d feared from the moment we amived. There were two major leaks. “Ihe first came in an Arabic-languirge newspaper in London. Given the thrust of the ory. it had presumably come rom the Syrians. Bu it was more annoying than truly damaging. The second leak, however, was in the Israeli newspaper Hu uretz, which published the entire US nessatianmue paper, This was imwelcome for us, since it confimiod we wre ready 10 20 far in retum for peace. Bul for the Syrians, the Fact the final-border section was still a work-in-progress, with the parentheses prove it, created the impression that they’d decided fo negotiate the details of a full peace without ficst nailing dowa the cetuen of the Golan [cights. Assad’s image as aswongman, implacably tough on Tseacl, had been built and buraished over his thee decades in power. The embarrassment of being seen as amenable to talking about a Syrizn erbsssy mn Isiel without an agreement on the Golim striek me is 4 potentially fatal blow Lo the prospects for a deal, since it deamatically narrowed the scope for the flexibility needed by both sides to negotiate. I can’t say [ was surprised when Clinton phoned me when we got back to Isract to suy that Assit had refused to send Al-Sharaa back. as planned, for a fwther round of talks in 10 days’ time. 1 didn’t give up, however. and neither did President Clinton. In February. at the Americans’ request, | sal down with Danny Yaton and US Ambassador Marti Tndyk in Jerusalem Lo deaw up a “bottom line” proposal on a withdrawal rom the Golan Heights. Since I'd already emporwered Clinton to reaffirm the “pocket deposit”, Can mo reason not 10 do this. 18 only beeanse of Assad’s Failing heal, | believed it was the oaly way we could know whether an agreement was possible. We worked on a large satellite map of the Golan and the valley below, and drew aur proposed border in ved. We mnisrked out a strip of several hundred meters on the far side of the Sea of Galilee. Jt included, ov came near 0, a handful of Sycian villages that had been there before 1967. Buc we were careful to adjust the line to exclude any area where buildings had stood. We compensated with slightly more territory — by bending the border westward 10 give the Syrians pact of the slope overlooking the lake, in what was now Israel. We also included the hot springs at 334 {BARAK 49 al-Tlama, which I koew Assad had said he considered cightlully Syrian during talks held under Rabin. Bur the details med out not to matter, President Clinton ajreed to present the map fo Assad in what we both haped would be a step lo reopens the path for pesce. The lwo of them met in Geneva iu late March. Though the President also came with full details of our positions on the other negotiating issues, he began by telling Assi that | had agreed 10 the Syrians’ longstanding pomt of principle an our future border: it would be “based on the June 4, 1967 line” before the Six-Day War, Then. the President unfurled the map. It was shortly after five in the afternoon in (srael when Clinton phoned me, He sounded us il he'd been punched in the stomaeh. “Ehud 10s not going to work,” fie said. “The moment I started, he tuned our. ITe just said: “Do I get my land?" I tried ta get him to listen, but he just kept repeating; “No 1 get all my land?” According the President, Assad would comtennce nothing less than being sble 10 sil on the shore of the Sea of Galilee and “dip his fet in the water Clinton said he'd done his best, and that was true. “| understand the effart is over.” I replied. “Probably, he’s 100 Trail amd §11 by now.” In fact, Assad would dic of lenkema barely tso months later. is immediate focus was on ensuring an unevntested succession 10 his son, Bashar. When Demis Ross came fo see me im Jerusalem, [ think he expected to find me more distraught than | Gel OF course, 1 wis disappointed. But {old lim | was erateful thar Clinton had stayed with a negoriaring effort that had been frustrating tor all of us, When | became Prime Minister, I'd assured the Americans that as Tong is our vill scearity inlerests were protecied. | was ready 10 go Guth thin any previous Israeli leader to get peace with Syria, and with Arafat too. I might Hail, but it would not be for Tack of trying, 1 believed that even a “failure” wauld tell us something: whether the other side was truly ready for pce. With Syaa, | told Dennis, “10s sot what we hoped for. But at least now we koow.” 335 BARAK 150 My own negotiating Leam, nol to mention the Americans. assumed 1 vould now Lun my attention to the Palestinians. Arafat was pressing for us 1 go ahead with hase-two of the Wye redeployments, In fact, he naw wanted us fo add fhe transfer afthree Arh villages on the edge of east kernsalem: Eizarie, El-Ram and, most importantly. Abu Dis. since from these you could see the golden done uf the mosque above the Western Wall in the Old City. I understood why the villages were politically important for hin. But in practical terms, 1 also new 1'd have to secure the support of the cabinet and the Kugsset for what the Likud, and the main religious parties too, would interpret as a first step foward “handing back Jerusalem.” For me. this underscored the problem at the heart of Oslo. We were trans erring land to Arafat. yet still without any serious engagement from the Palestinians on the “permanent-status” questions, ike the furture of Jerusalem, that were critical to the prospeets for real peace. They were eitical, in Fact, even Lo reaching a Iramework ageeement, or a declaration of principles. as a basis for a final teeaty. T probably should have seen the crisis-ridden spring of 2000 as a harbinger of the diflieuliics when we rally gol (0 that stage. | did mike a frst major effort 1o find. compromise ground on the main issues. | sent Gilead Sher and Shlomo Ben-Ami to begin back-channel talks with a Palescinian team led by Abu Ala‘a and assan Asfour, the srchiteets of Oslo. But as 1 prepared to seek Knessel approval for ceturning the three additional villages to the Palestinians, my main Grthodox. coalition partners. Shas and the National Religious Party, as well as Sharansky's Yisract ha "Aliyah, all threatened to walk out of the government. I did manage to keep them on board, but only by geuing the Knesset vole classified as & no- confidence motion. That meant that if we lost, the government would fall and there would be new elections. That was something none of them wanted. They feared that Arik and the 1.ikud woukd do beticr this time around, ind they would end up with fewer seats. Still, even thar didn't avert a different kind of crisis. The vote was on May 15. For the Palestinians, this wis iso Al-Nagha Day, the anal marking of the 1948 “catastcophe” of the Founding of the State of Israel. Danuy Yatom wld me the night before there were intelligence reports of large protests planned for the West Bank and in Gaza. President Clinton immediately got the American consul ta deliver a message lo Asafal, saying that the President expected him 1 intervene against any sign of violence. But Arafat's reply was that, while he'd do what he could, he 336 {BARAK 751 couldn’ puacantes anything. Tn the months ahead [ would come 10 understand what that meant, because it would happen again. T don’t think Araft himselt archestrated the violence, Maybe he couldn’ have stopped it completely, But 1 lisve no doubt — nov did President Clinton — tht he stood aside and let al bippen. Even worse = since he did have control over them — his security forces, with arms that Israel had provided as part of Oslo. fired on our troops as they tried to leep order. All of this, while I stood in the Knesset battling to get approval to give him te villages. As news arrived in the chamber of gunfise just a couple of miles away, it was not just Likud or other right-wing MKs who were furious. [ certainly wars. Yet | also knew thuf the price of losing the vote would be the fall of the government. We did win the vote, by a margin of cight, meaning that | now had Tull authority 10 retuen the three villages. Fuming over what had happened, however, 1 called President Clmton and tald him [was gomye fo delay the handover. T was not aboul to retur the villages under gunfire, oe reward Arafat for breaking even his existing sceurity commitments. ‘That meant that prospects for serious negotiations with the Palestinians were aiguin on hold, But anather, immutible, priority would probubly have delayed any new initiative anyway: my pledge w gel our soldiers out of Lebanon withiu a year of the election. 1 was determined to go ahead with it not just because Id promised Israchs to do so, 1t was because | knew from experience that without setting a deadline aud sticking 10 it, it wouldn't happen. | had been against kecping the security zone (rom the stare. Over the years, many Israelis. both inside the military and beyond, had come to accept we would be beter off pullmg our, Tt wasn't just the itriional loss of Israch soldiers” hives, but the fiel that there wis no obvions point, and no obvious end, lo ow mission there. Especially when major tragedies acourred - like the collision of two Israeli helicopters a couple of years earlier, Teaving scores of young soldiers dead — there was fk about s withdrawal Yet there was always a reason 10 reconsider, to put it off: a ITizbollab attack in the Securify zone, accusations of weakness from right-wing politicians, of siple caution in the kirya. The only wisy 10 gent done was Lo dead, snd 10 do il. My self-imposed deadline tor the pullout was now just cight weeks away. Tlizbollah had already begun escalating pressure on our outposts in south Lebanon with the abvious am of making the withdrawal as difficult as possible. They were also targeting our local surrogates, the Maronite-led South 1Lebanese Army militia. T'd been meeting regularly with Shaul Motaz, the former pacatroop officer who 337 BARAK /52 was now chiel of stall, to eosuse we had a plan 10 el our troups out as quickly and safely as possible once the order was given. Bul complex though the operational issues were, that was nat dhe most difficult part, The withdrawal had not just a military am, bi erilical political one: to denude Hizbollzh, with full international support. of its “occupation” fig-leal for targeting and lecrorizing the towns and villages of northern Israel. Shaul and a number of other generals in the Airy ied 1o make the security argument for keeping several small hilltop outposts just noth of the border. But | insisted not single sracli soldier or emplacement remain on Lebanese soil. Throughout the spring, we had been coordinating every derail of the planned pullout with UN cartographers on the ground. ta ensure that they. tov, recognized it would be a full withdrawal to the border. fulfilling the terms of the Security Council resolution adopted after the 1952 Lebanon War. Ordinarily, an operation on this scale would have been carried cut over a period of weeks. Bul when we handed over a pair of military stcongholds to the South Lebanon Army, and Tizbollah promplly moved in 1o take them over, it was clear that even several days might risk chaos, and casualties, as we left. The head of the northern command now supported an immediate withdrawal, and 1 agreed Frustratingly. we did heve to hold off for a further 36 hours, in order to ensure the UN staff on the pround could complete their verification process. Buc on the allemoon of May 23, alongside Shisul Mois at a command post on the border, [ ordered the pullout of all [sraci troops, vehicles and other equipment within the space of 24 hours. I then flew back to Jerusalem for a urgent meeting to secure formal cabinet approval. The field commanders ended up getting it done in fess than 24 hours, mostly overnight, without a single (saci casualty. lor nearly two decades. our troops had been serving and dying on a strip of land on which we had 10 claim, no settlements, and for which there was no rational security need Finally, we were aut, As T should have anticipated. there were acousations from TTizbollab and its allies that our UN-verified withdrawal was incomplete. At issue was a cluster of villages where Lebanon meels Syd, known as the Shebi’s Farms, Buta | knew first-hand. they wese not part of Lebanon. ['d met their Syrian inhabitants whea | helped “capture” the villages at the very end of the 1973 war on the Golan. When Syria now publicly supported Hizballah’s effarts fo wet fhe LIN to say the area was in fact part of £ebanon, 1 decided to call their bull. Through the Americans, | 338 {BARAK 753 suggested that Damaseus confirm in writing that this part of the Golan was indeed Lebanese. The Syrians never responded Equally predictable were the prophets of doom on fhe Israeli right, who said the 1ebanon withdrawal would bury northem Israel m Katyushas and in blood. The reality was that in the half-dozen years following the pullout, the lseacl-Lebanon border was quieter than at any time since the late 1960s. The main personal impact af the withdrawal, however, was to remind me of why 1'd run for Prime Minister in the first place. Despite the challenges, and inevitable setbacks and frustrations, of my first year in office, 1 was in a position to act on what [ believed to be critical sssues for my countrys future, On | ebanon, Ud succeeded. mainly because the withdrawal was something we could do unilaterally, With Syria, 1d tried had to ‘pet an agreement. only to find that Assad was unwilling, unable, or perhaps tou il] ta join in the search for a deal, 1 still recognized, however, til no issue was more important to [srsel™s tre than our conflict with the Palestinians. | knew that sesolving it would be even tougher than the talks with the Syrians. But the only way to find out whether peace wis possible was 10 try. So an The final diy of May 2000, with the |.cbanon pullout complete, | Mew to Portugal — the site uf a US-Euopeau summit — to see President Clinton. 339 {BARAK 751 Chapter Twenty-One President Clinton and T met the nest moroing. My aim was 0 persuade him that the tine had come for a make-or-break summit with Yasir Arafat. 1 suspected it would not be easy to convince him, and it wasn't. But [ made the argument that if we were tw have any hope of moving Oslo forward, we now faced astark choice. We were three years behind the timeline for starting work on a “permanent status” agreement, and only six months from an American election that would choose President Clinfon’s successar, We could, of course, pursue the Oslo process along its current, meandering path. But even though Bibi had slowed it down, that would inevitably mean Israel handing back yet more West Bank land to Arafat in return for familiar, but still unfulfilled and untested, verbal assurances that he wanted peace. bach snecessive Israch withdrawal redoeed his incentive fo engage of the core issues like final borders. refugees, or Jerusalem. [ could nor in oad conscience justify that, either to myself ar my country. The second aption was the summit. | realized there was no gnaraniee 1 would succeed. But it would finally force Arafat to negotiate on the core issues — before the departure of an American President who had a grasp ot the all issues and characters involved, and a personal commitment 1 convertmg the promise of Osta ilo # genuine peace. The obvious political isk, for both Clinton and me, was that after convening a summit with all the heightened expectations and pressures it would bring we'd fail to get un agreement, Thoth I'd be more directly affected, however, it was a more straightforward choice for me. Tn part because I'd been in front-line politics 50 briefly, but mostly because of what 1d done for the three-and-a-half decades before then, | viewed the political tisk as just one of miny, and by no means fhe most import “Thal wis wn obvious weakness in me aso traditional politician. | would indeed pay a political price later on for having piven too little heed. and ‘perhaps underestimated, the reaction in Iscael to the summit and what came after it, Yeu ried w iapress on President Clinton, there wee risks in at holding a sumimil as well. along with the obvious reward of a [ull and final peace if it succeeded. [Fit failed? Atleast we would know a peace agreement with Arafat was possible. hn fel, amet the diplomatic dif since Oslo, it wars clear there wis no other way that we cardi know 340 {BARAK 755 Walking with the Presideat in Lisbon’s spring sunshine, T tried 1 summon up a0 image that would bring both of us back to the starkly different ceality of our contlict with the Palestinians, Only two weeks earlier, Arafat's own police force, with weapons we had given them, bad opened five as | was fiying fo gel Knessel approval for returning three villages that Ae wanted. Aller 1 took office, ['d ordered a full-scale intelligence review of the security situation with the Palestinians. The sobering conclusion had been delivered to me six months carlier: plans were well underway by cells in the West Bank and Gaza for armed auachs against lssacli soldiers and terror strikes inside Israel. “It’s like two families living in the same house, and it’s on tire.” 1 said. “All of us are rushing to put it out. But there's this veteran firefighter who avives on the scene — a firefighter with a Nobel Peace Prize - and we have no way of knowing whether he’s got matches and gasoline in his pocket.” We had to find that out. | said. We had to establish whether we were all firefighters, and could put out the Names. Clinton and 1 had gol 1 know cach ather well. In one-on-one conversations like this, we called each other by our first names. though I was careful to address him 5 “Nr President” when offers were there. We'd been trough a lot together. [had 00 doubt that he wanted Lo put out the fire every bit as much as [ did. But 1 also realized he had emerged frustrated. and bruised. from our last joint effort at pescemalang: with Hales al-Assud. | was the one who had been pushing the hardest for hint to meet Assad in Geneva, over the objeetions of some of bis closest aides that it was likely to go wrong. Not only were the aides right. Assad had ended up delivering an extraordinary personal rebuff to the President of the United States. Now, | was again asking President Clinton for a summit, and | knew Madeleine Albright, Dennis Ross and others would be highly sceptical. “T understand they 11 have doubts. 1 understand their reading of the risks,” I told President Clinton, “But 1'm convinced erucial issues are at stake, which justify the risks. Let's move forward.” Bur Clinton was skeptical, too. 11e said thar without some sign of diplomatic progress between us and the Palestinians, be could see no way of holding summil. With Arafat due to see him in Washington in a couple of weeks, he said that I first had to give the Palestinian leader something: tae three villages, a Drisaner release, or perhaps unfreeze tax revenues which we'd been holdin back as leverage for al lost some progress on the core issues. Otherwise, Clinton said he was certain Arafat would refuse to attend a summit. And even if he said yes, 341 BARAK 156 Clinton felt we would aed a drafl document with broad areas of agreement before a diplomatic “endgame” could begin. T disagreed on tha. 1 argued that if we tried to produce such a document, there would never be 1 summit, In fact, we'd never eta dra) document worlh anything, “Neither side is going to commit itself on issues like borders, refugees, or Jerusalem.” 1 said pointing oul that even in our back-channel talks. the only forum in which there had been a hint of progress, those issucs had barely been touched. He did accept that “pre-negotiation” would never crack the main issues. But he sill said that before he could contemplate a summit, he would need Madeleine Albright and Dermis Ross to talk in detail with us and the Palestinians. “There had 10 be a firm basis fo work on, he said. Fven therm be said, he wes almost sure Acalat would resist the idea of a summit. And on that last point, he proved right. T spoke 10 the President by phone after Arafat's trip to Washington, “He thinks you're leying 10 tap hin into a summit, and that when it Fails, Ull blame ki.” he Lold me. ‘The very next day. the stakes increased dramatically. For months, military ieligenes had been waming of the polential for violence if we couldn’ find a long-term political resolution of the Palestinian conflict. But the seport which landed on my desk on June 16, 2000 was more specitic. lt said Arafat had called in Ins sceurity peaple and said: “My strategic understanding 1s that sracl 1s not inlercsted in teaching a deal. Therefine, we sie preparing ourselves for a violent and prolonged conflontation.” A few days later. we got an even more waitying report, sams the security officers had been told ta begin “intensive trainmy.” Arafiel wis quoted as saying: “Ihe Palostinian Authority is confronted by a strong and dangerous Tsrael, headed by a Prime Minister who is not interested in real peace. The proof of tha is that when he was Chief of Stat. hie was the only senior flier to oppose the Oslo Agreement” | snmmoned my scenrily team: Mofie is chief of stall the heads of military intelligence, Mossad and the Shin Bet. T told them that Arafat was wrong. My inalterable “red line” would always be Israel's ational and seedy mierests. Buta long as those were profeeted. 1 wasn’t just interested in reaching an agreement witl the Palestinians. [ was determined w do everything possible to try to get ane. But 1 also said that we liad to make sure we were fully prepared tor responding fo “Palestinian violence and, af some stage, Tall-blown teroe.” 342 {TARAK / 57 oes A few days later, the “pre-endgame” around the summit began. Not in Washington or Jerusalem or Ramallth ar Gaza, but in Kochay Yair, Nava and | still spent almost all our weekends there. We valued the quiet, or at least the slighty quieter, ime away from Jerusalem or Tel Aviv. Some of my oldest army friends lived there as well: anny Yatom, as well as Shaul Viofiz and Li Dayan, who was now deputy chief of stall. Newer colleagues, Loo, like Yossi Ginossac, a Shin Bet veteran who spoke fluent Arabic and. after working in the West Bank and Gaz in the late 1960s became one of the first Israelis to hald secret talks with Arafe, burlding tp pesos] relationship with him. Under both Rabin and Peres, he had been a valuable liaison with the Palestinian leader. Nowan under my Premiership as well, “The summit seemed to me more important than ever, but | lew tht anly President Clinton could make it happen. Short of giving the Palestinians the whole Hist of short-term rewards they wanted, including the three villages, [knew Arafit was never going to be enthusiastic, But if Clinton was persuaded that a peace agreement was within reach. T had confidence he would make the effort. 1 bad allowed Gili Sher and Shlomo Ben-Ami to go to Washington the week before for exploratory talks with Dennis Ross. Shlomo, us | knew he’d done in the buck- ehaunel talks with the Palestinians, had gone beyond mything ihe 1 would or could say at this stage in order to probe the edges of where an eventual compromise might be possible. Now Clinton had sent Dennis fo Isragl, with Madeleine Albright to follow at the end of the month, ind | bid to sue that their impressions would be critical to bis decision on whether to bring me and Arafat to Camp David, We agreed to meet Dennis and his team at Danny’s house in Kochay Yair, By the time I'd made the pleasant Shabbat-afternoon stroll from our house, a few streets away. they were in the back garden sipping lemonade and munching on Papo, 1°d met often with Dennis during my year as Prime Minister, and | lied hin. Tle was smact, knowledgeable and expericaced. Tle'd worked under three US Presidents: Carter, Bush Senior and now Clinton. No American diplomat had been mare indefatugably involved m the search far Middle Fast peace. And whatever his occasional fastrations, be also recognized | wis ready 10 go further than iy 343 BARAK £58 previous Tsracli leader in Leying Lo get that peace. Tnew that he would press me w tell bit how fa that actually was. Ie didn't ask directly. But each of his ostensibly theoretical questions was aimed at establish whether | could give him enongh for a sunmmit to bridge the gaps on key issues. Could 1 accept a “trade-ofl between sovereignty and time?” Translation: could | tive the Palestinians sovereignty over a larger part of the West Rane of we signed an agreement that would phase in their control? Could [accept the principle of land swaps? 1his meant giving Arafit land in sicas bordering the West Bank. or in the Negev near Gaza, to compensate. at least partially, for the area we would keep for the major settlement blocs, What about applying my. prisiciple of “disengagement” between [sacl sud the Palestinians lo Jerusalem? Meaning Arafal getting control of the predominantly Arab neighborhoods in the east of the ¢ity, Dems knew my lng-standing reluctance 1o comma to concessions mil we. 20L 1¢al, final negotiations with ArafaL “We'll not reveal anything you tell us,” Tre assured me. “We won't turn what you say inta opening negatiating positions for Arafat. But if there 1s going to be a summit, the President wanted some answers.” “To Dennis's frustration, however, | could give hit no specities. beyond telling him: *“You know me, Dennis. You know I'm serious about this. Of course, we will Protect our vital security and national interests. But the problem in muking peace won't be us, ou the Israeli side, as loug as Arafat shows a capacity and « will Tor decision.” The translation of thar. as Thoped and trusted he understood was that if and when Arifar demonstrated that he wanted a comprehensive peace between a new Palestinian state and the State of Ismael — a definitive “end of conflict” ws the international lawyers would describe it — T would place nothing. except our secusity and core national interests, in the way of getting an agreement Madeleine Albight visited ut the end of June. When she came lo see me wu day aller meeting Arafat, she carried a request from the Palestinian leader: two week af “preparatory” talks before a summit. Again. | knew her mission was to bring buck enangh progress for the President lo feel a summit was worth i, But agam, 1 couldn't give her what she wanted. “t know what will happen in preparatory talks.” 1 said. “We'll raise new ideas, which the Palestinians will reject, and ask for more.” don’t know what she told Clmton, or Arafat, But Dennis called me the following day. He said that Arafat had agreed w attend a summit, snd would leave the date up to the President 344 HOUSE_OVERSIGHT_011815. BARAK {59 When Clinton phoned me at the beginning of July, however, he still hadu't finally decided to hold the summit. [needed him lo know that, on my side. he'd have a truly willing partner, ware of the political risk he'd be taking, 1 ike Dennis, the President tried fo probe my position on land sways, und Palestiniun sovercignty for al least some Arab neiglibochoods in Jerusalem. Finally, he asked if 1 would rule out those possibilities if they represented the difference between success or failure ata summit. | did not give hint a definitive “yes.” | said we could think through thse issues logether. But when he phoned again. oa July 4 from Camp David, 1 felt I had to go further. T said that, for his ears only, 1 was willing to give him the assurance that, assuming; that Arafat was willing fo move foward us on cone issues, | would consider limited, symbolic moves on both land swaps and Palestinian sovereigaty in pact of Cast Jerusalem. Clinton replied: the summic was on. It would begin at Camp David in one week's lime, on July 11. PE “Two days before caving for the US, [brought my ministers together. “We can’t Tow what will happen at a summit.” 1 said. “But we have a responsibility to give Wa chance, and recognize the situation in which we find ourselves, we sit ilk: and don’t eve try, we'll face an eruption of viokaee, and never know whether we could have avoided it. If, God forbid, we fail 1 reach an agreement, there will also be violence, We will face u new reality mare difficult than you ean imagine. But if we do mage the suike deal, we nre going 1 change the map ad history of the Middle Fast.” T reminded them it would be up to Tsraelis 10 say yes oc no. in a referendum, to the terms of any agreement we negotiated. “If we achieve a breakthrough, Um conlident they will do so, by i landslide.” said 1 would hold fast 10 & number of principles. 1here would be “no return to the 1967 lines,” meaning that we would draw a new border with the West Bank to accommodate the largest settlement bloes, They were mostly around Jerusalem, or just beyond the 1967 border. In practical leans, over the years they had become part of Tsrael. Tens of thousands of people lived there. As the Americans and even the Palestmian negotiators recognized, no lstach government, Labor or Likud. 345 BARAK (60 would agree 0 make them part ofa Palestinian state. The second principle was that “Jerusalem will remain waited.” IL would not be cut into Jewish and Asab halves as Tad happened between 194% and 1967. That, | knew, might prove tougher ta cary through on, But even iC had lo concede i degres of Palestinian control in parts of cast Jerusalem, 1 expected to be able to retain Issacli sovercigaty over the city. The third principle was that there would be “no foreign army wes of the Jordan River.” In other wards, if we did hand back at least the niajor part of the West Bank, it would be demilitarized and we would have secuity conteol over the Jordan Valley Finally, we would nat “accept responsibility for the birth of the refugee problem and its solution.” Though there could be a “right of retum”™ info a new Palestinian state, we would not agree to rewrite the history of the 1948 war by sanctioning the resettlement of hundreds of thousands of Palestinians inside the State of Israel. 1 think it was the very fact we were talking about a comprehensive peace agreement thet made it so hard for my Orthodox and right-of-center coalition partners. They didn't see the aticaction of coming to final terms of peace. They knew it would mean concessions. There would be a Palestinian state. We would ive up the grea mujority of Biblical Juda and Surusia. While most of the settlers would remain, since they lived in the major blocs, those in morc isolated settlements around the West Bank would have to be moved. They saw the prospect alla fim peace only in tems of what we were gvmg up. They dida’t see what we would gata: nol just peace, and international recognition aud endorsement for it. But normalcy: the central aim of Zionism. Jews living in a state like any other. Ever since 1967, we had been in control of the daily lives of hundreds of thousands of Palestinians on the West Bank aud in Gaza. That was bad for them. But it had been bad for us too. Fifiy-fivo years afler the bith of our state, we still didn’t have a permanent, internationally recognized barder. Rather than dealing with our weonomic and soil issues like other states, we were best by intemal divisions that were in 50 small part a result of our unresolved conflict with the Palestinians. Shas, the National Religious Parc and Sharaasky’s Fisrael be Aliyah were all threatening to pull out of the govenment because of the summit. Nothing [said could change their minds. Sharansky was Lhe fist 10 declare bie was leaving. A fow hous later, Shas and the NRP followed suit. If the Likud mustered the required 61 votes for the no-confidence mation it was introducing before 1 got on the plane fo the US, the government would fall. [Fthe parties that had lef the coalition, with a total of 28 seats, went along with Arik Sharon, it wouldn't be close. As if that 348 {BARAK 61 wasn't enough, David Levy. my Foreign Minister. old me be would not be joining me at Camp David. [le wasn't resigning. at least not yet. But he knew that the final decisions at the summit would be mine, he feared it would fail, and didn’t want to stu in the consequences. None of this meant | wasn't going. Liven if the no-confidence vote suceeeded, the new Israeli electoral system, with its separate vote for Prime Minister. meant [ would remirin in office, at least until the summit was over. In a nationally televised message, | reminded the country that I'd been elected with nearly 1wo million votes. I felt I had a responsibility. and a mandate, that went beyond parc palitics. “I must rise above the politcal arguments, and seek out all possibilities on the way 10 peace gercemen that will cod the conflict, aud the blood, between us und our neighbors.” T made the same points before the Knesset. T did. of course, want parliamentary support. But 1 was acting on a mandate from the people of [srael. [t was they, in a referendum, who would ultimately decide on anything we might ageee. When the Knesset voles were counted, thanks 10 the fact two dozen MKs abstained, both sides lost. Arik fell seven votes short of a majority. So the government survived Bul those apposed to The summit gol move voles han we did: 5410 52 There were several consolations as I prepared to tly out from Ben-Gurion aport, Shas leuder Eli Yishai passed me an envelope on the tarmac, Inside was a nole (rom Rabbi Ovadia Yossel. the Shas spiritual leader whom 1°d met with privately afier the election and a number of times since. Ile wanted to wish me 00d luck, Nearly 30 reserve generals also issued «public message of suppart, Perhaps most enconragingly, a newspaper poll found a majority of Israclis — 55 percent 10 45 — believed Twas right © 20 tv Camp David and that T had a mandate to make concessions in return for peace. David Levy came over w lk before | bowrded. “1 donb! we'll gel am agreement.” hie said. [told him what | was telling other ministers, what I'd wold reporters and, in fact what 1 had told Nava. “The odds are fitty-fifty.” The reporters took this us coy, or defiberulely deceptive, So 1 udded thi it was not because | Knew something they didn't, “11's because there are lwo possible outcomes, and | don’t know which one will happen.” The gaps of substance were bridgeable. The question was whether both sides wanted peace, and whether cach had made a serious, strlegie docision lo go Gor it. 1d made that choice. Bu {had no way of knowing whether Yasir Arafat had. 347 BARAK £62 Twas confident of finally answering that question at the summit. Camp David was different from Shepherdstown. No reporters would be there. Mobile phones were banned. Fach delegation had ane landline, We'd alsa be operating under a time constant. President Clinton was due 10 keve for a G8 siminit in Japan on July 19. The gave us barely & week. | did wonder whether that would be enough, even if both sides were conuniteed to reaching a peace agreement. Yet] hoped it would at least provide the possibility, as it had for Begin and Sadat twenty-two years eaicr, to reach a framework agreement that open the door to a (inal peace Treaty. Not just the time, but the umbers were limited. We and the Palestinians could have only dozen members in our negotiating teams. Some of my choices were automatic: Danny Yatom; Shlomo Ben-Ami, whom I'd made acting Foreign Minister m [.evy’s absence; Amnon Lipkin and Atomey-General Flyakim Rubiostein: Gilead Sher and his chief negotiating aide. Gidi Grinstein. [also took along a strong security team, including Shlomo Yanai. head of scatepic planning the kira, and Israel Iason, a former deputy-head of Shin Bet. There was another smportant, 1F less obvions, inclusion: Dim Mendon. A leading member of the Likud before he'd formed the Center Party at the last eloction, Dan was not just a friend Ile was a man of rock-solid integicy. with strong moral and ethical compass. who pul principle over party. He was also i lawyer, and had been Minster of Justice under Bibi. Along with Auomey-Geneeal Rubinsicin, | kaew I'd have a gifted legal team if we got to the point of considering the specifics of a peace agreement. There was another consideration as well. Both Dan and Elyakim were right-of-center politically. 1 fell | noeded eis voices as a kind uf litmus for the tough decisions. and concessions, I might have w consider if an agreement did prove possible. Twas not nervous us we crossed the Atluntic, though even those who knew me best assumed 1 would be. Nava had seat me off with a list of dictary instcuctions. almost like a surgeon general's warning thar Camp David might prove hazardous tomy health. But {fell prepared. 1°d gone to every sonree | conled fine shout the Begin-Sadat summit. T knew there would be periods of crisis and thal at certain points I'd have to allow leeway for ny awn teain to explore possible compromises beyond our set negotiating limits. Yet none of this altered my belief that holding the sumenit was the right thing Lo do, nor my confidence in being sb to play my part. [did feel a Inge responsibility. Decades after our conflict with the 348 {BARAK 63 Palestinians had begun, seven years after Oslo, T was making an attempt, with the participation of the President of the United States. to shape the final terms of peace, | knew | carried the conflicting hopes und fears of Israelis with me, And the odds really were 50-50. Either we'd come home with an agreement, to be placed before the country in a referendum. Or we would know that, at least for now, it was beyond reach. 349 {BARAK 61 Chapter Twenty-Two ICT believed in omens. [might have turned back as soon as we got to the summit, We reached Camp David a hittle before fen at might an July 10, after belicoptering (rom Andeews Air Force base near Washingion. When we arrived. it was pouring with rain. The cabin assignments were also a surprise. Twas given the ane that Anwar Sadat had at the first Camp David summit in 1978, Arafat got Menachem Begm's. Sill the bins themselves, cach named for i tree, were kage and pleasant. Mine was ealled Dogwood. It had a bedroom, two large sitting rooms and a terrace. [ took it as a good omen that it was the same one where Nava and I usd stayed during our visit with the President Clinton and Hillary right afler 17d became Prime Minister. With just eight days to address the core issues of decades of conflict, we got down fo work the next moming. Clmtan began by meetmyr Arafat, #s | went through the Americans” sirategy for the negotiations with Madeleine Albright, Dennis Ross and Martin Indyk. Then I met the President in his cabin, which was called Aspen, He told me that while Arafat sull thought [ was trying to “trick him™ into un agement, und didn’t think we'd necessanily got # deal. he did accept | was serious about trying. My fear was still the opposite, that Arafat was not serious. Yer my hope was that the isolated environment of Camp David, and the wide public expecta thi we would accomplish what Sadist and Begin had dove there before, would deliver the breakthiough that I believed ought w be possible. Tor that to happen. T told the President, I believed it was essential that Arafac truly understand the importance of wit was a stake, Not just the cost of fahure, bit what was potentially on offer: the creation of the Palestinian state he sought, with the full acceptance of Israel and the support of the world. 1 wish 1 could say I was optimistic when Clinton led the two of us inte Laurel Tadge, the lurger cabin u few bundseds downhill from Aspen, for the opening session of the summit. The scene at the front door — with me bustling Arafat ahead. with the intention of allowing him to enter before me - yielded the best-known image from the summit. Captus hy the television crews allowed info the compound foc the eecemunial opening, it spawned a couiage industry of political speculation and armchair psychoanalysis purporting to decipher what it meant. Some sand it was an enconryang sign of “chemisiry” belween me smd Aral, a not 350 BARAK (65 unreasonable guess, since both of us were grinning throughout, Others concluded that because each of us was trying to nudge the other to go in first, it was a sign of underlying contlict; neither of us wanted to allow the other the privilege of appeing lo be polite. SEI others, bizarrely, said tha if wis un orate Middle Eastern power play. with the aim of demonsiealing that / was ultimately in contcol of proceedings. In fact, it would turn out to be a singularly apt image of what happened in the days that followed: a reluctant Aca. au engaged and expectant Prime Minister of Israel. a smiling and hopeful Clinton. We did begin on a note of optimism. Tn my opening statement, T said: “Now is the time for us to make a peace of the brave, to find uw way to hve together side by side wilh mutual respect, and 10 cereale a better fue for our childs.” Arafat said he hoped that the peace Begin and Sadat had made at Camp David would prove an auspicious example, “With the help of President Clinton, we could reach a deal that is good for both sides.” But it was going 10 lake more than noble words. The details of a peace treaty, or even a framework agreement, were going to require negotiation. Both Arafat und 1 arrived fully aware of the shape of the “hard decisions” 1d referred lo months. earlier when we met in Oslo. Ou his side. it would come down to whether he was prepared for a comprehensive. final peace. A true “end of conflict,” with no get-out clauses, no strings lefl untied, no further clams on either side. In concrete tenms, this would mein abandoning his claim for & notional hundreds of thousands of Palestinian refugees 1o resettle inside the pre-1967 borders of the State of Tsrael, And what were Israel's difficult decisions? In return for the end of conflict, 1 would have to deal away the maximun possible part of the West Bunk, certainly well above the 80 percent I'd quoted Shimon Peres &s suggesting when I'd first met with President Clinton. I would have to accept the idea of land swaps, if mecessary, in order lo bring the overall percentage as near as possible lo the equivalent of the whole of the West Bank. T would have to be exible on the arrangements to easure Israeli securicy oversight over the Jordan Valley. Aad if a true pesca was really an the tbl, both Ara snd 1 would Jive 10 consider som form of comprontise on the most emotionally and symbolically difficult issuc of all: the future governance of Jerusalem. On the first evening, we met as an Israeli delegation to discuss our position for the days ahead. Gili Sher and Danny Yatom helped me koep a clear overall picture of proceedings throughout the summit. Our secure landline was operated by a Shin 351 BARAK (66 Bet technician. T assumed that, one way or another, the Americans could listen in. but was (airly confident we were beyond the electronic earshot of the Palestinians kept myself flly informed of, but at a distance from, the specific work of our five negotiuting leas. Thongh | contd not have siayed engaged with ull of them 2 the same time, | also hoped the arcngement would give them an opportunity 0 explore any realistic opportunity for a breakthrough and any sign of flexibility on Acafit’s side — without committing me until there wars such flexibility. Yet for the first coupk: of days of the summit, there was not only 1o sign of flexibility. There was little meaningful engagement. Dennis Ross and his team drew up a paper setting out the main issues. For those on which we differed, our positions wore marked with “1 snd “P11 wasn't until sound midight on day- wo that the we got a first look at the American drat. The main, unhappy, surprise was Jerusalem, This crucial issue was nat marked with “1” or “I” It said outright that there could be two capitals. one Tscaeli and ane Palestinian, within the city of Jerusalem. 1 was uot opposed to the Palestinians calling Jesuselem the capital of their state. But even in follow-up talks afer Oslo, whea Yossi Beilin and Abu Mien hid explored avenues toward a possible resolution of the Jerusalem question. the maximum understanding was that Iscael might expand the existing city limits to accommodate the “nwo capital” solution. The Palestinians” capital would be in Abu Dis, on of the villages Arafat bad asked me to hand bick i Vay. “Ihe way the American document was worded suggested dividiog Jerusalem as it now was: something ruled out by all Tscaeli politicians, of all parties, ever since 1967, When | phoned President Clinton, he asked me to come talk. We sat on the back tecrace of his cabin, looking oul incongruusly on & beautifully tended golf hole installed by Dwight Eisenhower. 1 rold the President that after all the hours we had spent together, 1d felt blindsided by the inclusion of a proposal on Jernsalem tha went beyond anylhing we'd talked abou “IL was my mistake, he replied, obviously already aware through bis negotiators of the error. Ile said that he'd put pressure on his acgotiadons t gel the document imshed, and that Denis hadn't had time 10 read it through. But it was alseady being fixed: the word “expanded” would be added to the Jerusalem section. 1 was grateful for that, but told Clinton I was concerned that even this “1 and P” paper might have the unintended effect of delaying any real progress. “Since i's an American document, it gives the Palestinians no incentive to compromise,” I said, suggesting that it might be better 352 {BARAK £7 simply to withdraw the paper. Clinton's answer encouraged, and surprised, me. “We agree,” he said. “The paper no longer exists.” It soon turned out the Palestinians were unhappy with it too, but for another reason, On the lookout for vithudatom of Arulit’s insistence thal Camp David was an Ismach “tap”, they were convineed that the paper had Israel's fingerprints all over it. That wasn't true. The one change we'd insisted on was because it misrepresented our position on Jerusalem. Still, since Dennis had added the word “expanded” to the Jerusalem soction in longhand, the Palestinians were convinced of Israel eo-authorship. Ta fact, three days into the summit. the mood among the Palestinians seemed mrcasingly amrieved. Nat just the Americans, but some members of my own eum, were nrging me to show more “personal warmth” lowands Arafat. [did always exchange greetings and pleasantries with him af mealtimes in Laure] Lodge, but even there, 1 admit, that [ didn’t exactly shaw enthusiasm, much less <bullience. Alter one dinner, when I'd been placed between the Palestinian leader ad Chelsca Clinton, the President's National Security Adviser, Sandy Becger, asked me why, rather than talking to Arafat, I'd spent almost the entire time ehting with Chelsea. My response was only bill-joking: “Given the choice, who wouldn't?" It wasn’t only that [ believed a charm initiative would come over as contrived. 1 didn’t want fo risk mislcadm Arafat, the other Palestinians and possibly the Americans as well, by giving them the impression | was satistiod with the progress of the summit, or felt that we were heading towards any serious engagement and compromise on the care issues. | had met Arafat many times before Camp David. 1 hac mace it clean in all of those meeting that, despite differences on avange of diflicul issues, T did want a final peace agreement and that T was ready to consider the tough decisions necessary to make it possible. At Camp David. [ was not agguist meeting Andtiad ass mater of principle. 1 simply fell the time for such a meeting, if il came, would be at the moment that we saw at least see signal of a readiness on his part to negotiate seriously. Sill, sven the sirengih of feehmiz among some of my own negotiulors, | fell a respousihility 10 give ita 1ry. | told Yossi Ginossar, the former Shin Bet officer who was closest (0 the Palestinian leader among the Tscaelis. to set up an informal meetmge, 1 added, to Yossi's obvious satisfaction and surprise, that 1°d be willing to have the meeting in Araflac’s cabin if that’s what be preferred. ‘The next aflernoon, went there for tea and baklava. Abu Mazen, his top political adviser and the main 353 BARAK {68 Palestinian architect of Oslo. was with him, slong with a moce junior aide who served the fea and sweets. At least this time, Arafat didn't take notes as we spoke. The moad was friendly, We talked about a whole range of issues. With ony ane exception: what wis really lppening, or what should happen, in the summit tafks. 1 found the exeroise disappointing as & resull. But Yossi Ginossac assured me it would help the atmosphere, and would eventually translate into negotiating progress. “L hope 50.” | said 10 wasn’t until day-Gour that real talks began, The Americans aranged for negoriating teams from both sides on borders. the refugee issue. and Jerusalem to meet with President Clinton, The Palestinians participated, but showed no sign at all of arcadiness 10 compromise. Borders should have been the most suaightforward. Assuming we wanted a deal, it was about sitting down with a map and working out how to address both sides” arzuments, But Arafat's representative in the meeting — the Oslo negotiator Abu Ala — said he wouldn't even discuss borders without a prior agreement Lo land swaps ensuing Palestinian contol over an area equivalent to 100 percent of the West Bank. Shlomo Ben-Ami did try to find a way around this. He suggested the Palestinians anne that lo be the case for the purposes of the meeting, so that at least there could be meaningful discussion of the border. including the provisions Iscael wanted in order to retain the major setlement blocks. President Clinton agreed tial made sense. He sid that without talking about the stbsiance of suell issues. there wasn't goiug 10 be a deal. Lven Abu Ala'a seemed receptive, according to Shlomo. But he insisted that he would have to ask Arafat first whether it was okay. On refigees, pretty mich the same ing happened. The Americans, sid | assumed al that point even the Palestinians. knew that a peace deal would be impossible if ve agreed to bundreds of thousands of refugees entering Israel - in effect leaving the state created in 1948 with u Jewish minority. Bil when President Clinton began trying 1 narrow down deteils of a compromise resettlement package ~ how many refugees would return. where they would po. and how to arrange nlermational Francia] support for them — Abu Mazen insisted thit nothing could be discussed until without a prior [srecli aceeplauce uf the “principle of the right of return.” On Jerusalem, according to Gilead Sher, the President didn’t even try to find commen ground on the care issue: sovereignty. Instead he used the formula Shlomo Ben-Ami had suggested. telling cach side to proceed vo the assumption sovereigary was decided in its favour. and to concentrate instead on how everyday 354 {BARAK 69 municipal functions and daily life would be divided between Tscael and the Palestinians under a peace agreement When | convened aur negotiators in my cabin to take stack of the logjam, | was setting more and more skeptical of finding a way to gel 10 actual negotiation on the “hav decisions’ | assumed both sides knew we'd have w make. 1 old our team we could not play that game. Lintil there was at least some movement from Arafat, [ didn’t wimt them suggesting any Israel concessions, We'd obviously get nothing in return, The sunimit would fail. Despite my repeated insistence both to the Americans and Palestinians thar, without an agreement, any Israeli supgestions would be null and void, that didn’t mean they would simply be forgatten, ‘The result is that we'd schnally be ing worse situation than before Camp David, Politically, I'd find myself in much the same position as President Assad, alter the leak of the American draft from Shepherdstown: apparently ready to consider piving Acafal the geeat majority of the West Bank, without the slightest sign Arafat wag ready for a [ull and final peace. But that wasn’t my main coneera. Tt was that anything that we put on the table here would handcuff future Israeli povernments if ancl when wn “endl of conflict” agreement became possible Still, when Denis Ross learned from my negotiators what I°d decided, he was trustrated and upset. He came to see me on Saturday morning day-five of what wits loakmyg increasingly like a stillbom summit, “his sommit was your idea,” he said, reminding me that the President had agreed wit over the reservations of a lol his own aides. ITe told me that at a minimum, Thad to help give it a chance: by ving him my true negotiating “red lines,” Kither that, or give my negotiators. more keeway 10 explore compromises. | did not want to make Dennis™s job ny ore difficult than it already wes. And [told him Twas still ready Lo engage fully if we ever got to the real substance of a possible deal. “But I can’t do what you've asked me,” replied. “Rol when Arafat is simply holding firm and not showing a willingness even Lo lock for compromises.™ Fortunately for my relationship with the President — though not for the prospects of an wgveement Clinton had considerably more sympathy with my position after his next meeting with both sets of negotiators that afleruoon. Jl was a return encounter with Abu Ala'a on territory and borders. Shlomo Ben-Ami now produced a mip of the West Bank with our propascd breakdown mio the areas thist would be controlled by a Palestinian state, the part Israel would refain tw accommodate the major settlements, and tercitory which we suggested would go to 355 BARAK (70 the Palestinians aller a transitional period. The part we had earmarked for Palestinian cuntcol was now a bit over 85 perecal of the West Bank, more than I'd indicated to the President in our first meeting a year earlier. But while Abu Ala’ ad fold Clinton be would ssl for Arafat’ permission at least lo negotin, he elearly hadn't received it. Ue refused Lo talk about the tap. or even respond Lo Clinton's suggestion thar the Palestinians present a map of their awn, until we did two things: aceept the principle of land swaps and seduce the size of the territory we were suggesting for the settlement blocs. To Shlomo’s, and 1'm sure even more 50 10 Abu Ala'a’s, astonishment, the President exploded. He told Abu Ala"a that ta refuse to provide any input or ideas was the very apposite of negotiation. It was an “outrageous” approach. Le stored oul. Tt was late that evening when the first move wward the “make-or-breal’™ situation [ had hoped for seemed to occur, though still with much more likelihoad lbreak than make. The President decided the valy way 1 make progress was to sequester pair of negotiators from each side overnight. Their task would be to search honesty for the autlines of a possible peace agreement. They were to update Arai unl mysel und then report 1o Chinon the ext day. Then, we'd see where we were. | agreed to send Shlomo and Gili Sher. my former “back-channel™ negotiators. 1 knew that whatever guidelines I gave them. they would probe beyond then, just as They'd dome in the baclechannel talks. They were negotiators. They were also sma, oreative, badly wanted an agreement and, like me, believed it ought to be possible. Though T would retain the final word to approve of reject what they suggested, [ knew fhat anly in a legal sense could it be null and void. | also recoguized, however, that we had to be willing to push further, both to find out for certain where the Palestinians stood and to convince the Americans we genuinely wanted an agreement. Shlomo and Gili left a little after midnight for Laurel Lodge, Marme guards were posted at the doors, with orders that neither negotiating Leam was to leave until morning without notifying the President's staff. Mother Natuze provided a Turther incentive Lo stay inside, since if was again bncketing down with rain. The aegotiators talked not just through the aight, bul the neat morving es well. Tt wasn't until ealy aftemoon that Shlomo and Gili came to my cabin to report on haw they'd gone. As I'd anticipated, both of them had ventured beyond concessions that | was ready to consider, al least at a time when we weren't even near to a final peace deal. Taking the President's instructions to heart, they'd said 356 BARAK 71 they were willing to consider full Palestinian sovereignty over lwo Arab acighborhoods in Last Jeruselem, and even some form of Palestinian authority and control in the Christian and Muslim quarters inside the walls of the 01d City. They add dropped our insistence on rac control aver the Jordan Valley, snggesting that we hold on Lo only a small segcat of the bosder with Jordan. They had gone beyond the share of the West Bank allocated to a Palestinian state on the map that Abu Ala’ wouldn't even look at. Now, they suggested around 90 percent. But when [asked what the Palestinian negotiators, Sach Lirekal and Mohammed Dahlan, had proposed in eum. the answer was almost nothing. They had taken notes. They had asked questions. The ane Palestinian proposal, from Saeb Frekt was ou Jerusalem: Pakestivian sovertigaty over al the city’s predominantly Arab areas. and Tsraeli sovereignty over Jewish neighborhoods. In other words. division of the city. Even though [ was concerned that Gili and Shloma had gone so far, especially an Jecusalem, T'd ceached the point where 1 doubted that even that would matter. We were novw in day-six of the summit, barely 48 hours from President Clinton's deastnre for the Ge summit, md we were negotiating only with oursclves. Koowing that the President planned to go see Asafal, 1 sat down and wrote him a note — emotional not just because I did it quickly, but because of how deeply let down [felt by the Palestinians” deliberate avoidance of a peace deal which, with peuuine reciprocity, should have been within seach. “1 wok the report of Shlomo Ben-Ami and Gilead Sher of last night's discussion very badly...” it began. “This is not a negotiation. This is a manipulative attempt to pull us to a position we will never he able 10 aeeept, without the Palestinians moving one inch.” | reminded President Clinton that just as he was taking political risks, I was too. “Even the positions presented by our people last night, though they are not my positions, represent an additional risk.” | snd. said T doubted there would be another Tseacli leader willing 1 engage in serious efforts for a final peace agreement with the Palestinians after what had happened bee. Unless things changed dramatically, | wis nol proped for es lo thro out further suggestions, or consider painful concessions. “1 do not intend allow the Tscaeli state to fall apart, physically or morally. The State of Israel is the implementation of the dream of the Jewish peaple, for zeneration upon generation. we achieved it aller enormous effort, and at the expenditure of a great deal of blood and sweat. There is no way Iwill preside at Camp David over the closing of 357 {BARAK 72 this saga.” T told the President that T still believed that we were facing a “momeal of uth.” But only if he could “shake” Avafal, and get hie to sense the enormity of the stakes an independent Palestinian state, versus more, and undoubtedly deadlier, violence. And if it did come to anned conflict? “When the people of Israel will understand how far we were ready to go, we will have the power to stand together, ufc, in such a stugle, however tough it will became, even if we will be forced 10 confront the entire world. There is no power in the world that. can foree on us collective national suicide. Peace will be achieved only if there is a willingness to negotiate on both sides, [am sure the people of Israel, and the American people, will understand it when Ue details will be revealed.” Clinton had alieady left for Arafut’s cabin by the time Danny Yatom went to deliver the letter, But the President, too, was in a more sober and downbeat mood by the tame thd meetmg was over. Lite tit night whe, baying now sed ny mole, be joined me on the balcony of Dogwood. 11 looked exhausted. “I1 was the toughest meeting I"ve ever had with Arafat,” he said. Clinton said he had told the Palestinian leader til anly one side, he Istrelis, had so far been negotiuting in good Gaith. I Arafal was not prepared Ww make a genuine effort fo reach an agreement, then there was no choice but for all of us to go home. Now, it seemed, bath the President and | were kit to wait and sce wha, if anything, Arafat came up with in reply. “ve been through bautkes, and danger. in my life,” T said. “But in teens of my responsibility, today, for me as well, was prabably the toughest, Shlomo and Gili went beyond whit | could live with. IT this offi can™ move him, then 1 beheve we are lef to prepare for war.” [told the President he didn't even need to phone me after hearing from Arafat if all he offered was some clever half-reply, Only if it was serious und substantive. 1 also remmnded him that while he'd promised Arafal that he would not “blame” the Palestinians if the summit failed, that had been on the basis of negotiating in good faith. 1 hoped that, if the summit collapsed in these emcamstmecs, he would keep to that standard, Finally, | touched on an immediate concern if tie summit broke up. Fou months, the Palestinians had been talking abour simply “declaring” a Palestinian state. The Americans had insisted neither side should resort to unilateral action m u contlict whose resolution depended on rues agreement. The Europeans had been less 358 {BARAK 73 eaplicit. T told Pecsident Clinton T could speak only for how [would respond if a state was indeed declared without a peace deal. “We will extend Iscaeli sovereignty aver the major settlement blocs, We will establish a security zone in the Jordan vitlley, und let them know thal there will be a hewvy price should they stack say off the outlying setlements.” In other words, Palestinian unilateral action would prompt unilateral Israeli action. “And the confrontation will begin.” x ors Clinton seemed, if not completely revived, considerably more upbeat when he came back 10 see me un hour later. He told me that he had received the Palestinians’ answer. The way he described it to me, Arafat had agreed lo leave President Clinton ta decide fhe amount of West Bunk land that would wo ta a Palestinian strc, i Fire he now fold me tithe was assuming would end up at around 90 10 92 percent. The wade-ofT, be said. would be a limited. “symbolic” land swap. Arafat also wanted control of the Jordan Valley. but had agreed to begin newoliating on [sracli security needs there as soon as possible. Then, cane Arafat's counter-conditions, which appeared to bother the President much less than they did me. Tverything would be contingent on an unspecified, “acceptable awa on Jerusalem.” And despite Clinans einphasis thal any meaningful agreement had to include a formal declarativn that the Isracli-Palestinian contlict was “over.” Arafat was insisting that could come only after the terms of whatever we agreed were fully implemented Sill. it was al lest step forward. Clinton scemed genuinely encousssed, and | didn’t want to risk closing off this first chk of light. T suggested. for instance. that we could address Arafat's reluctance about an “end of conflict” statement by providing an American gurantee that the tens of the deal would be implemented. Still, it very soon heeame char that any hope of real progress rested on by far the most difficult issue: Jerusalem. Across party boundaries, even across divisions between religious andl sceular, nearly all Israchs viewed the city as not just our capital, but the centrepicee of the state. It had heen divided afier 1948. The Old City, and the site of the ancient Jewish temple. had been under Jordanian rule for 19 years when our forces recaptured it m the Six-Day War, It was under a Labor 359 {TARAK i 21 soveenment that the area around the temples surviving Western Wall, left uncaced for under the Jordanians, was cleared and stone plaza put in place for worshipers at the expense of parts of the old Moroccan Quarter, Tt was under 1 abor, 100, that srl unilaterally expanded Jerusatenn’s city fimits 10 take in more thas (wo doen adjacent Acab villages on the West Bank. No Isai government since thea, Labor or Likud. had deviated from a shared pledge that Jerusalem would remain Istael’s undivided, sovereign capital under any eventual peace agreement. Yet when [met Clinton the next moming in Lanrel Lodge. he insisted we hed to find some room for flexibility. He said that, of course, Israel would retain sovercigaty over the Temple Mount; the sife of the Western Wall and, above i, the AlAs mosque comple. “Bul withonl dumging your sovereignty,” he rgued “we have 10 [ind a way to draw a picrure for Arafat that includes some measure of Palestinian control im part of the city.” “Could you gree 10 Arafat having an offfec, maybe, inside the walls of the Old City” he asked me. What ahout a foc of administrative control iu some of he outlying Arab neighborhoods in ast Jerusalem? 1 replied that 1 couldn't possibly amswer any of his questions unl and unless if was clear that Arafat accepted onr sovercigaty over - and our national and religious conncetion with — the Temple Mount. Yet 1 said 1 understood that we would have to reach some compromise agreement on the city iF we were ever going to have a ehince of a peice spgcement. “Bul its an issue that is difficult for every Jsmeli.” 1 told hin. Before | could even begin 10 see whether there was a way forward, T would have to take it through with my entire negotiating team, Then, we could discuss it. 1 med out 10 be the most open, serious, scrching discussion | was is part of during all my years in public life. It began, on the terrace of my cabin. at two iu the afternoon and went on until sundown, | introduced it by saying what each of us already knew: Jersalom was the most emotionally charged snd polincally complex issue of all. Our maximum position coming into the summit hiad been that we wauld again expand the municipal boundaries of the city. as we'd done after the 1967 wir, m order fo accommaodile two separate “city comenls.” One would be in Abu Dis, just 10 the southeast of the Old City. almost literally in the shadow of the Temple Mount. The understanding was the Palestinians would be fre to rename the village, referring to it by the Arabic nme for Jerusakem: Al Quds. | suid that we should use that position as a starting point, and disciuss how, or whether, we might go further. All T added was the need to be aware of what was a 360 BARAK 175 stake. [didn’t know whether peace was within reach. T was still deeply skeptical But if it was, we had 1 accept tha Jecusalem would be key. And if the summit failed. for whatever reasan, what inevitably awaited us was “confrontation,” Israel Hasson, The Shin Bet veteran, spoke first, He saw two chotees, Fither we could retain Isrsacli soverciguty over a “united Jerusalem” with functional, day-to- day autonomy for the Palestinians in their neighborhoods. or we could in effect divide the city. “Divide sovereignty.” He did't say which he fvorcd, only that it wis essential that we made the decision now if we could, however difficult or reluctant Arafat was as a negotiating partner. If we waited, we'd end up having: to deal with Ishimists: Hamas and Iskamic Jinad, Oded Fran, the career diplomat whom 1d put in charge of frustrating, formal talks with the Palestinians fu the months preceding the summit . said he was convinced that we should give the Palestinians full sovereignty aver at least the “outer” Arab neighborhoods in Fast Jerusalem, which had become part of the city only when we'd expanded the city boundaries afer 1967. Tle said thal was in Iscael’s own interest. We had ao historic connection to these Arab villages. and something like 130.000 Palestinian lived there. “Why should we wani wo annex them,” he asked. 1 would be like sceepting the “right of retura™ through the beck door. Dan Meridar’s voice, for me, was especially important. [ knew he was as determined as [was to fry to et «peace surement with the Palestinians. Bul he was also 8 former Likudnik, and a native Jensalernite. “1m against any concessious when it comes to Israeli sovereignty,” he said. “Any attempt to divide Jerusalem would be a serious blow, and nat just far Jews in lseael” For centuries, Jewish communitics all over the world, ad looked 10 Jerusaken, prayed for Jerusalem, The yearly Seder meal, on Passover. ends with the Tlebrew phrase: Shana hab b*Yerushudam. Next year, in Jerusalem. “What we decided bere in Cup David,” Dun saiel, “also affects Jews in Rew York. in Moscow. In Johannesbucg.” Tle urged us 1 focus instead on offering Arafat as aticactive as possible a package of concessions on all the ether issues. “Then let him decide. But even if sovereignty over Jerusalem means thal the deal collapses, Pm nol willing the pay that price.” No voices were raised. Tt was the rarest of political discussions. People offered therr views, and listened to athens’, Amnon ©ipkin pomted out that a linge arca of what was now came inside the boundaries of Jerusalem was nol part of the city he'd known before 1967. Tchoing Oded Tran, he said: “IU in our interest for as 361 BARAK 176 any a possible of the Arab inhabitants 1o come wader the authority of the Palestinians, and as few as possible under our cule.” Amnon’s bottom line was that we auld not give up Israeli sovereignty over the Temple Mount, which, although he was a non-observant Jew, he called “the cradle of Jewasis history.” But equally. we couldn't and shouldn't “un the Al-Adsa masque.” Tle wes also in Lavoe of agreeing to what Clinton had asked of me: giving Arafat a base in the Muslim Quarter of the Od City. Lis one caveat was that we should not do any of this unless it was part of 2 genuine, final. peace agreement with the Palestinians. Danny Yatom urged us to move beyond our emotions and look for a practical solution, “We all know how the boundaries of Jerusalem were drawn,” he stid, refersing to the posi-1967 expansion of the city. * hey ‘re not holy. 11 is importani 10 get down 10 our real red lines.” Eli Rubinstein, the atcorney general, agreed Fen though he was an observant, Orthodox Jew, and more sympathetic politically 10 Likud than Labor, he concluded that we needed to include “as few Arabs ss possible” under Tseacli sovereignty, and to cede the outer villages to the Palestinians, adding: “This is a moment of truth.” 1 was nearly five hours before | brought the discussion to a close. “This is ss rave a decision as when Ben-Gurion accepted the partition plan in 1947: the declaration of the state; or the mast tense moments of the Yom Kippur War.” 1 suid. “Or the decisions which Begin took m this same place.” OF course, Begin hadn't even been willing to enter into discussion on Jerusalem. But we were in different situation. Tf we were going to get a true end 1 our conflict. the question af Jerusalem had to be addressed. “We can’t dely the decision. We can’t avaid it. We will have 1 deciele.” My vw red line was he same as Amnon Lipkin's: “sovereignty over the site of our Tirst and Second Temples.” Tven shared sovereignty elsewhere within the Old City seemed to me a step too far at this stage, bu | did’ nuke 1 ont us part of s full peace. “Withont disengagement from the Palestinians, without an end of conflict,” T reminded oue negotiating lea, “wees heading toward furcher tragedy. We can't pretend we don't see the iceberg.” Vasked several members of the team, under Shlomo Ben-Ami, lo drafl a paper based on our discussion. Since | kiiew that Clinton, and Avafal wo, could do nothing of substance until I'd resolved how far to go on Jerusalem, T went to see the President. 1 told him about our session. [said that we were now crystallizing what had been said iu a formal position, and 1 hoped to be able to ret in a few hours with “the fucthest point we can go.” Clinton said that would be a critical 362 {BARAK (77 moment in the summit. IF we cond find common ground, he said, seal would have achieved what had cluded it undec Rabin, end even Ben-Gurion: “end of conflict, and Jerusalem recomized internationally as your capital,” | told him that the discussion with my negotiators had been moving and illonmaum “1 ould see how nuh it weighed on everyone.” But | added that 1 sill did not feel anything of a similar nacre, or remotely as serious, was happening on the Palestinian side. 1 also said that in deciding how w proceed, J couldn't ignore political realities back home. | would have to pet any major change in ouc position concerning Kusalent through the Knesset, even before putting a peace agreement to a referendum. “When will you et back to me with your paper?” he asked. I said I'd try by ‘midnight. | also asked him whether he could delay going to the G8 summit in Japan, for which he was due 10 leave Camp David on the moming of the 19". That meant we had just ane full day left, | said even if the plan wus 10 resume our talks aferward, [ couldn’t move on Jerusalem right before we recessed. I would mean “putting my last and best offer on the table” and runaing the risk of leaks in Tscacl while Clinton was gone. Ile said that he had to go to the G8, but would try to put oft leaving for u further day. Then, he asked me to draw up a list of questions for him Lo present to Arafat so that we could solidify our understanding of how fac he was ready to go for peace. 1 had Shlomo get busy on the list of questions, Rut it wok fime. We reconvened around cleven at night, 10 discuss both the questions and the Jerusalem package. Though it retained Israeli sovereignty over the entirety of the Old City, it did give the Palestmians a greater measure of control over ather areas of Fast Jerusalem than any Isvacli government hid been willing to consieler in the past. Still, shnost everyone in the negotiating team could live with it, assuming it became the eritical ‘element in a final peace. Dan Meridor, alone, remained firmly oppased, though Elyukiz Rubinstcin also id some reservations. Even Dim said he understood the importance of getting a peace agreement. if indeed it was possible, and our readiness to discuss new proposals on Jerusalem. When lef) for Clintons cabin ut about 1:00 mn on Wednesday, 1 bad no idea | was about lo enter the most diffieult mecting — and the only real fight — | had with ‘him during our long effort to achieve a Middle Last peace. T brought Shlomo and Dyn with me, which meant that Madeleme Albright, Dennis and Sandy Berger stayed as well. Usensed tension in all of them, in large part, | soon discovered, because they took exception to the more than twelve hours we had speat discussing 363 {BARAK 178 aod refining our position vn Jerusalem. 1 think Clinton expected a formal offer from us. Since I'd been guided by his request for a list of questions for Arafat, however, that is what we came to him with, As we'd discussed, | wanted finally to whit some sign of whether Arafa, loo, was ready 10 make diffieuh decisions. The questions were specific. “Will you accept an agreement that stipulates the following...” it began, and proceeded to outline the kind of peace we could accept and still hoped for. The points meluded not just Jerusatem, but wreas 1 knew would also be sensitive for Amafal, such as the “right of retum” and formal agreement ww an end of conflict. We went furcher than betore in some areas. One of the outer Fast Jerusalem neighborhoods would be under Palestinian sovereignty, The rest of the city woukd serin mdr Issac sovereiguty, but most of the other Avab villages would be subject Lo a system of Palestinian administeation. The Ilacam al-Sharif, the mosque complex ibove the wall of the Jewish temple, would be under Palestinian “administiative and religious management” We also suggested “ypecial arrangements” implying a Palestinian presence in the Old City, but again under Israeli sovereignty. The questions envisaped eventual Palestinian control in the Jordan Valley, wilh im Israch sceurily zone for 12 years, rather than our propasal in pre-suenmit talks for 30 years. Then, explicitly, we proposed a question to Arafat to confirm my understanding with Clinton that tae “right of recur” would apply 101 ta smal praper, but to a Palestinian stale on the West Bask and Gaza. Uinally, the document said: “I understand thal such an agreenient constitutes an end of conflict.” After he read it. the President blew up. Far from the “botcom lines” he'd appuseutly haped for, but which Ud sever thought wore expected af this stags, | seemed to be reteeating from ideas Shlomo and Gili had presented in thee all-night session with the Palestinians. Given the eround rules of that exercise. they'd felt able 10 go beyond smything we'd sciually agreed, und in some reas beyond shat they knew [could support. As a resull, the list of questions assumed Tsrael would keep a litle more than 11 percent of the West Bank. nearly one percent more than Shlomo hid mentioned. Shlomo and Gili had also neised the possibility of up 10 three of the vuter Jerusalem villages coming under full Palestinian sovercigaty. “You keep us, and Arafat. waiting for 13 hours.” Clinton furned, his face nearly scarlet. “And you want me to present something fess than you've already offered.” Ile said he wouldn't do it. “I his is not real. [Ls not serious.™ Ile said that he'd ‘gone to Shepherdstown in search of what was supposed to be an endgame with the 364 {BARAK [79 Syrians. Then to Geneva lo see Assad, “where I felt like a wooden Indian, doing your bidding. will nor let it happen here. [will simply not do it” 1 tried to keep my voice steady when | replied. 1 explained that the issues we were ahdressing went lo the hear! of Isls micrests, its future scourity, ils identity and definition as a nation. 1 had a responsibility to tread earcfully. Then, my voice rising too, [ came back to wha [ felt was the real problem. Arafat and his negotiators had been sitting and waiting for me and my team, and probably Clmton as well, wo deliver more and more concessions with no sign that they were willing to move on anything. “1 find that outrageous.” 1 said. 1 did not expect Arafat to respond with equal concessions. After all, Israel had mast of the tangible assets, “But 1 died expect him al lost 10 take a small step once we hid taken fen. We have ool seen even this. This is the kind of behavior parents would oo tolerate in their own children! We don’t expect Arafat to accept this, but | #o expect him ta present a counter-position.” Clinton remained adamant he couldn’t go 1 Arafat with a retreat fron oue earlier ideas. “My negotiating team moved beyond my red lines.” 1 told him. The overnight talls were supposed ta be non-binding snd assumed that both sides would make & peauine auempl Lo gel an agreement. “I can’t sce any change in Arafat’s pattern. We take all the risks.” [ said 1 doubted that Arafat expected to hear that we had deeded fo give him Jerusalem,” In any case, the brash public hadn't given me a mandate 1o do that. But [ would still move in Arafat’ dircetion. if and when 1 got any sign he was willing to do the same. The President's anger eased, He supested he caucus with his negotiators and Tigre ont wha 1o do next. 1 fell bad about what bid happened: not about Ue list of questions, or my insistence that we could not offer major concessions with no sign of reciprocity. But [ did regret that it had left the Americans sa frustrated, and Clinton so angry. He had invested not just huge amounts of lime snd brsnpower, but political capital. in the search for peace. He phoned me at about 3:30 in the moming and asked me ro come back. This time, went alone, We suf on fhe terrace of Aspen, He said again he couldn't go to Arafet with the list we'd drawn up. Bu having met with his negotiators, he suggested they draft a more forthcoming list of their own — consistent wich what Shlomo and Gili had proposed. 1 agreed, as long as they kept in mind that it had fo bie something [eon ulimately live with, and thi it be presenled to Aral as a 365 {BARAK 80 Atcrican proposal. T sugested the President could tel] Arafat that he'd uy to get me fo agree to il, providing Arafat first showed a readiness 10 move. The American questions did go further than ours. They asked Arafat whether he would negotiate an the bass of gem Palestinian soverciunty over all the outer Jerusalem neighborbiouds, as well as the Muslim Quarter of the Old City and a “custodial role” over the holy sites. Bur Arafat said no. He insisted on Palestinian sovereignty over ull of Fist Jerusalem, including the Old City and the holy sites. For a few hours afer Clinon’s fruitless meeting with Arafal, Dennis and the American team engaged in a rescue effort. adding another carrot. They included the Christian Quarter as well, meaning Palestmian soverenmty over nearly half of the OI City, including the areas where almost sll Arab residents lived. Dennis gave the proposal to Shlomo and Amnon Lipkia 10 being to me, and asked two of the Pulestmian negotiators to take it to Arafat, Fven offering sovereignty over the. Muslim Quartec went beyond anything 1’d proposed. So did a lot of the other American questions. Sul, T said we'd be ready to consider them in discussions with the US negotiating team — with the exception of the Christian Quarter. But that, too, turned out not 16 mater. Arafan did nol even respond. Clinton called me 10 say we'd reached the end of the road. “There were only two options: end the summit and announce we'd tried and failed, or defer Jerusalem and fry fo get aurcement on the rest of fhe issnes, Casked for time to think it over, and he said he'd come see me when | was ready. 1 was tempted 10 put oll Jerusalem. Tn the admittedly unlikely event we could get a deal on the other issues. that would imdenrably be un achievement, But [ canldn’t help think that Arafil’s lack of engagement ou Jerusalem was vel another sign that he was nol ceady for the almost equally tough compromises cequited to resolve the other core issues. And there was no escaping the reality that without a deal on Jerusalem, no agmreement we reached sould truly represent am “end of conflict.” Moreover, Jerusalem wasa’t just a Palestinian issue. [Lwas of fundameatal interest 1 the whole Muslim world. If we left it unaddressed, we would be putting future Israeli governments in the positon of having Lo cgoliale on Jeusakan afer we'd given back our key negotiating assets and all our leverage. Taceepted now that the search of a full peace treaty. or even a framework agreement, looked all but impossible. Even Shlomo’s and Gili’s freelancing bad produced only a series of no's from Aralat. Bul 1 fell | couldn’t give up. Much as T'd been resisting it. [ believed [ needed to give Clinton my re bottom lines. even 366 HARA 81 wilh Arafat still mute and uncesponsive. That was the oaly way ve could know wilh certainty whether peace was possible. IC it wasn’L, it would also demonstrate awerfully to the Americans that we were nat the party who had prevented an ameement Tlie President came to see me in Dogwood a little before 1 at night on the 18%, Tess than 12 hours betore he was due to take his delayed flight ta the GS. I told him 1d decided to do what Rabin hud done with Syria. [was going 1o gnive him a “deposit” to keep in his pocket, which he would be free 10 use as the basis for a further, American propesal to Arafat. assuming it was part of an agreement with a “satisfactory resolution” of the refingee 1ssue and un expheit endeof-canlict, He couhd present it as something which he could tell Arafat be wis confident of persuading Israel to accept. Tt weal well beyond what I'd offered before, on all the maar issues, [ proposed Palestinian rule over 91 percent of the West Rank, | was ceady for a Palestinian state 1 have sovereignty over 85 percent of the border in the Jordan Valley as well, and our seeurity zone there would stay in place for “less than 12 years.” Seven out of the nine outer Arab neighborhoods of Jerusalem would come under Palestman soverengmly. The mer neighborhoods would be under Palestinian civil authority: including planning and zoning, and law- enforcement. For the mosques on the Temple Mount. I proposed a shared custodianship fo incl the new sue of Palestine, Morocco and the chieir of the Higher Islamic Commission in Jerusalem. | also agreed 10 consider Palestinian sovereignty over borf the Muslim and Christian quarters of the Old City. Clinton. arching his eyebrows and smiling, said what I'd offered was a package of genuine concessions. 1 was more than hie had expected and, he assumed, more thaa the Palestinians could have hoped for. Tt had the makings of a potential breakthrough toward a fair and final peace. I told him [ hoped so. Bur piven Arafi’s behavior so fa, | hid my doubts Now. iL was our tun fo wait. he President invited Arafat to Aspen and, from what we heard soon afterwards, zat no hint of any readiness fo reciprocate. He agreed only to Talk to is negotiators and wet buck with an answer, Overnight, the Palestinians sent messages to he Americans asking questions on cach of the concessions, though still with no indication from Arafat of a response. Finally. he sent a suggestion that smee Clinton was about ta fly off 10 the G8, we tke i two week break 10 allow Arafat lo consult with Arab leaders. To his credit, Clinton knew an escape act when he saw it. Tle recognized that only by confontiag the 367 {BARAK 82 issues raised by our proposals and showing a willingness to find common ground would we have any hope of success. No roves, Clinton seid. [le needed a straight answer, Again, not full acceptance necessarily, but agreement to treat the proposals a basis for negotiating an Israchi-Palestinin peace, Amfal’s smswer came shorily before dawn. [Lwas “no”. Clinton couldn't quite believe it. TTe went back to see Arafat, telling him he was making an error on the scale of 1948, when the Palestiniins bid rejected the partition of Palestine aud the creation of an Arab state: or in 1978, when hy negotiating on the basis of Sadat’s Palestinian-rights tramework, they would have ended up with a mere 5.000 Israch settlers on the West Bunk mitend of nearly 200.000. What most astonished Clinton wars thst Arafal wis saying no even lo using the package as a dasis for negotiations. Sill, Arafat would not budge As Palestinian negotiators fried to salvage things by suggesting another frip by Mudeleine und Dennis 10 the Middle Kast, it was cher thal even the Americus. were fod up. They knew that one side, at least, had been trying 0 pet an agreement. ‘They couldn’t understand why Arafat was unwilling even to accept the “pocket” proposals is # basis for further talks. When Yossi Ginossar, our most rehab le conduit, went 10 see Arafat, be found him sitting alone and. in Yossi's description, “paralyzed.” Clinton finally decided to have one last go. When he did. Arafat not anly remirined imwilling, To the President’s astonishment, he insisted that the ancient Jewish temple hadu’t been iu Jerusalem a all, but in the West Bank city of Nablus. 1 was getting a bite to eat m the diming room in Laurel Lodge when Mudeleme stowed up. She didn’t bother defending Arstiat. She was as rusinded is | was. Her ‘message was that after the summit, it was imporcant not to make things worse. A ‘negotiating process had to be kept alive, Then, Clinton sat down with me, He dchvered a simili message, but with even greater fshmg, “You're smarter than [ am.” he joked “You're certainly experienced in wer, and I'm not. But I'm more experienced in politics, and there are a few things [I've leaned along the way, The most important is nol fo comer your advensinics, and not lo comer yourself, Always kave yoursella way out. Don't lock yourself into a losing option.” 1 could see that he wes right. T also believed, as strongly now as before the summit, tha Isracl’s own interests and its security were not served by an unresolved conflict with the Palestivians. The problem was that, in the abseuce of un equal commitment on Arafat's side. any continued negotiating process seemed futile. 368 {BARAK 83 T packed my bags. T wld Danny Yatom to inform the Americans we were leaving and to gel our plane ready 10 take us back Lo Tsrael. T let the others in ou team know that we were going, A number of them, und several of the Americans as well, urged me to veconsider. But | said [sw no point in staying. What [didn’t know, however, was that vos of the Palestinians” original Oslo negotiators, Hassan Asfour, had approached Dennis Ross with a new proposal: that we ask Arafat to aveept everything except the proposal on the holy sites as a basis for negotiation Sovereignty over the Temple Mount would be addressed in later, international negotiations. When Dennis brought this to me. my instinct was to say no. Like so much else at the summit, it was an inherently skewed formula: it would involve major Israeli concessions on all the other main issues, witha sceuting our absolute minimum need in Jerusalem: soversignty over the Temple Mount. T didn’t say yes. Still, with Clintons words of advice still on my mind, I said that 1'd think il over, When I mel the rest of the Isracli team, almost all of them fell we should stay. The consensus was that especially if violence broke out afer the summic’s collapse, we didn’t wanl to feel wed leh any stone untied. AT abou 11 pr, | phoned the President and told hin that we would stay until be returned from Okinawa. le was clearly pleased, and asked us to keep working in his absence. When | resisted tat, saying tit any substantive talks needed Ins involvement, we finally agreed that talks could continue in search of a formula for the holy sites. On all che other issues, only informal discussions would be held until and unless a way ahead an the Temple Mount was found. If that happened, and if rag finally accepted the “pocket” proposals as an agreed starting point, formal negotiations could resume. Clinton accepted this formula. ITe went to see Arafat and secured — or thought he had secured his agreement as well. One of the President’ great streniths was his genius for blurring the edges of potential differences in search of common ground. But when edges Aad to be sharpened. this could lead to confusion. Before leaving for the GS, the President wegheeted w mention 10 Arafat our explicil umdastanding that, with the exception of the talks on the holy sites. nothing would happen until he accepted the concessions that President Clinton and I had delivered as at least a basis for further negotiations. As « result, Aratat’s feam now set about happily asking questions and probing my negotiators — pushing us to go further — but with no move inclination than before to produce any concessions of their own. 369 BARAK {81 When I leaned what was happening, T told my negotiators they were not lo hold any Further formal mectings during the four days Clinwn would be away. Dennis's initial response was frustration. Madeleine Albrights's was fury. They buth made mo secret of their view that | wis needlessly stonewalling. 1 wast’! until a few ous later that Madeleine apparently saw the steavgeaphec’s record of ty conversation with the President before he'd left, confirming the condition that Acafit accept the “pocket” at least as a basis ou which to proceed. That evening, she apologized to me for the misunderstanding. and explained the mix-up 1 the full Palestinian and fsraeli negotiating teams. 1 spent most of the remaining three days ia my cabin or. when the rain relented, walking through the woods. The Americans appeared t thik | was sulking. | wasn’t. Twas trying to find the least diplomatically damaging way 10 navigate the period until the President's return, T couldn't see showing up at Lwrel at every mealtime, mingling and joking with the Americans and Palestinians, but cefusing Lo enter into aay form of negotiations. That would compound the awkwardness of the sitation. and also be a direct affiont to Madeleine. I liked and respected her But [could not in good conscience help her out m her efforts to find ai feast some, informal. way of moving the summit along in Clinton's absence. If Arafat had failed to show even a scintilla of movement with the President in the room, I knew there was no wiry hat he wis going lo do so wilh the Secretary of State. For the Palestinian negotiators, who were predictably in favour of her efforts, the definition of “new ideas” was whatever further movement they might cajole out of mr negatiatars. Still, on day-three of Clinton”s absence, T got a note saying: that Secretary Albright was on her way w my cabin. | didn’t want the needless diplomatic difficulty involved in agaia telling her T could not sanction free- wheeling, and decidedly one-sided, negotiations while Arafat hadn't moved a single inch, So | made myself scarce, Fortunately, | was wearmye sneakers, old Danny to inform the Americans Twas out jogging around the perimeter of the large Camp David estate. and went off to do just that. 101d my own delegation 1 was taking time out to assess where we stood. [ did continue meeting with Gili Sher and Danny Yatom. Yet for much of time, I read. { also did a lot of thinking. I considered the “pocket” concessions I'd agreed to. the uncertainties and risks I'd been prepured to run. and the need ta decide how to deal with the fact that Arafat, when he had engaged at all, hed said “no” 370 BARAK 85 Onee it was clear to the Americans there would be no talks until the President returned, however, Madeline began ucging me to go see Arafat personally. The two ‘members of aur team wha were the least pessimistic about Camp David's anteame, Shlomo Ben-Ami acl Yossi Ginossar, uso said they tought it was a good idea. 10 was they who'd pressed nie go see Aral (or tea and sweets eadier in the summit. But that meeting had produced not even a glimmer of negotiating Nexibility from the Palestinian leader. Yossi had said at the time that it would help the atmosphece. and pay dividends later on. But that hadu’t happened either. “Madam Secretary,” I told Madeleine, “eating more baklava with Arafat isn’t going: co help. The situation is simple: he needs fo answer whether he views fhe President's proposal us a basis for going forveard.” Whea Clinton ceturned, he promptly got back down Lo business: making one ast push to see whether a peace deal was possible. He phoned me around midnight an the 24% of July, a few bows afer he'd arcived. [Te wld me be had seat an even ore far-reaching package to Arafet, expanding on my proposals. Now. all of the outer Arab neighborhoods in East Jerusalem would come under Palestinian sovercigaty, i addition 1 the Mustim amd Christan quarters in the Old City. And Acafit would he given “custodial sovereignty” over the Muslim holy sites on the Temple Mount. I didn’t object. Though it was further than [ felt I could go, it was within the spit of my “pocket deposit”. The same ground rules still applied: these were American proposels., whieh the President was telling Arafat he would try to deliver if he accepted them as a basis for serious negotiations. But when Clinton phoned me back. around 3:15 in the morning, it was fo tell me that Arafat had again said no. ‘The curtain had finally come dowd. What remained now was to clear up the set. 14id meet Arafat once mote, in a joint session with President Clinton, but only for closing statements. The President and [spoke as mich in sorrow und Frustration as anger. Both of us said we thought an historic agreement had beea within our grasp. and that far-reaching proposals had been tabled to make it possible. Arafat responded with words both of ws had beard before: <Miasive toward Clinton, chapsodic about his “old partner” Rebin and fulsome in his ostensible commitment to keep tying for peace. Buc it was just words. We knew he was not willing even ta dati about the kind of compromises a real, final peace would require. “The Prosident’s remarks 10 the medi were, by the standards of post-summit diplomacy, unmistakably clear in making that point. ITs praised me and the Israeli 371 {BARAK [86 negotiating team for courage and vision. Essentially. be thanked Arafat for showing up. That was some consolation. But it didn’t aller the weight of the message we were carrying home, Arafat either would not ar could nat make peace, at least on terms any Issel lesder could seep or the people of [snel woukd endorse. There were only two potential deal-breakers on our side, as Arafat had known from the beginning, The first involved the “right of rerum.” We were never going 10 sign 8 pesce agreement ccepling Lhe return of hundreds of thousands of Palestinians within our pre-1967 borders. Demographically, that was a recipe for the inexorable end of Israel as a mujority-Jewish state, 1t would alsa imply a rewriting of the history of how Israel wis bon: in a wae, with a almost cqual umber of refugees either fleeing or forced to leave on both sides, aller the Arab world had imanimously, and violently, rejected 1 UN partition that would have created a Palestinian Arab state as well. did aceept a “right of return” wo the Palestinian state we had hoped Lo create, as part of a [inal peace deal, on the West Bank and in Gaza. 1 alse supported the idea of a multi-billion-dollar international Fund 16 compensate or veselile Palestiniin religees, and was ready 1 commii Isnt a8 party to that effort. The other eritical issue was Jerusalem. [ had stretched our negotiating position almost to breaking point. The “pocket” ideas Arafat ended up. rejeetmg challenged a longstanding 1svach political taboo. In practical terms, they amounted 10 a breach of the assurances which | and every other Israeli Prime Minister since 1967 had given: never to re-divide Israel's capital. Tad we actually zot an end-of-contlict deal. | would have had to justify it to Israelis in a referendum. [think 1 could have done 50. But one thing | could nut give up was our sovereignty over the Temple Mount, the centerpiece of our history as a people and Israel's as a state. It was our connection with our past, a focus of what we had gone through, what we had achieved, and what we had left 1o accomplish, If was essential to who we were. Arafat never even engaged in a discussion on the “right of return”, On the “Temple Mount, however, he was explicil. Any pusce, any basis for negotiation Lowaed peace, had to begin by confirming Palestinian sovereignty. Besides, as he'd told the President of the United States, he had persuaded himself there never was a Jewish temple in Jerusalem. When I heard about that remark, 1 was less shocked than Clinton. [L struck mie as just another wary Arafat had of conveying Ais botiom lines. It was a bit like stories he liked to tell about visiting his aunt in Jerusalem as. 372 {BARAK 87 2 young boy and secing religious Jews walking through the streets of the Old City Tdon't know whether those stories were Leue. But the point was that while he had na problem with Jews in their lang coats and black hats praying in the holy city, Jews exercising authority or sovereignty, o i Jewish state, wis something chic cntirely. Camp David had made it clear it was something he was not prepared lo accept. I'he question which | now had to confront was what 10 do next. 373 {BARAK 788 Chupter Twenty-Three Tt didn’ fully hit me how draining our efforts had been unl the morning that the summit collapsed. when President Clinton called me to come talk to him in the living coom at Laurel Lodge. When © arrived. Madeleine was alieady there, sitting. on the edge of the sofa. She greeted me with a resigned shrug and a valiaat but aot altogether suceesstul effort at a smile, “We ried? Clinton said quictly as 1 took i seal in a wooden chair opposite his “4 pave it everything.” 1 he nomial reason for the mccting was Lo brit me on the communiqué the Americans were ping to issue: mostly boilerplate assurances that both sides remained committed to seeking peace, but with an additional “understanding” that neither would take unilaters| actions in the meantime. But mostly, Clinton wanted to reinforce his message of a few days earlier: don’t “lock yourself into a losing option.” Don’t close the door, Dan’t give up. “1 won't” | told fim, an wssusance | echoed in remarks 10 reporters u few hours later, when | seid that while the peace process had “suffered a major blow, we should aot lose hope. With goodwill om all sides, we cam recuperate,” But [old the President that we conldn’t just ignore what il happened it Carp David. Yes, in the event Arafat suddenly had second thoughts about the potentially historic achievement he'd passed up. he would know where to find me. But until nd unless that happened, 1 told Chnton thi [assimed my “packer” concessions would now be firmly back in his pocket. And while we couldn’ erase them from memory, [said it was important both of us male it clear that. in legal and diplomatic terms, they were not gomez fo provide Arafat 4 new starting point from which he could make his customary demand for morc. “And T have to Lol] you that, given what bas happened, there's no way 1 can justify handing him contral of more land. | am not going to wo ahead with the Wye redeployiments m these circumstances.” “You don’t have to,” Clinton replied. “I'll back you.” Though I never discussed internal Israeli politics with any foreign leader, even the closest of ules, 1 didn’t donb thist the President’ support was parily cecopnilion of what awaited me once I got liome. The compromises I'd been willing to consider had gone further — much further. on the politically combustible 374 BARAK 89 question of Jerusalem — than any Israeli leader in the search for peace. Even befor Pd left for Camp David, the defections from our coalition meant we'd been loft with only 42 seats in the Knesset, nineteen short of a majority, Amid the first, sketchy media repos Ut we were even talking ahonl sharing control of parts of Jerusalem with the Palestinians, thee was & chorus of denunciation (vom right- wing politicians back home. Bibi Necanyalm had largely kept cut of the public eye since his resiguation afer the eleetion. Now, he issued a statement accusing me of having “broken all the red lines held by all Isuaeli governments.” During the President's final push to save the prospects for a summit agreement. Bibi called 1 news conference. He said he was determined to prevent what he called an impending disintegration of Israeli society. “Whal we hear from most of Lhe repons out of Camp David does not answer our hopes,” he said. It liadn't answered my hopes either. Bur [ had gone into the summit with my eyes open. Crustrated though 1 was by Lhe way the summit had ended, Thad no tegrets about going as far as 1 had in eying Lo reach, al the minimum, 2 Niemework agreement In that sense, it is true te summit had tailed. But when I'd urged Preswdent Clinton to convene it, | mile the argnment that if genuine peace wis ever going to be possible, we al least had 1o know whether Arafat was interested in, or capable of, playing his parc. That question had. for now, been answered. At least as nmportunily for Imac, the President of the Cited States und almost the entire international community recognized we'd done everything realistically possible wy reach an accommodation. Diplomatically, the ball was in the Palestinians’ court. ‘There was a final achievement as well little noticed or remarked upon in the dys immediately afer Camp David, bu hugely siguificaut. A taboo had been broken. For the first time. all Tscaelis recognized what their political leaders, both Labor and Likud, had long known: a formal. tinal peace with the Palestinians, if amd when it ene, would require 1s nol just 10 withdaw from the reat majority of the West Bank. but 10 find a formula for sharing power in Jerusalem. Many Tseaclis sill believed that was a price too high, and not just Likudniks. A couple of weeks aller the sumimil, © Rabin told in Isach newspaper that ber late husband would be “turning in bis grave” i he'd knowen the concessions 1d been ready to consider on Jerusalem. I found the remarks hurtful, but I understood them. In a way. they drove home the point I'd made to Clinton during the summit: off [sraelis had a deep, emotional auachment to vue historic capital. “Yitzhak would never have agreed to compromise on the Old City and the Temple Mount,” Leah said, 375 BARAK £90 “because for him, Jerusalem was sacced from a steietly national and historic point of view. Iwas for me as well. Tn fact, [think its religious significance probably resonated mare strongly, Sell, the major change from the summit was that even those Israclis who found a compromise on Jerusalem unacceptable recounted al, if they did want 10 negotiate a definitive end to the conflict, talking sbout it was unavoidable. At least for now, however, there wasn’t soing to be pence deal. As our EI Al 707 deseended over the Medilerrancan for our approach back 1 Ben-Gurion Aiport, 1 faced the more immediate issue of ensuring my government survived “This was partly in case, against all adds, Arafat showed a readiness to revive the swarch for peace — bul also becanse of the real prospect bie would choose violence instead. PRU Since the Knesset was about to go into recess until late October. I would have a three-month window fo restupe and stabilize my coalition but only 1F we could weather a no-confidence motion introduced by Arik Sharon efler Camp David. We did weather it, barely. Arik needed a majority of the Knesser's 120 seats to bring: down the government, The vote ended mu 50-50 ne, The other 20 MK abstained, or didn’t show up. This was nol because of any enthusiasm for my efforts 10 get an agreement at Camp David. but because of a lack of enthusiasm for an early lection in which they feared losing seats. Sill, thi did allow me Lo focus on the challenge of the inevitably aliered situation with Arafat after the summic's collapse. My main concern was the pessibilicy of violence. Fen before returning home, 1d phoned Shaul Mofaz and Avi Dichicr, the former Suyerel Matkal officer sho was now head of the Shin Bel “Let's hope the violence doesn’t come, told them. “But if it docs, make sure we are ready.” Though there was no sign of violence in the weeks immediately after the sammil, there was cqually hile sign of diplomatic engagement by Arafat. Obviously relieved at the way Camp David had ended. be retuned 10 Gouza to & hero’s welcome, proudly proclaiming that he had refused to “give up” Jerusalem. Tt wis vintage Arafat: the “weneral” in hus stirched umform and kefiyeh, fresh from 376 BARAK (91 the diplomatic equivalent of the battlefield. teiumphant against the odds. TL was the cole he liked and played best. Tis next move was Lo take the show on the road: Ln Arab, Furapean and world capitals, pleading that he had been the “vietim™ of summit chicancry in which President Clinton and | had presented bin with a deal a0 self-respecting Palestinian could accept. [le was also campaigning fo international support for a move, in contravention of the final Camp David communiqué, lo “declare” a Palestinian stale unilaterally in mid-September 1 spake personally lo ony Blair and French President Jacques Chine, and also dispatched Shlomo-Ben Ami, Arnon Lipkin, Yossi Beilin and Shimon Peres, who was Minister of Regional Cooperation m the coulinen, an i series of diplomatic visits 10 mike sure the true story of what had happened at the summit was understood. As a resul, the globetrotting Arafat received an almost uaanimous rebuff for the idea of a unilateral declarution of stateheood, He was told that if he ceally wanted a state, he should return Lo the asgotiatiog table with Tsrael. By the time | weut 10 New York in carly Sepiember — joining the largest collection of world leaders ever assembled. for the UN's Millennium Summit there seemed Fitlle chince of thal uppening. {mel privately with a number of world leaders before delivering a brief address lo ie more than 150 presidents and prime ministers. [ was at pains to take the high road. None of the foreign leaders 1 met had expressed any doubt that wed gone much further than they had expected a Camp David, and that the onus for putting diplomacy back on track rested fimly with the Palestinians. Lookiag straight at Acefat from the UN podiuen, T said: “We are at the Rubicon, und neither of us can cross it alone.” Jerusalem, “the eternal capital of Ismael.” was calling ou for a “peace of honor, of courage and of brotherhood” — a peace recognizing that the city was also sacred 1 Muslinis and Christians the world over. When Arafat spoke. it was almost as if the summit had never happened. “We remain committed 10 our national rights over bust Jerusalem, capital of our state and shelter of our sacred sites. as well as ouc rights on the Chistian and Islamic holy sites.” he declared. Ile didn't mention Jews, beyond a bizanre weherence to the 2.000% mmiversiny of the birth of Christ “in Bethletern, Palestine.” [ eouldn’t resist cemarking lo one of the American negotiators tha I'd altways thought Jesus grew up as a Jewish boy, making thrice-yearly visits at festival time to the temple in Jerusalem, a a time when there was not a church, much less & mosque, in sight 377 {BARAK [92 Still in my mestings with Clinwn, T assured him T wes not giving up altogether an the prospects for peace. Not only did I feel that would be wrong, as long as there was a semtilla of hope, | believed that our continued diplomatic engagement nihil provide 1 counterweight 1o amy moves by Avsfat fo revert 10 violence, 1 was also eitical for Tseae] to retain the diplomatic, political and moral high ground we had earned in the eyes of the international community from the concessions we had boon willing lo consider. When the President suggested dialling @ final Anicrican paper. based on Camp David though presumably with an even more geuerous proposal for the Palestinians, 1 agreed. [ figured even Arafat might realize at some point that if he did want a negotiated peace, the time for dithering was over. Clinton would no longer be president in five months’ time. Unless 1 could Gud an alternative way to refortify my coalition over the coming weeks it was entirely possible I'd have to form a “unity” coalition with Arik and the Likud. Still, 1 told President Clinton | doubted the ticking clock would make a ditTerence 1o the Palestinian leader. Tf it didn’t. T believed at some point all our talk about an “ead of contlict” would give way to conflict. The only question was when. Tragically, | got the answer only weeks after my return from the LIN, ose Al the urging of the Americans, 1 invited Arafat and his negotiating tam 10 private dinner in Kochav Yair on the 25th of September. The atmosphere was surprismygly warm, for which a lot of the credit, ws well as culinary praise, bas to Lo 10 Nava “Very cordial, even congenial, Nihil Shath old reporters afer the dinner, nearly 45 minutes of which I spent talking alone with Arafat on the stone terrace out back. Each of us spoke ro Clinton for about L0 minutes near the end, anid the President was obviously pleased Ww hear us sounding upbeat about frying to arrow any differences on the forthcoming American negotiating paper. On the substance of our differences, by mutual agreement, Arafat and I didn't say much to ch other. 1 did ivy to impress on bin tha me was gelling shor. His monosyllabic reply — yes — veas at least better than the alternative. 1 else fo believe we could both now focus on trying again 378 {BARAK 193 The cequest that had come across my desk a few days earlier need not have changed thar. Tiven though Arik had failed. foc aow, 1 bring down the government, he was keen to male political capital from the collapse of Camp David. He mow declared his intention lo pay a visit 10 the Temple Monnl. The Mound — or as it was called in Arabic, [faram al-Sharil — was part of Isiacl. The unsubtle point of Arilc’s visit was to dramatize his determination to keep it that way. | he target of this political theatre was nol Artal or the Palestinians. [was the Israeli public. me. and my goverament. In an all-pecfoet world, 1 would have liked to find a way to block the visit. In a democracy, it wasn't that easy. The only way [ cauld do so was on the grounds it was a threat to public order or security, a judgement in the hands of our police and security services. [ duly asked for the views of Avi Dichter of the Shin Bet, and Shlomo Ben-Anii. who in addition to Deing interim Foreign Minister was Minister of Internal Security, in charge of the police. Both came back with the same answer: though we'd all be happier if Arik stayed down on his farm in the Negev, there was no reason to expect his visit would pose 2 major public-order issue, and no basis for blocking ir. When Shlomo contacted Jibril Rajoub, Arafat’ West Bank sceurity commander, Rajoub ssked only that two conditions be imposed. and Shlomo ageeed. The first was that the visit not occur on a Friday, when the mosques would be full of worshipers; the second, that Sharan not set foot in either of the mosques on the Haram. Our chief of police: informed Sharon thal iF be didn’ seep the eonditions, we'd deny him permission to go. But he agreed. When he went, for about half an hour under police escort on Thursday moming the 28, he complied, AU first, we thought it would prove a one-off media stunt. But that evening, Danny Yatom brought me an intelligence report with evidence that Arafat's Palestinian Authority was planning for wide-scale violence after Friday prayers, in protest over Sharon’s visit. anmy ealled Dennis Ross. Madeleine Albright called Aqalfet. 10 urge him 0 ensure this didn’t happen. But as Dennis would remesk later. “Arafat didn’t lift finger to stop it.” ‘The trouble began the next day, shartly after Friday prayers. It was also the eve of the Jewish New Year, and the Western Wall area weas crowded. As people poured out of the mosques. a number began hurling stones. some of them the size at small boulders, onta the Jewish worshippers and police below. One knocked out the highly experienced. stcady-handed evmmander of the Jerusalem police, whieh T'm sure contributed to making the confrontation that followed even worse. By the 379 {BARAK 191 <od of the day, dozens of Tseaelis and Palestinians were injured. Five Palestinians lay dead. Though the media almost instantly labelled it a new “intifada”, this one was very different. It was not u burst of anger, however misdirected, by stone- throwing youths convinced Thal s road accident in Gia hud been something more sinister. There had been no serious unrest on the day of Arik’s visit. We would later learn this was a deliberate campaign. waged with guns and grenades. by Iamas and Islamic Jihad, the Fatah offshoot Tanzin, and Arafar’s own police force. The media had changed, two, in the 13 years since the first intifada, with the rise of twenty-four-seven news broadcasters, including the Arabic-language Al Kizeera, Inmiages of pain and sufering and fear stoked anger on both sides. None, in the first days of the violence, was more powerful, or heart-rending, than the pice of a terrified 12-year-old Palestinian boy named Mohammed al-Durrab, sheltered hy his father as they took cover [rom the crossfire in Gaza The facts of the incident, as best we could establish immediately afterwards, were that the Palestinian security forces had opened fire on Israeli troops near the serclement of Netzarim. “Ton Palestinians, ieludimg te Ble boy, lost Heir hives when the soldiers reiuned fire. We later established with near certainty that the boy had in (act been killed by Palestinian gunfire. Bur even if we'd been able to prove that at the time, I'm sure. that in the increasingly poisonous almosphere, it would have made little difaence. Nor would it have changed the next, deeply disturbing escalation: the spread of the violence into Israel itself. with unprecedentedly serious clashes between our awn Arab citizens and the police in the Galilee, in Wadi Ara, in the mam mixed Arab-Kewish ities, and the Negev. Beyond the political implications, the demonsteations of solidarity with the Palestinian violence presented a security challenge of a different order: to the ability of the Israeli police, and by extension the government, to ensure basic law and order inside our borders. The worst of the lashes lasted barely a week. Bul they left thirteen Arab Tsracli protestors dead, sparking demonstrations as far afield as Jaffa. as well as gly incidents of mob violence by Isncli Jews agnst Ants in some sas President Clinton tried his best to help us halt tie violenee on the West Bank and in Gaza. I doubled the Americans would succeed, but was fully ready to join in their efforts to try. About ten days into the new mifada, 1 attended a crisis meetmy with Arafal, mediated by Madeleine Albright and Dennis Russ, at the US ambassadot’s residence Pacis. Tt was nominally under the aegis of President 380 {BARAK 195 Chirac, but the understanding was that Madeleine would be in charge. Far from showing any willingaess to end the violence, Arafat at first simply lied. [le said the Palestinian violence was in response to an unprovoked assault by [srieli oops, and demanded an intentional “protection” Force. There wis u panticulatly biz moment when J read out the names of individual Taozim leaders whom we had intercepted organizing the attacks. Arafat pretended he'd never heard of any of them, almost as if'| was reading from a zoology lextbouk about species of polac bears. This wag a man who had been awarded the Nobel Peace Prize. What he really deserved was an Oscar. But people were dying. Needlessly. We ended up agreeing to a US-led fact- finding commission, as well is a number of steps to separate the Palestinian auackers and Israeli units. T reaflirmed our policy of insisting that Israeli soldiers use live fire only if they felt their lives were under threat, Arafat undertook to order his security (owces and Tanzim ood 10 launch further attacks. Tle even phoned Gaza wilh what we were given Lo understand were explicit orders. Bul it was all for show. as we discovered when we were invited to the Elysée Palace to meet Chirac. “The Freneh President had ekeny received advance word from Aral abow his demand for an intemational “protection” force, presumably with a role for the French. To my surprise and frustration, and Secretary Albright's as well. Chirac sisted thst no agreement was sceeptable wathont ia happen, “Then, he fumed to me, demanding w know why the violeace had lef nearly 400 Palestinians dead, ‘but barely two dozen Israelis, if the Palestinians were the aggressors. “Mr President,” I said, “just several weeks ago we were prepared to go very far in order Lo put this entise confliet behind us. 11 is My Arafat who rejected the proposal, ven as a basis for negotiations. Just a basis to seek peace. TTe then deliberately turned to terror, We are protecting ourselves. and our soldiers. Are you really saying that you'll be happy far us ta sign un agreement to end it only when wnother 350 Tscaelis are killed? 'm not playing that game. Arafat started this, TTe has 10 stop it ‘We know he can. and we hold him responsible if that does not happen.” It did not happen, We tried all we could to prevent a further deterioration, | approved moves, in co-ordination with the Palestinian police, a lower bur security profile where possible. We made sure Israeli police were not visible from the ‘mosques on the Haram al-Sharif. But atter the next Friday prayers, a crowd made its way 10 a police post at the edge of the Old City and auached it. In Nablus, the ‘burial site of Joseph had long been a source of tension. Shlomo Ben-Ami reached 381 IHARAK 196 an agreement with the Palestinians to replace an Tseacli woop cordon there with Palestinian police. But on the morning of Saturday October 7th, hours after the Palestinian police took aver, a mob attacked, bumed and ransacked the site, They destroyed the Torah scrolls. A Gow hours later, our soldices found the body of cabbi from a nearby settlement. Tle had gone Lo survey the damage to the synagogue Tht evening, | delivered an ultimatum: “If we don’t see a change in the patterns of violenee in the next two days, we will regard this as a cessation by Arafat of the peace process.” Thar did, briefly, have an eftect. When Clinton reinforged my message later in the day, Deans told me that for the first time, he sensed that Arafat realized be had 16 uct. Bul again, it was not enough, nor in anything like a sustained manaer. And with an appalling zet of murder thoes days atterwards, it was 100 late, That outrage came in Ramallah, Two Israeh reservists Look a wrong tun and ended up driving inw the wn. They were taken Lo the Palestinian police station. Tluodreds of people broke ia and stabbed them, gouged their eyes out and disembowled them. In a chilling image broadcast around the world, one of the murderers brandished the bloodstsned pans of hs hands ma gesture of triumph. Since | was Defense Minister as well, 1 spent the hows hat followed in the Aza. We ordered atrack helicoprers into action for the first time. thongh with advance wim fo focal Palestinians i the areas we tngeted. We destroyed the Ramallah police station, as well as a militia base near Arafat's headquarters in Gaza. But Arafat emerged to tell a cheering crowd: “Our people don’t care. They don’t hesitate to continue their march to Jerusalem, the capital of the Palestinian independent state.” Tsraelis did care. TL is hard 10 say which emotion was more powerful: disgust or fury. But if the opinion polls were to be believed, a large majority wanted vs to hic busele with the full fore of tre Israch army. Still, sy overriding aim remamed fo cod the viokeee if possible, nol make it worse. When Clinton asked me to join him. Arafat. King Abdullah of Jordan and UN Secretary General Kofi Annan for a summit in Sharm al-Sheikh, {agreed We worked out a series of steps to disengage. Arafat was finally supposed to order the Palestinian Authority security forces and Tanzim to cease fire. and establish 10-0 perimeters around cur amy pasitians. We would reapen Gaza airport and. over u period of two weeks. pull back our forces 10 where they had been before the violence began. But agai, it didn’t happen. The Palestinian attacks intensified and, as I'd made clear at the. 382 {BARAK 197 sumimil, we responded. The only, brief, lull came when Acafat feared the Americans would cancel his scheduled visit to Washington Lo see Clinton on November 9. [was due to follow him three days later, met Clinton and Dems Ross over diner in a litle kitchen arc attached to the Oval Office, and buth seemed surprisingly upbeat. The President said he'd told Arafat the broad points that would be in the new American negotiating paper. ft wits Camp Dirvid-plus. Assuming all 1ssues m a final peace were greed, the Palestinians would now end up, afier a land swap near Gaza, with a “mid-90- percent” share of the West Bank. On Jerusalem, the puiding principle would be “whit is Arab will be Palestinian, and what 1s Jewish, Isaeh.” On the Temple Mount, the Haram wl-Sharf, cach side would have control of its own holy sites. Finally. though Palestinian refugees would be fee io return in unlimited numbers 0 4 new Palestinian state, there would be no “right of return” ta pre-1967 Israel, ‘The President told me that alle lie'd run all this by Arafat, he and Dennis had asked whether “in principle” these were pacameters he could aceept. Arafat had said ves. Tassie they expected mie 1 siy the same. But 1okd them 1 couldn't give them an answer. What concerned me now was the violence. Until it was reined in, 1 would not be party to rewarding Arafat diplomatically. [ urged the Americans to ‘make ending the violence their focus as well, because if they didn’t get tongher on Arafiu’s noncompliance with anything resembling a de-csealation, tsracl wouhl do so. ve a Since the Knesset had recurned before my trip to Washington, I'd needed first to make sure my government would survive, The obvious, or at least 1he most mathematically secure, choice would have been a deal with Sharon. Lispecially since the lynching in Ramallah, there were calls from politicians on all sides for a wmly coulition between Labor and Likud. Arik defimicly wanted in, “The main issue seamined the peace process. | didn't find Arik’s specific abjections to Canip David hard to deal with. As Td said from the start. the fact that we'd failed to reach an agreement at the summit meant that any concessions I'd considered were now, 383 BARAK 198 in legal and diplomatic terms, null and void. The package Arafat had ultimately rejcoed had not even been presented by me. IL was an American proposal. Besides, it was obvious no seriqus negotiations were going ta happen anyway far the Toreseeuhle fire. Arile, however, said he winled not just u “Tull divorces” from Camp David. Tle insisted we Formally declace an end wo the eatice Oslo process. Trold him that was a price Twas not prepared to pay for his support. Despite the failure af the summit, and the terrible human cost from Arafat's choice of violence aver diplomacy, there was a wid intentional recognition thal it was the Palestinians. not Israel, who were responsible. For us to end the Oslo process meant inviting accusations we'd never intended fo reach & peace agreement in the first place, and Una it was fre that was closing te door. We would also risk Jorfeiting the American support we'd secured by our efforts to reach a peace deal, am asset all Israeli governments would benefit from in other circumstances and contents in the future. Vorunately, | iad an aliecnalive 10 a coalition with the Likud. Alarmed at the prospect of a having Sharon in the government, the Oslo-era doves in Labor, led by Yossi Beilin, worked ont new dial with Shas. The Sephari Orthodox pitty was sill not prepared to rejoin the cabinet. but it did promise “safety net” in the Knesset to ensure we would not have to worry about no-confidence vores while canfronting the Palestinian vioknce. | knew Shas’s support would waver if there was i resumption of serions peace negotiations. SGll, as Clinton continued Lo insist we make one final attempt 10 get a deal, 1 felt we had a responsibility to play our part, {wasn’t prepared to put us i the position of appearmyt to stoneweall ns efforts, end encourage the false mamative thal loach “iirmsigence” was somehow Irustrating Arafat's readiness to make peace. ‘The Palestinian campaign of violence was getting worse. An Islamic Jihad car bun near Mahanch Yehuda market m Jesalem minred nearly a dozen people and loft two dead. [amas blew up a school bus in one of the Gaza settlements. killing two more peaple. In Hadera, halfway up the coast from Tel Aviv to Haifa, a car bomb on mam street left fwo people dead and more than 60 injured. Palestinian snipers from near Bethlehem began opening fire on Gilo, ou of the post-1967 Teswish suburbs of Jerusalem, and home to more than 30.000 people. Yet despite all this, 1 autharized Shlomo Ben-Ami, Gili Sher, Amnon Lipkin and Yossi Ginossar Lo continue talks with Palostinian nogotiators on the terms of the President's last-ditch peace proposal. 384 BARAK 199 By the end of November. T believed that the chances of a peace agreement with Arafat were so microscopic as lo border ou non-existent, and thal my own ospects far retaining sufficient support fo be an effective Prime Miniscer much beyond Clinton's departuse were nal much better. 1 wis not just Arik and the Likud. but other pactics on the right thal were actively alempling Lo briog down the government. I was being squeezed politically: by opposition to the concessions. specially on Jerusalem, I'd heen willing to consider in pursuit of a peace aprcement. aud by the ever-worsening Palestinian violence. Shlomo Ben-Ami put it best, saying that in the view of most Israelis, “Arafat's response to Camp Dayid was not peace, it was an intifada.” By the second part of Novenber, there were five separate motions of no- confidence working their way through the Knesset. T could have quashed them all ata single stroke, since Arik, both publicly and privately, was canveying fo me his continuing terest in joining a oily coalition. Bul T again decided against it, at his stage nol so much because T expected a peace deal, but because [believed continued Israeli engagement in the peace process was essential to preventing Aral from evading his responsibihily for malimg a deal impossible Teould also have wrongfooled ny opponcuts by insisting that ay cay election be not just for a new Prime Minister but for a new Knesset, something very few existing Knesset members were anxious to see happen. 1 did, in fact, do precisely that a1 the end of November, delaying an immediate move tw try to topple the government. But T immediately regretted doing it. The game-playing side of Dalitics was the part | least understood, and most disfiked. 1 recognized that to bring down the Kuessel along with me would be nnfiir 10 the couniry, not lo mention my own Labor Pacty, which still had the largest aumber of parliamentary seats. In pursuing my peace efforts with Hafez al-Assad, and at Camp David, I'd insisted | was acting on the mandate ['d received in the Prime Ministerial election. Tr the peace efforts had failed, or if 2 significant pact of the country fell T was wrong to have tried in the way I did. surely the responsibility for that. too, should all an me. remained confident | had been right 10 make the eTorts with Arafat, with Assad, and. of course, to have followed through on my pledge to withdraw our troops from canon, But beievimg that yon ure right, even if later events might bear you uu, was not all that mattered in politics. You liad 0 be able 10 bring the public with you. Tt was clear my support was ebbing away. Looking ahead to the 385 {BARAK 100 challenges [sracl would face during Clinton's final peviod in office and afterwards, Tknew I could not go further without seeking a fresh mandate from the county, Tawever unlikely the prospects now seemed, Deciding fo do so was a decision thal was probably casier for me thm for other politicians. Privileged though 1 felt as Prime Minister w be able 10 pursue what | felt deeply were Israel's national interests, the mappings of office were not that mmportunt to me. 1d gone mio politics to do things. not for the photo opportunities, Jabid still believe it was iportant to see te final diplomatic push by Clinton through to its end. But 1 knew an <arly election for Prime Minister wouldn't happen overnight, It would myolve a couple of months” preparation, ve When | ealled a news conference on December 9, the media, and the country, assumed that il wes about the Palestinian violenee and the ups and downs of the Clinton initiative, and 1 did talk about both, But at the end. | said: “There are those wha doubt the mandate | received from the ertizens of Israel. | have decided to seek a new mandate — to lead the state of Israel on the road to peace, security and a proper civic and social agenda.” I said I would go see the Israeli President the following morning, “0 will formally resim, and run for a special election, at the head of the Labor Pasty. for the Prime Ministevship of Ismael” The election was set for February 2001. The last act in Peesident Clinton's attempt at a breakthrough actually came after the American election, and just a month before George W. Bish wonld succeed him. Since, in pracucal ers, ny final agreement would almost certainly come under President Bush, Clinton's final ‘negotiating paper was framed as a set of paramaters which, if agreed to by both sides, were intended ta set the stage for a fimal deal. On December 23, Clinton presented the drat to both sides” representatives at the White louse. | wasn't there. But the accounts I got from Shlomo, Gili and Dennis Rass afterwards made me feel as iF 1 was, The president said he would red through the document snd then leave the Isaeli and Palestinian teams with Dennis w make sure they'd recorded each detail. [Te said this was no longer the starting point for further argument on the bse shape oF a peace deal. This was his considered judgement of 386 BARAK 101 what would constitute a fair agreement. TTe was presenting it an a take-il-or-leave- it basis. IF either side said no. he would withdraw it, and it would not be binding on President Bush. He proceeded 10 Lay oul Ins proposal. 1tnow envisiged the Palestinians ending up with between 95 and 97 pereent of the West Bank. Iseael's military prescnee in the Jordan Valley would be for a maximum of six years. after which our soldiers would be replaced by an intemational fore, On refugees, the solution Clinton proposed would “make it clear there is no specific right of return Ww Israeli itsel™ ut recogaize “the aspiration of the Palestinian people to return to the area.” He proposed a joint endorsement by Israel and the Palestinians of the right of refugees 10 vet to a now Palestinian stale. In Jensalem, Arafat would have sovereignty over the entirety of the Old City except for the Jewish Quarter and, of couse, the Western Wall and the “holy space of which itis 4 part.” Finally, the President said, this would be a fined peace: an ead of conflict aod. voce implemeated, an cad to any futher clainis. Tle wanted replies [rom Tscael and the Palestinians within five days. Dennis added that. while both sides could come back with reservaions. if any of these Rell ouside the substantive hmils of President Clintons parmnetes, the sesponse would be interpreted as a “no” and our scarch for an agreement would De over. Clinton's latest proposals went beyond even wht 1 was will to have him keep in bis pocket ac Camp David. Opposition politicians in Israel, and even a few off our cabinet ministers. promptly objected tw the formula for Jerusalem. T told the eritics as | knew I'd have to argue to the country in a referendum, m the vanishingly unlikely event we acitally reached an sgrecement — that miking peace was aot like making love. Tt was something you did with enemies. 1, 100. would have preferred to say no to Clinton's ideas on Jerusalent. But to reject them would have placed Israel in the position of rejecting the entire Clinton paper, something | was not prepared to do. I sent word to the President that we accepted his ideas. We did raise reservations fwenty-cight in all, bout how various pitts of the agreement would work on the ground. But none fell outside his parameters for peace spicement. At first Arafat asked the Americans for more time. Then he went to Washington to see Clinton, There, he presented his “reservations”. They were not just outside the Clinton parameters. They rejected two key elements. Arafat said there could be wo 387 {BARAK [102 Tscacli sovercigoly over the Western Wall of the ancient temple. Noe would he agree to any compromise on the “right of return.” For me, that was the tinal answer. As one Palestinian leader remarked to me amd the still-cscalating temor attacks @ couple of years later, the Palestinians had “needed a Ben-Gurion, bul we got an Avafar™ He didn’t mean Ben-Gurion the Zionist. but the statesman who at crucial moments like the partition vote in 1947, could give up his maximulist hopes and dreams in order to sceure a better future Tor his people. Arafal fell much more comfuriable, more sceure, when the suicide Tombers were calling, the tune. Then he could whip up the crowds with promises of “miechmyz on Jerusalem” or jet round the world telling everyone that Ismael was denying his right 10a state. Though | now knew an agseenient was impossible, for many on the Lsracli lef, ‘my ostensible allies in the forthcoming election campaign against Arik, that was see 10 accept. Parteularly for Yossi Surid of Meretz, and 10 2 cerin extent Yossi Leilin too, the vuly explanation for vur failure tw get a deal had to be thal we hadn't negotiated well or creatively enough. The idea that Aratat simply didn’t wimt a two-state peice was anathema to them, So was the political platform [ssid that {hoped to implement if | was re-clected as Prime Minister, Maybe, al some point in the future, a negotiated peace might be possible. We had accomplished something of importance at Camp David, We'd made clear our red lines, We knew where Analut stood. But for now. 1 believed we had to move on, both in order lo keep the situation on the ground from getting worse and 1 act in Israel's own long- term political and security interests. I said we should unilaterally disengage from the West Bunk and Guava. The idea was straightforward. The Palestinians” unwillingness o accept even the final Clinton parameters, driven home with murderous terocity by the explosion of violenee since Camp David, should not be allowed 10 panlyze Issel politically. I proposed thal we map oul Lhe area we required to retain and scourc the major settlement blocs, as well as the outer Cast Jerusalem suburbs: a further security strip along the Jordan River; and several other strategically important 388 BARAK 103 paints. Tt would amount Lo retaining contcol aver around 20 percent of the West Bank, but none of the major Arab lows or cities. Though deliberately stopping well shart of share of the West Bank Arafat could have secured through i negotiated peace, it wonkd remove lsmaeh troops and seks from most of the teeritory. It would give the Palestinians ample room lo set up a state if they so chose, and conceivably to expand its area if some future leader had more of the “Ben-Gurion” in him than Arafat. Until then, it would allow both of uur peoples to ton with their lives and focus vn their own political and social and cconomic challenges ‘There was a second. critically important part to what 1 was proposing: the onstnetion of a physical scourily fence along the now “disengagement line with the West Bank. Tt was the suggestion rejected under Rabin, acoepted under Peres amid the Hamas bombings in he 1996 election campaign, but never followed through an. Even under the new arcangemeat I envisaged, Tsraeli Loops would cetain the freedom of action 1o respond Lo, or pre-empt. tersor attacks with Lacgeted operations inside the West Bank. But the physical barrier would hugely increase aur abit fo hall the auackers before they could sirike Yet even if I'd been able 10 bring those on the left of Labor behind thie plan, this election campaign was poing: to be a lot tougher than in 1969. Since Knesset members waren’! running for their seats, the Labor machme lacked its usual incentive put up posters, knack on doors, or gel out the vote. Arik, however, benefited (om the enthusiasm of Likudniks and other right-wing activists who saw an opportunity to retake control of Israel's political agenda. Long before election day. | realized my time as Prime Minisier was up. Before the campaign began, an old friend of mine, a leading Israeli journalist, tried to talk me into withdrawing. “You're going to lose, Ehud.” he said. “Why, after making all this effort for peace, afler doing your best, do you wanl thie last act lo be losing 10 Arik?” I'd never seen the objective as just staying in office. If that had been the case, | wouldn't have put the chances of a peace deal with Syria fo their final test. { wouldn't have gone fo Camp David, | also would have acecpled Arik’s serial ffs 10 join a unity coalition. But never in my life had | walked away from a challenge. T certainly wasn't going to retreat in the midst of Palestinian violence, and when sriel stil faced key decisions on how to mave on from Arafar’s unreadiness io negotiate an end w our decades-old con flict 389 BARAK 101 1 did regret being unable to rely on the support of two key constituencies that had helped deliver my landslide victory barely 8 months earlier: my own Laboe Party and the Aral citizens of Iseael, | had no frouble understanding fhe reasons many (srieli Arabs sere abandoning me. The lashes in the Galilee al the stan of the sew intifada had le mose than 2 dozen of thee community dead. As an official inquiry would later conclude, there was blame on all sides. A number of Arab members of the Knesset liad played a part in inciting the violence. Yet the police had heen unprepared, and they had used excessive free. As [said publicly before the election. I as Prime Minister, was ultimately responsible, and 1 formally apologized for what had happened, Yet the roots went deeper, to the economic and social disadvantages still faced by many Arab eitizeus, and the difficulty in resolving those problems calmly and collectively as long as Istael remained ina state of war with its Arab neighbors. Tor Labor and the political lefL, it wes as if, despite Arafat's repeated rejections of ever more fortheomiog terms of peace. they still couldnt bring themselves to believe he really meant it. By default, they were inclined ro blame me for not delivering peace. | was neeused of relying foo mich on a close eireke of aides and acgotiators ['d knaven from my time in the army. of not giving a negotiating ok lo Labor veterans of the Oslo negotiations like Yossi Beilin. and of being msulficiently sensitive 1o Arafat's needs in Lhe negotiating process. Typical of the argument was a broadside by the journalist and historian Tom Segev, in fa aretz, which accused me of an “incredible arrogance” which had “led to an historic mistake. Rather than continue on the Oslo road, Barak put it into his head that he could reach u final sciilement and try aud impose it on the Palestinian Authority President.” T did not try to “impose” anything on Arafat. T did, quite consciously. abandon the “Oslo road” because it was inexorably leading to a situation where, after the final Wye redeployment, Arafat would have control aver the reat majority of the West Bank without having lo commit to any of the assurances that ‘even most on the Israeli left would define as the minimum required for peace. Now, of course, we knew tht was something the Palestmian leader was not prepared to do When election day came, not that many of my critics on the left actually voted azuinst me. Nor did the Israeli Arabs. Yet in very large numbers, they simply didn’t vole. In percentage terms, Asik's victory was even more decisive than mine over Bibi. Tle got more than 62 percent of the vote. I received barely 37 percent 300 {BARAK [105 Yet the wenout was the lowest in Tsracli history. Arik received fewer votes than T bad in 1999. Acound half of the 1.8 million people who had supported me stayed au home, 1 conceded deft ailer he first exit polls and sid 1 would be stepping down as head of the Labor Pasty. Still, since the election bad bea only for Prine Minister, Labor remained the largest party in the Knesset. Mathemarically, Arik might be able to cobble together the required 61-seat mapority with un assortment of smaller pavtics. Bul without Labor as ballast, his government would be even more precarious than mine. When I triggered the election, he'd let it be known that if he won, he hoped to include [bor in his government, with me as his Defense Minister. Even though 1°d anounced 1 wis stepping ssid. he phoned me the morning after the election tv make that argument again. Ile said Israel needed a strange government, especially to confront the escalating violence, Having a person with my background, whom he kaew well and trusted, in the defense portfolio was important. I didn’t say yes. Unloctunately, I failed to do what I should have dove: didn't immediately say no. When the public leaned about Sharon’s interest in i umty goverment, Labor descended ino bickering. Some of my former ministers, like Yossi Beilin and Shlomo Ben-Ami, were against the idea of joining any Likud-led government. “They were especially disuusted by the prospeet of domyg so under Arik, the archileet of the 1982 Lebanon War. Most of the Labur’s central commitlee did seem in favor of joining. But given the scale of my election defeal, many wanied do so without me, For a few days, Arik kept phoning me. | did feel that the substanes of the amungement he suggested made sense. Bus over tha first week, | realized thal, understandably. he had litle interest in addressing my policy concerns. I decided to focus instead on ensuring a properly organized transition to anew Labor purty leader, amd publicly confirmed that | would indeed be resigning Several weeks after Arik formed his government — including Labor, with Simon Peres as ane of four deputy prime ministers he invited me to his office. He wimted lo ask my views on u specific security question. That fook barely 15 minutes. But 1 raised another issue that argued would have more far-reaching implications. Tt was the idea of building the security fence along the West Bank. 1d tried to mike the case for domg so during the election campaign, and I'd lost the election. “Now I'm fuming fo you. When [lef uffice, 39 Isvaclis bad been killed in the tercor attacks. Now, there are 70. When the number reaches 700. 391 {BARAK [106 thece’s no doubt you'll decide to build this fence. But to your dying day. you wont be able 10 look yourself in the mircor and explain why you waited for another 630 Israelis to die first.” He did eventually strt building it, but only m the wike of wn act of terrorism which, even by the standards of this new and still-escalating intifada, was truly abscene. In March 2002, suicide bombers murdered 30 people, mostly elderly, as they were celebrating the annual Passover Seder m a hotel dining room m Netanya, Arik bil back two days Later with Israel's krgest miliary opesation on the West Bank since 1967. Israeli forces retook major Palestinian towns, placed Aratat under de fucto siege in hus headquarters m Ramallah and imposed curfews and elosures. In June, the government formally approved the seourity ence. Still, another year would pass before the major part of the barcier was in place, by which time sume 500 Israelis had been murdered in the terrar attacks, Only then did the number of casualties begin to fall 1 tried Lo steer elear of public eriticism of Arik's government. One of the lessvos Td learned as Prime Minister was how easy it was to second-guess from the outside. No Prime Minister can act exactly as he might plan or want 10, The most vou can do is make sure you understand and analyze the issues and follow your instiners, experience and conscience to came as near as possible to doing what you beheve is right, You will mevitably mike mistakes and misjuduements, | certainly did. Al least some of the criticism | received was deserved. 1 was at limes loo inflexible. T tended to limit my focus to a small group of rusted aides and advisors. Twits less good ut schmoozing with ar, perhaps more importantly, delegating to thers in the government or the party. [ suspect it’s no coincidence thal the man who brought me into government in the fiest place was olen criticized for the same things. By character, instinct and experience, Rabin. tao. remained less a politician than amitary mm. Yet towards the end af bis sceond period as Prime Minister, be did et better at delegating to people around him, and creating an atmosphere that encouraged teamwork, even when he knew he could not accept or act on everything they might suggest. During my term as Prime Mister, | was much loss good at that But another thing Yitzhak and I shared was a determination to set ourselves specific goals and do everything we could to achieve them. [ promised to get the army out of Lebanon. With the Palestinians, [arrived in office convinced that the process begun in Oslo was both a huge opportunity and a potential dead-end. T was 392 {BARAK [107 determined 10 focus on Lhe cod goal: initially, at least, a framework agreement, and over time a (inal political eesolution of our conflict. Ever since the outbreak of the Palestinians” firss intifada, | believed this was as much in Israel’s own interest as thers. Yet when Centered office, we had no way of knowing whether Arafat wanted two states living side-by-side in peace. © felt it was my duty to find out, and, if the answer was yes, to put a peace agreement iu place. I felt the same about way about Syria and Hafez al-Assad When lel ollie, 1 believed had scehieved the most important goals of my premiership. We were out of Lebanon. Though we couldn't achieve the peace anzreements | had hoped for, it was not for fack of trying, Along the way, Ismiel ud demonsteated 1o the world that it was able and willing lo consider painful compromises, and that it was the Arab leaders who, at least for now, were unequal ta the challenge of making peace. [f I'd been able ta retain the backing of the volers who made me Prime Minister in 1999. we might even have moved ahead on unilatecal discogagement from the Palestinians. dramatically altering the trajectory of our relationship. Yet even without that, Camp David did delineate the terms of amy future peace amagement. When ae iF conditions il lowed i restumpiion of serious negotiating efforts, the shape, and indeed most of the details. ora final peace between our peoples were now clear. Twas on holiday in the summer of 2001 when Clinton phoned me. 7he New Times had run a picec on how and why the summit, and the subsequent negotiations through the end of the year, ended in failuce. When T later read the article, by the Pulitzer Prize-winning reporter Deborah Sontag, | found it a meandering mix of opinions garnered from an assortment of Americans, Turopeans, Iscaclis and Palestinians. including Arafet himsell, with the overall conclusion thar Clinton and I had not offered as cenerous a deal as was assumed ancl tha 3 was somehow unfair 10 sugwest the Palestinians deserved blame Gor ejecting it. There liad been several other articles in various publications along the same lines. [ didn’t see much point ar this stage in setting the record straight. To the extent the content of the Times piece bothered me, at wis a simple, but important, enor of fact. Quoting Arafat himself, Sontag wrote that during the back- patio discussion I had with him at the dinner in Kochav Yair shordy before the new intifada. he'd “implored me to block Mr Sharon’s plans” ta visit the Temple Mount. Arafat dida’t raise the issue at all, and presumably knew that we had consulted his West Bank security chief 1o ensure it happened quickly, avoided the 393 BARAK 108 mosques on the Taram, and would not become a catalyst, or in this case a pretest, for violence. Yet the revisionist history about our peace efforts left Clinton not jusc Trustrted, bul wenuinely puzzled. What the hell were these people talk boul, he asked me. Why were they missing the forest for the trees. “he rue story of Camp David,” he said. “was that for the first time in the history of the conflict, you and I, the Prime Mimister of Isrucl und the President of the United States, placed on the table a proposal, based on Resolutions 242 and 338, very elose to the Palestinian demands. And Aratat reused to accept it as a basis of negotiations, walked out of the room, und deliberately tumed fo terromsm.” All the rest, President Clinton suid, wis gossip. All of it was now isrelevau. Loo. 11s parameters were of the lable. Palestinian vialence against Istaelis was gefting ever deadlier. And | was out of politics. When 1 delivered my final vamirks lo a Labor Party meeting, | wis asked whether [was leaving politics for good. 1 replied that | would always main a member of Labor. But [saw my role as a bit like when I'd Teft the amy. “I'm a reserve officer,” | sil, acting that hoped would not be called buck to duty my time soon. 1 had heen Prime Minister for aly 21 months. But Id been in polities for six years. and in uniform for nearly thirty-six: in public service for more than four decades. Now, suddenly. 1 was « private citizen, And foro few years, 1 actually stayed thal way. 304 {BARAK 109 Chapter Twenty-Four Thad only a geaecal idea of what T would do next. “Something in business” describes it best. But 1 sought the advice of a friend who, rather than leaving politics, had just entered iL. Colin Powell was now the second President Bush's Searetacy of State. “Why don’L you 20 on the lecture ciceuit?” he said. The short answer was that it hadn’t occurred w me that ['d be any good at it, But it proved anrgering snd interesting both Ror me and. it seemed. the andienies | spoke lo. [8 was also lucrative. | would deliver four lectures over the span of a week and ead up ‘making twice what, until that point in my life, Thad earned during a full year. Iwas also malted onto a number of company boards, 1 med down sore, in order 10 avoid even the appearance of a contlict of interest. But 1 did get involved in an area where I believed my range of experiences might be relevant: investment decisions, and venture capital. The result was a drumatic chinee in lifestyle. Nava and [gol 10 spend more Lime with our daughters. We vacationed overseas for the (iest time. We also decided t build a new home, und the place hat we chose gave me my first experince of how far | was from being « “private citizen” in he eyes of the lsrach public. When it became known we were planning to move to Kfar Shmaryahu near Tel Aviv, one of the wealthiest places in Istael. all hell broke loose. [ow coutd you wis asked | couldn't resist joking that | just wanted 1 be close 1a one voters. Likud supporters were about as rare in Klar Shmacyahu as panhandlers. Along with Mishmar ITasharon. it was the only place where I'd polled over 80 pacent even in my loss lo Sharon Israel had changed dramatically from the kibbuiz-centered pioneer socicly of my youth. Greater Tel Aviv, in particular, was thriving economically. and the rismy crop of millionaires, whether from traditional business or in the bourgzeoning technology sector, included its Geir share of former kibbuumikim. Sill, socially and culturally, a puritanical streak remained. a sense that there was something not quite right about people raised on a socialist ideal becoming personally well off. 1 aecepled this. | recomized thal | wis nol just a former kibbataik. 1 had been head of the Labor Party. And Prime Minister. Sull. [did feel much of the personal criticism was unfair. 1 had devored more than four decades of my life to serving my country. I'd behaved with sermpulows honesty while in office, and was avoiding 395 {BARAK 110 any business involvement that could present a conflict of intevest now that Thad lel. Praokly. T saw nothing wrong with earning money through honest endeavor, and using the proceeds to provide economic security for myselt and my family, and fo gave our grandchildren s beller start in hfe than Rava’s or my own parents had been able to do. Tn the end, we didn’t move to Kfar Shmaryahu. But that was because of an even more profound ehinge im my fife: 1 separated from Nava, after more than 30 years wwgcther, When we had begun plans 1 ose, §langhed oT a warming from i psychologist friend of mine that decisions like building a new house could lead to a deeper reassessment of vour life, But that is af least in part what happened. There were also other changes that eased me tw stop snd take stock. | was no louger Prime Minister. My father had passed away soon after 1 Jefl office. Professionally, wis exploring new areas and developing new interests, Nava and [ had been happily mardied since our Lweoties. We had three wonderful daughters, and a ficst eandchild. Yet the more I thought about where we were inoue lives, the more [ felt our future paths were pulling us in different directions. For both of us, the separation was difficult, though it wis mace a bil less painful because Nava knew that it had nothing to do with another woman, or another relationship. [ did imagine that 1 might one day meer someone else. But Iwas equally prepared for it ot happening. | certamly didn’t expect it ay time soon. When it dic, it began by accident. A few weeks afier onr separation, [was visiting the Knesset for a discussion about fixing Tstael’s broken electoral system. In the andience was 1 member of one of the ¢ivie associations pressing for reform: Nii Pricll, say first, und only, serious girliend before met Nuva, We spoke for a Few minutes allecwards. We agreed lo meet again. and catch up with cach other's lives, a week or so later. Both of us now had grown children. We were both on our awn. There is, [assume for everyone, something impossible 10 replicate abo s first love. Nili and T were givea an unlikely second chance. That seemed to me an exwaordinary gift. It still does. Yet if my personal life scemed full of new promise, the same could not be suid of the country I'd served for my whole adult life. ar of the political panty 1d led into government. The continuing construction of the security fence along the West Rank finally did begin to reduce the sheer number of Palestmian attacks: from nearly 50 in 2002, 10 about hall that number in 2003. Bu the suicide bombers who did get through — from Tames, Islamic Jihad and Fateh’s “Al-Aqsa Martyrs’ 396 BARAK 111 Brigade” - struck wherever they could inflict the most terror, and death: at bus stations, on buses, in shopping centers, restaurants and cafés. Over a 12-month period, beginning with a bombing of Tel Aviy’s main bus station at the beginning of haary 2003, they murdered 145 man, women and ehildren. 1 wonld not be until Lwo years” later, with the West Baok fence in place and a range of othee security measures, that the attacks, and the deaths. were finally brought down dramatically. “Ihe Labor Party had finally lef Arik Sharon’s coalition in late 2002. But in Israel's 2003 election reverting to the old rules again, with a single vote for party and Prime Mumister Arik and the [kd won resoundingly, They doubled their Knesset seats. 10 38. Labor, now with only 19 scats, against tired to Shimon Peres, as interim party leader. 1 didn’t miss the political limelight, But by mid-2004, with the first sigm of a aor hinge in policy toward the Palestinians, | Rell | hid a contribution to make. What fist prompted me to dip sy toes back. into polities were the ever more abvious signs throughout 2004 that Arik’s coalition, and his hold on the Likud. were unraveling. Pant of his problem was a study drimbeat of compton allegations around what had become a kind of Family political operation: Arik aud his two sons, Omri and Gilad. But Arik also seemed to be undergoing a welcome palitical conversion, to the need for the more profound political “disengagement” with the Palestiviaus which I'd lng been advocating, He ud endorsed the Bush Administcation’s “road map” for resuming the peace process. Yet with Yasis Arafat ageing, ailing and even less inched to consider the difficult decisions he hal shirked at Camp David, Arik wen! one, dramatic siep farther. He raised the idea of unilaterally withdcawing Israeli forces and settlements from Gaza — ensuring a showdown with the rank and file of the Likud. and other parties on the right. His main Likud rival, very much back in front-line staf politics, was bis Finance Minister: Bibi Netanyahu. Though Bibi semained oa board until the last ‘moment, he dramatically resioned for the cabinet in August 2005. a week before the Gaza withdrawal, decking: “1 am not prepared to be i pariner to a move which ignores reality. aud proceeds blindly wward turaing the Gaza Sup into & base for Islamic terrorism which will threaten the state.” To this day. Bibi, along with many Israelis across the political spectrum, draws a dire fine between our pullout From Gaza, Hamas's takeuver and its violent purging of Tatah's old guard there. and the periodic wars we've had to fight since 307 BARAK 112 then in response to TEamas rocket fire into Tseacl. The mocal: Arik was wrong lo withdraw. But the Islamists” ascendancy was happening anyway. Afer all, it was Hamas attacks that provided the spearhead of the intifada of terror launched in the wake of Ciamp David. Arafat's own miluence was also inexorably on the wane by the time be passed away. in Paris, a1 the end of 2004, 10 be succeeded by Abu Mazen. 1 do not know of a single senior figure in Israel with any military axpesicace who believes that we would be more secure today if we still had thousands of soldiers and settlers inside Gaza. Surprised though 1 was by Arik's decision to leave, 1 had na doubt that the fundamental security judgment he was making that a disenjzagement was in Tscael’s own interest was the right one. | was encouraged, loo, by his parallel amouncemnent of a small, token withdrawal from a few small West Bank settlements. My regret ac the time was that he did not £0 further toward the kind of major West Bank disengagement I'd been arguing Tor, and hat even in Gaza the pullout seemed insulTiciently prepared or thought out. The model, T believed, should have been our withdrawal from Lebanon — involving detailed prior consultation with, and political support from, the UN and key infemational allies, also felt it was erincally important to ensure that, while we would obviously need offshore pawrols 10 prevent arms and munitions from getting in, we allowed and encouraged an environment in which the Gazan eonomy could function and grow after we left. None of that happened. Though we Ie Giza, we effectively scaled of und blockided ane of the most densely populated, economically strapped and politically febrile strips of land on the face af the earth, SHI 1 did se 1 us tn smportant first step toward the kmd of wider disengagement that would prioritize Tscael’s own security interests, and political and social cohesiveness. until and unless conditions allowed a for a serious new effort for u final peace deal, 1 was heartened when Shimon fed Libor back inte Adil’ coalition at the start of 2008 wo ensuce he'd have the support necessary 10 go through with the Gaza withdrawal. And while 1 did make a brief attempt to rerun as party leader bater in the year, when it was clear {wasn’t going to win, | threw ay support behind Shimon and agaiast the other challenger. the longtime labor- union leader Amir Peretz, who was runing on a platforr to take Labor out of Sharon's govemment, But Peretz wan the leadership election. He did leave the cabme, forcing Arik 10 call an early election for March 2006. And that, along with the most ambitious and 308 FRARAK 113 ill-fated Tsracli war in Lebanon since 1982, was the reason 1 ultimately found myself beck in the Israeli government Te began on July 12, 2006, when Tizbollah fired rockets from southern Lebanon as cover for un ambush of two Israch Humvees on our side of the border. Two soldiers were killed, and two others ahducied. A few hours later, when un scacli armored unit crossed to look for the kidnapped soldiers, an explosive charge blew up one of our tanks, lalling four of its crew members, Arik was no longer Prime Minister by then. With Bibi marshalling opposition inside the Likud to the Gaza disenagepment. he had formed a new centrist party called Kadima, along with prominent I ikud moderates and buttressed by a |.abor heavyweight: Shimon Peres. Bul before the lection, Ak suffered a pair of strokes, lapsing into a coma [rom which he vould never emerge. is notional deputy, the veteran Likud politician and former Jerusalem mayor Eaud Olmert, found lmmself as Prime Mimster. Kadima did comfortably win the May election, If <nded up with 29 seats, followed by Labor with 19 aud leaving the Netanyahu-led Likud with only 12. Olmert formed a coalition, including Labor, which had undeniable political ballast: Shimon wis one of his deputy Prime Ministers, along with Haim Ramon. The gified lawyer, longtime Likudnik sud strong backer of the Gaza plan, Tzipi Livni. was Foreiga Minister. Amir Peretz. as head of Labor, was sven fhe Defense Ministry, But without Sharon himself a the helm, the overnment was now shout to face s military crisis with virtually no military experience around the cabinet table Olmert called an emergency cabinet meeting on the eveaiag of the Iizbollah aaek, and ust before al was due to converte, my phone rng, 11 was Shimon, who, though with no first-hand any experience, did at least have the political ‘experience in war that none of Olmert's ofher ministers could offer. He'd been by RBen=Gunon’s side durmg the 1956 war, had been mn Golda®s govemment in 1967, and was Defense Minister aller the 1973 war, though Entebbe, until Begin's defeated Labor in the 1977 election. Despite our own battles inside Labor, Shimon and 1 had become closer agam of late, especially after I'd supported him m his fist 309 BARAK 114 Labor leadership contest. “Shalom, Ehud.” be said when T answered the phone and. without small talk or preliminaries, asked me: “What do you think we should do?” 15aid 1 couldn't offer specific suggestions. “It's a detail-related question, and 1 dont know the details.” But 1 advised nm on the process | fell would be needed to come up with the right answer sehen te chief-of-staff, the former air force ehicl Dan Halurz, briefed the cabiner. “Halutz will propose what to do. Psi him." 1 sid. “When he prosents his recommended ction, asl him for his assessment of what Hizbollsh will do in response. When be, or the head of military intelligence, has given you the range of possibilities and told you which is the most likely, say. OK, let's assume that happens, What's our rent step? Hows is that gome to lead us 10 ous sain objectives? And what are the objectives?” Newspaper reports the nest moraing said that Shimon, and only Shimon. did indeed press the chief-ol-stafl about each further stage of the operation and bout the aims that we wanted to accomplish. Bul ITelutz finally fobbed him off by saying that once they gat lo the Tater phases. they could discuss it From the first reports I received through my army contacts. T feared the aperation would go badly. There was no doubt we could inflict damage on Hizbullah. But there were no clear answers to the questions Shimon had raised. The initial Israeli air force response had been put in place more than five years <arhicr, when [was Prime Minister, Codenamed “Operation Cinnamon Sticks,” it was dosigned to lake ou ll of the fixed Uizbollah missile sles we hed been able to identity. We knew its limitations. A lot of the rockets wee fired from mobile faunchers. But in one exercise, the known “Hizbollah” sites were replicated in the Galilee. hey were destroyed in 43 mines. {had no donbl that part of the plan would succeed. Tn the early hours of July 13. it took valy 34 minutes to destroy the nearly 60 launchers we had pinpointed over the previous five years. But Operation Cinnamon Sticks had been futended as a first step in a far wider assault on | lizbollah and other targets. including a number of infrastructure installations, deeper inside [.ebanon. It was part of a plan for a full-scale war, if the government decided that was necessary. As the early public statements by Olmert and other ministers made clear, they did not intend 10 start a war, at least at the outset. They certainly didn't have a coherent plan for one. But they would soon find themselves in Israel's longest single armed conflict singe 1948, When Hizbullah fired hundreds of missiles ot Lsrachi wens and cities, vur operation intensified not by plan or military logic, but improvisation. As a former Prime 400 {BARAK [115 Minister. T felt it was not my place 10 eriicies Olmert publicly welen Tseacli troops were inaction. Two days in, in fect, I wld a lelevision interviewer that the government had every right to respond and was doing so effectively, Olmert phoned lo thank me. When he, like Stmmon, asked whit 1 thought the goverment should do next, © was steaightforward: “Do your best 10 bring things 10 aa end as soon as you can.” I said that Ilalucz and the other generals would be caught up in the aperatiouzl details, which made his role and that of the cabinet even more weitical. “In any operation, you'll have an idea about what represents a satisfactory exit point. But there will be a temptation, when you get close to that point, to take just one more step, to keep going until you're absolutely sure you've reached it.” Resist that temptation, | okt hin. | said there was a danger that, before they kow it, he and the other minister would be in way over their heads. In pure military terms, there were just rwo realistic choices in responding the Tlibzollah attack: a deliberately limited and (airly brief vperation, or a full-scale wae. We ended up doing neither. The resull was an operation that lasted 34 days, nearly twice the length of the Yom Kippur War. Our air force flew 12,000 missions, more thin in 1973 and nearly twice as many ws in the 1982 1.cbauon War. Hizbollah ficed about 4.000 rockets into [sracl — fom a stockpile we estimated to number nearly 20,000 — and not just at the border settlements but as Far south as Haders amd Hani, keeping hundreds of thousands of 1sraclis wader effective siege. More than 120 Jseacli soldiers and 44 civilians were killed. Sv were hundreds of Ilizbollah fighters and, inevitably, many Lebanese civilians as well. with a predictable surge of criticism from much of the outside world. Only President Bush and Britain's Tony Blair sieadfastly reminded the erilics of how the war had actually begun The ane putative victory for Israel was the UN cease-fire resolution that Tzipi Livan helped to negotiate in August. Al leas! on paper, il contsined s commitment 10 a “long-term solution” including the disarmarient of Hizbollab and the “unconditional release of the abducred Israeli soldiers. which has given rise to the current exisis.” Bus as [snk newspapers begin speaking 1 the retming soldiers and officers, a pietuee emerged ool just of a long and difficult war, but a lack of clearly communicated military objectives, and an often-chaotic chain of command, ‘which ended up costing Israeli lives. Our tinal advance, alone, shartly betore the cease-fire, claimed the lives of some 30 soldiers. And for what, many lsvaclis were soon asking themselves. One of the newspapers most supportive of the operation at 401 {BARAK 116 the beginning summed up the feeling of most of the county at the end: “IF you don’t win, you lose... Tlizbollah survived Tt woo the war.” Without the botched handling of the war, 1 might well have remained a mere member of the Labor Party and a private citizen, But when the commission of inquiry released its report in April 2007, three people were singled out: Olmert, Amir Peretz and Halutz. Olmert was portrayed as a military novice who'd gone mio battle without understanding the wartime role and responsibilines of « Prime Minister. Halub's “oxcess of charisma” was held responsible for keeping ‘ministers, and military officers as well, trom questioning his judgement or pressing, hum for altematives. Amir Peretz wits found to be the wrong man in the wrong cabinet post al the wrong time. OF he three, only Haut seemed ready to ke personal responsibility. Even before the report came out, he resigned. Olmert and Peretz were determmed to stay pur, despite calls to quit not just from the apposition bul from Tzipi Livai. Tnside Labor as well, the war produced a clamor Tor change. When a vole for pasty chaieman wes held in June 2007, T was chosen to return in Peretz’s place. Within days, 1 replaced him as Defense Minster as well, Yet the min ilem m my in-box sould no louger be Lebanon. | liad been briefed a few weeks carlior by ‘Olmert on a threat hundreds of miles further away: a construction site in northeast Syriu, along the Euphrates River, where Mossad hid uncovered evidenes that the Syrians. with technical help from North Korea and funding from Iran, were building a nuclear reactor. ve a Thad got to know Olmert fairly well over the years, initially when 1 was in the Sirya nd both be and another visi | iknd politieian lo whom {heesme closer, Dan Meridor, were members of the Knesset's defense committee. But from the day 1 returned to the Israeli government in June 2007, there was growing tension between ns aver dealing with the Syrian nuclear threat, It was not boul wieder we should take military action lo destroy the reactor, before the fuel rods arrived on site and it could begin producing bomb-ready material. Just as under Menachem Regin in 1981, when we'd lannched our preemptive strike on Suddam Hussein's 402 (BARAK 117 reactor near Baghdad, there was never any question thal we would take any and all possible measures to prevent Syria from getting a nuclear weapon. An immutable, core assumption in Israel’s security smateiry was the need to retain our ability fo deter, and if necessary defea, our enemies. A nuclear Syrie — or Ina, or ran would dramatically alter the balance of power in the region, at obvious risk to Israel. Syria posed a particular threat, as part of an increasingly close alliance with Iran, and with Llizbollah in Lebanon. “The question, however, was how and when 10 strike the reactor. Olmert wanied to attack within days. He seemed to assume that. as a former chief of statf. ['d nod enthusiastically and go alam with him, {did understind the reasans for his sense of urgency. Not only did we hive to mike sure we atuscked before the fel was on site. There was always the risk the Syrians would find out that we were aware of ther nuelear facility, putting them on even higher alert, But the operational challenge was complex. We need a fail-safe plan lo destroy the reactor. We had © do itin such a way a3 10 avoid a full-scale military confrontation with Syvia il’ possible. And we had to ensure we were ready for that, if it did happen. It took very litte time for me wo realize thal none of those prerquisties wis ye! in phice Not unlike the recent Lebanon war, we were ¢hoosing between two ofl-the-shell plans from the fry. One involved using a large military force, and would almost cortainly daw ins into a major conflict with Syn. The other was a smaller, Lacecled operation. But it remained unlested, and there was no certainty it would acrually destroy the reactor. Over the next few months, Olmert got more and more trustrated with the tact we hadn't yet attacked, and frustrated with me as well. We held dozens off meetings. sometimes lwo of thee a day, chaiced by the Prime Minister, sometinies Dy me as Defense Minister, or by the chief of staft or service commanders. Invariably, | began my remarks by saying: “We bisve to destroy the reactor.” This wag nol because T felt that any of us seriously doubled that. TL was because Olmert was beginning to suggest to the few ministers and senior officers aware of our plang thet | was weainst wlackng the reactor. In fact, | was working with the military and Mossad to cusure we had a plan that would succeed, with the minimum possible risk of drawing us into a major clash with the Syrians after the tacility was destroyed. | was also working with fhe help of the Americans ta make sure we could get the forees and munitions in place in the north of [sracl w 403 BARAK 118 deal with a major conflict with the Syrians. All of this. under a tight seal of secrecy Finally, in <arly September 2007, everything was in place. Olmert brieted the cabin, snd scenred the ministers” approval to destroy the reactor, with the understanding that the precise liming of the operation would now be lefl wo the Prime Minister, the Defense Minister and the Foreign Minister: Olmert, me and “T7pi Livni. The three of us met immediately after the cabinet discussion. Olmert argued that the risk of leaks justified auacking thal night, and {agreed with him. Tzipi was reluctant, but Olmert turned to her and said: “Are you sure you're comfortuble with un uitack being ordered by me and Barak, while you chose fo abstain?” She thought it over, and added her approval. We struck just aflec midnight, in an intricately coordinated air autack tha. evaded not only a Syrian respanse, but Syrian notice, The reactor was destroyed. Althongh even toy the exact details remain subject to Isrcl’s military seercey regulations. accounts published abrozd in the weeks and moths that followed painted a surprisingly aceurate picture, includini the pioneering use of electronic wrfure capabilities to deal with risk of acter detction. But in the immediate aermiath uf the attack, lseael defiberately made wo public comment. We refused 10 say whether we'd had anything to do with an attack. As we he had hoped, this allowed the Syrian President, Bashar al-Assad. both the space and 1 good reason to deny that it had ever happened, deny that le'd been trying lo make a nuckeas weapon. and thus feel no compelling reason to retaliate. PE ‘The reactor operation, however. marked the start of au increasiagly tough period in both my and Tipi”s relationship with Olmert. Policy wis not the problem. These were no major security exises in the months ahead. But in the spring of 200R, it became known that the Israeli police were investigating Olmert's relationship wilh an American businessman sumed Moshe Talansky, ‘The suggestion, initially in a New York paper and then the Isracli press. was thal Olmert was guilty of taking bribes. In his first public response, he did't deny 404 {BARAK 119 ceociving money from Talansky. But be insisted it was all a part of election campaign evolributions. Publicly, [ reserved judgement, “1 hape, for evervone’s sake, and for Prime Minister Ofmer!’s sake. that the suspicwons now circulating turn out to be baseless.” | wld a reporter. “Let's be patient.” Privately, [urged him to lake a leave of absence and clear his name. Yet with other ministers convinced that would make things worse, 1 held off doing anythmg else until there seemed to me no choice, after Talinsky gave evidence in Jerusalem's District Court. Though he ‘enuinely seemed not to have expected anything specific in return. he said he had wwven Olmert somethmg like $150,000 m cash, | called i news conference the next day. | didnt say whether or uot { thought Olmert was auilty. | did say that | believed he couldn't continue leading Lhe country while resolving his “personal matters”, Things finally came to ahead in September 2008, When Kadima held fresh leadership elections, Tzipi Livai won. Olwert contiemed he would step aside for his successor. But under Israeli law, he would remain Prime Minister until she either succeeded in forming a new government or called early elections. She opted an the end for Option B, md the election wis set for Februsry 2009. “That meant Olmert would still be Prime Minister for another three months. We'd long been discussing the increasingly worrying sivaion in Gaza. After Arik pulled out, an election had placed Hamas m power, after which the Islamists <mbatkedd am # violent pure of Fatah loyalists, Arms smuggling through Lumels {rom the Sinai had become rife. Rockets [rom Gaza were now landing on southern Israel. Hundreds of thonsinds of Israelis were living with the reality of a warning siren andl rapiel dash into their shelters. For a while, wid negotiations through Taypt 10 end the rocket fire, we limited ourselves to sending small ground uaits into Gaza to target the source of specific racker attacks. But thar was always going 10 eve only a limited effet. [also rn the risk of our soldicrs being abducted, or killed. Pressure was building for a major military operation. With the election drawing rer, Bibi Netanyahu was reminding voters that he'd been agamst the pullout from Ciaza, and saying that we should now hit Hanes hard. Both Ohnent and Trip, along with most of the cabinet, were also in favor of doing so. But my long-held view, remforeed by the recent war agaist Hizbollah in Lebanon, was that we hid 10 begin by deciding what we wanted lo accomplish, and what was possible. Only then could we Lake action. T told the cabinet that, operationally, we were perfectly 405 BARAK F120 capable Lo taking over Gaza. Bul wha ther, T asked. Unless we were prepared to resume open-ended [sracli conteol, we'd be lo with 110 one to cun Gaza afterwards. The obvious candidte, Egypt, was even less interested than we were in assuming esponsibility For the nore Hen onc-ancd-u-hall million Palestinians who lived there. © doubted that even Arafat would have been ready 10 do so. But relations had only worsened. since his death in 2004, between the Fatah old guard in the Palestinian Authority on the West Bank and the Lamas overlords in Gaza. | doubled very much that Abu Mazen would want to get involved. 1 did send an aide to see him to ask whether, in principle, he was apen fo reassuming control of Gaza following an Israeli talceover. His answer was unsurprising and unequivocal: no. 1 scenred cabinet support for the more limited wim of restoring u period of calm Jor Tsraeli citizens in the south. T said the militacy operation had to be as sharp and short as possible, and end with some kind of political understanding thar the cockets would sop for a sigaificant period of time. The final plan was presented Lo ainisiees a few days before the operation. Tt would begin with surprise aic suikes and a naval bombardment, followed by a limited round incursion to hit remaining Hina targets ouside of the major refugee camps, which 1 was detemmice lo avoid. The whale operation was intended 1 last for two week at the most Topefully. closer to a week, with diplomatic efforts through Ty pt to secure a Lasting case-fite and, ideally, prevent Hamas from resipplying its rocket suvchpiles through its smuggling tunnels from the Sinai When we launched Operation Cast Lead on the morning of December 27, nearly all the Hamas forces were where we'd expected them to be. Two wives of sir strikes, with over a bundied ois und stack helicopters, killed 350 Hamas lighters. We destroyed amass headquarers and dozens of its government end police installations. The attacks continued in the days that followed. We took a mange of actions designed wo minimize civilian casualties. We dropped leat before bombing sorties, phoned resideats. and fired light missiles before heavier ordnance was used. Still, 1 realized tha civilian casualties were unavoidable — if nly because Himzs, like Hizbollh in Lebanon, was dehberately Gring its rockets from civilian seas, sometimes even near schools ue hospitals. Civilian casualties were obviously wagic in themselves. They also made it inevitable that the longer the operation went on. the more likely we were fo fice international criticism. and diplomatic pressure to bring it 1o an end. That was an additional reason | had insisted that the operation be well defined and time-limited. 408 {BARAK 121 But both Olmeet and Tzipi soon fell prey w the same self-defeating temptation that had worried me during the meandering war against izbollah. Our ground incursion began a few days info the operation, The intention was to stay for a few nore days und then, responding lo mevitsbl informational appeals, call a hall w a campaign that had alieady achicved ncarly all of its targets. Perhaps wanting to ‘balance the failures in Lebanon there with “success” in Gaza, Olmert wanted us to continue, and expand our attacks deeper into Gaza. | reminded him that we'd agreed the aims beforehand. The longer we stayed. the loss clear any gains would be. Yes. our ground forces had so far faced virtually no resistance or casualties. “But that's because we're outside the main populated areas,” 1 said, “The deeper we gel iu, the better it will be for Hamas. They gain simply by surviving, like Tlizbollah.” Yet Olmert kept insisting that we'd succeeded so far, so let's not stop. It wasn't until January 17, three weeks after the operation hegan, that we announced a cease-fire. Militasily, the operation was a success. While [amas launched nearly 3.000 rockets inw Israel in the year before our attack, there were only 300 in the vear that followed. But politically and diplomatically. the extra week reduced, rather tin helped, the ehimees of reaching in understanding for a longer-term reduction of the attacks. To the extent there was any political gain, it was to burnish Tzipi Livni's credentials as a tough potential Prime Minister ahead of the election. Thal was nol her meat. OF all the politeians I"ve known, she is among the least interested in sueli games, especially with lives at stake. But it was one of the effects. She won the election. in a photo finish, with opinion polls suggesting she'd been effective in shaping the campaign as i choice “between Lzipi and Bibi.” Kadima got 28 Knessel seas. to 27 [or Bibi and the Likud, which gave her the list crack at torming a povernment. There's no way of disguising the fact that Labor's result in my first election bck m charue wis a disappomiment. We went down six seats. to 13. The big gainer was a far-right, stridently anti-Arab party called Fisrael Beitenn. led by a former Likudnik named Aviedor Lieberman. Tzipi's aftempt to Torm a coalition beeime less a polineal process than a contest between rival stalls in a Middle Lastern bazaac. Bibi was holding pacallel talks with the Orthodox ‘parties critical to assembling a parliamentary majority. Ile was matching and raising every assurance af a ministerial seat or budjetary concession that T7ipi was prepared tw offer. In the end, she threw up bee hands, saying she refused 10 draw out a process which was not so much a negotiation as organized extortion. I am 407 {BARAK 122 sure she won the respect of many Tseaclis for taking an all-to-tace stad of principle. She certainly won mine. But Twas not alone in wondering whether it was worth the price that she, Kadima, and the country would pay as a result: Ribi’s Telus as Prime Minister mu Likud-ked coalition, Though | was not surprised when he asked me to remain as Defense Minister, and to keep Labor inside the coalition, that was not an easy argument to make to my reduced Knesset contingent, They saw joining Bibi, especially in a government wilh the right-wing Lieberman as Foreign Mivister, us @ betrayal of all the eons that they and [ had made to achieve peace with the Palestinians. Still. the decision «an whether to join the coalition ultimately rested with the party central committee, ahnost every ane of whose members wis on # local goverment connil. For them, the choice was between a share of power, however limited, and the wilderuess of apposition, So we jomed Bibi's government, 1 was personally m Gavor of our doing so, bul for more comphested reasons, 1 knew that Bibi’s background, his instincts and his undeniably paver ful political rhetoric were all tirmly rooted on the political right. | recognized that he was often more interested m polities thin policy, and perfiups above both of those, in the Lactical maneuvering required lo consolidate bis political position. Bul | had known ‘him long enough to dismiss the suggestions of many of my colleagues that he was mielicernally shallow, 1 felt he wus capable of doing what was best for Iscael, and that he had a basic pragmatism that would guide how he got there. All that. however, was just a reason for not saying “no” when he asked me and Labor tv stay on, The reason | felt it was right to say yes had to two with specific policy challenges. The frst wes fo cusire there al leas! some peace process with the Palestinians. Bul that, in tura, was in lacge part because I believed it would win us. the diplomatic support, especially from the Americans, needed fo tackle a more aren! threat 11 agsin involved un enemy stale trying to gel melon weipons. Bul aol Sycia. The Tslamic theoccaey of Tran. We'd been aware for a number of years about Iranian efforts to go nuclear. The Mossi had notched up a series of successes in delaymy the Inmians from getting there. But they were petting inexorably closer. In fact, when I'd taken over as Defense Minister under Olmert, T formally directed the new chief-of-statf, Gaby Ashknazn, to get to work on a plan to attack the most important facilities in the Iranians’ nuclear nework, with the aim of pushing back the point at which they might develop a bomb by five to six years. But it became clear we didn’t have the 408 (BARAK 123 operational capacity to mount such an auack, in part because we lacked the occessary bunker-busting bombs and the lanker aircraft 10 get us 10 Tran and back. T did seelc help from the Americans. | met Defense Secretary Bab Gates, CIA director Mike Hayden, National Scourity Adviser Steve Hadley and even President Bush himsel. While not explicitly mentioning that we were planning military action against Iran, I sounded them out on the prospects of getting more heavy munitions. and possibly leasing several US tanker airerall. Yeu in our final meeting with President Bush, during a visit 10 Ise] in June 2008, he made it clear to Olmert and me that he knew what we were up to. Olmert hasted a privite dmner for the President, Aflerwards, Bush asked to talk privately. Olmert poured us cach a ghass of whiskey aud lit a cigar, and we sank int brown leather armchairs. Smiling, the president looked sicaight at me, and seid to Olmert: “This guy scares the livmyg shit out of me when he tells me what you want.” He fold Olmert how 1d asked for heavy munitions, Tankers and i varicly of other military equipment. “Remember. I'm a former 1-16 pilot,” he said “1 know how to connect the dots.” Then, turning more serious, he added: “I want to tell both of you now. us President, the formal position of the US government. We sire wially against any action by you lo mount an aiack on the nuclear plants.” The effect was all the more dramatic because of his Administration’s support for our attack on the reactor in Syma the year before, “1 repeat,” Bush suid, “in order to avoid any misunderstanding. We expect you not to do it. And we're not going lo do it, either, as long as T am President. T wanted it to be clear” Olmert said nathing, so [ replied, “Mr President, we're in no position to tell you what the position of the United States should be. But 1 ean tell you what [believe history will have to say. I'm reminded by what we call, in field artillery, “bracketing and halving.” | said that in the wake of the Al-Qaeda attack on the “Twin Towers, he had fired one shell long. in Afghanistan, and another one shard, in Iraq. “But when the lime came to hit the real target — Iran — it ended up you'd already spent wo terms, and all your political capital.” He seemed neither insulted mar unsettled by my remark, He simply nodded. Perhaps, in prt, because he was prety sure that we lacked the ability to attack the Iranian facilities anyway. We sill lacked that capacity when I became Defense Minister in Bibi's government in Muy 2009, But fhe main reason I’d stayed in the job, and my mam 409 FBARAK 7 121 focus from the day Bibi's government ok office, wag to do all T could wo change that. 410 BARAK 125 Chapter Twenty-Five Thad hoped that in facing down the nuclear threat from Tan. T could audge Bibi towards a reengagement with the Palestmians not with great enthusiasm, but as an act of pure political pragmatism. There were only wo ways we could stop the Tranians (rom getting a nuclear weapon: for the Americans to make suce that happened, or not to hinder Israel from daing so. Fither was woing to be « lat harder af there was lension with the new Amerie president, Barack Obama, over moves 10 vive the peace process with the Palestinians. T didn’t expect it to be put to the test so soon. Yet within weeks of our taking affice, President Obama faunched un effort to restart negotiations, declaring it “nnolerable” tha there was still not a Palestinian site. He was explicit about what Israel needed to do. In an Oval Office meeting with Bibi in May 2009, and ina speech in Cairo fhe next month, he called for a total halt fo settlement construction on the West Bank. US opposition To setllements wasn’ new. For years, Washington's position had been that they represented “an obstacle to peace.” The mam issue wasn't even the creation of new seftlements, since there had heen almost none in recent years. 11 was the expansion of existing ones. The Jewish population on the West Bauk had been about 190,000 when T became Prime Minister. In the decade since then, it had prow to 315.000 — more than half-a- million af yon counted the Jewish neighbortoods bul inside the expanded, posi- 1967 boundaries of Jecusalem. The expansion — “natural growth’ as we euphemistically described it to the Americans — was what President Obama now wimted Bib lo end. 1 had no illusions about how bard it would be 1 get him to agree. With cach passing year since Camp David. the pro-setlement right wing in Israel had become mare confident and influential, In a way, the settlers and their supporters. passionately devoted 10 a “Greater Israel” and opposed 10 any Pakestinian stale — had become the 21*-century equivalent of the kibbutz avaal-garde ofa hal century earlier. The rise of Avigdor Lieberman's Yisract Bettetnu party was the latest sign, alongside n move vightward within the ©ikud iisell. For Bibi lo sty yos toa settlement Freeze would mean putting aside his own short-term political interests in recognition of the importance of our alliance with the Americans. Tle’d actually done this, twice, during his First ten us Prime Minister. He had greed 10 give the a1 {BARAK 126 Palestinians control of most of lebron, and accepted further withdrawals under the Wye River agreement. But amid predictable protests from the right, he bad promptly retreated from his Wye commitments, 1 knew that his default response to Obama’ ell Gov w scitlement freeze would be “m0.” And it was, delivered fivst lo the cabinet and then 10 the public, as soon as he got back from his talks with the President. In my repeated meetings with Bibi in the weeks that followed both onc-on- one, and within the informal group of elose ministers and aides known ws the Group of Fight I tried to persuade him that, if only because of America’s key role an Iam, we needed to shaw some sim of engagement with Obimir’s efforts, | was ot entively lone. One ally was an old fiend: Dan Meridor, who had rejoined the Likud before the election. Another was more unexpected: Avigdor Lieberman. Tle Was never goin to accept a settlement freeze, Not only did hus heart, and political interests, lie on the West Baok. Tle lived there. But like many in the party he led, be had come to Israel from the former Soviel Union. shaping & woddview that in ‘many ways remained European, and pro-Western. Le was worried about creating the inmression of blanket Israchi intransigence towne popular new Ameen Presideal, and isolating ourselves internationally, if we did't go some way towards helping to restart talks with the Palestinians. “Though Biba showed no signs of retreat on fhe seltlement freeze, be did accept that broader point. Ten days aller Obama's Cairo speech, he publicly accepted the idea of a Palestinian state for the first time, having ruled it out as recently es the month before in his White House talks with the President, The shift was dismissed as trivial not just by the Palestinians, but by may in my own Labor patty snd almost everyone else on the lef. T disagreed. TRnew how deep. genuine and longstanding Bibi's resistance to Palestinian statehood was. But I had another, serious eoncern about the “peace plan” he armounced: wn entirely new precondition bie insisted the Palestinians must meet if peace wag ever going be possible. Tle said they must “clearly and unambiguously recognize Israel as the state of the Jewish people.” On a whole series of levels, this made no sense 10 me. We udn’t asked Lgypl ov Jordan w grant us explicit recognition as a Jewish state when we ‘made peace with them. Even when Bibi himself had briefly tied to apen negotiations with Damascus in his first period as Prime Minister, we'd never felt the need 10 ask it ul the Syrians cither. To the extent there was any logic in demanding it of the Palestinians. Bibi’s reasoning seemed ta be that this would 412 {BARAK i 127 acutralize any secidivist claims to all of Palestine, especially since we had around 1.8 million Arab citizens living inside our pre-1967 borders. But as I told Bibi, that was i red herring, There was 1 more straightforward, legally binding answer; 1 pence treaty which, as wih Egypt nel Jordan, declared in end fo our conflict wd to any further claims on either side. My main concern was more fundamental. Bibi’s new approach contradicted the central thrust of Zionism: that afler centuries of powerlessness and persceution, Jews would nally take control of thieit own destiny. We now had our state. [tL was ‘more than six decades old. “Why do we need the Palestinians, or anyone. to validate us as a Jewish state? Why propose something that imphies the Palestinians somehow live say in whit kind of state we choose 1 be?” Yel the more | pressed him, the eleaser it beeame that fhe substance didn’t much matter to Bibi. His move was political, and tactical, aimed af staking out a position of power in he diplomatic process. Besides. he didn’L expect any new negotiations lo make eal progress anyway. As Defense Minister. Thad scope for taking steps with the Palestinians on my awn, With Bibis knowledge ind tacit aceoptance. 1 established a purticulaly strong relatiouship with Abu Mazen's Prime Minister, Salsa Fayyad. A respecied ‘economist, he operated on the assumption that neither violence nor negotiations seemed likely to lead the Palcsamians to statehood ws things now stood. He saw his roll is doing an end-sun. He would put in place the institutions. the infrastneture, the economy, the internal security and the stability needed for 2n eventual state to succeed. He was trying to do for the Palestmians what Ben-Gurion had done before 1948. Hee and {mel and talked olin but discreetly — sometimes in his office in Ramallah, sometimes in mine, sometimes over dinner in the 31"-Noor flat T was renting in central Tel Aviv. I remember one dinner in particular. I led him onto the temic after we'd eaten. Iwas a siznlingly clear night. You vould sec us far noth as Lebanon and, since the West Bask was bacely a dozen miles away, the twinkling lights of Ramallah as well. Ile gazed in that direction, then at the bright Tights of the svennes and restaurants and cals fir below us. Smiling, be ssid: “Ehud, why do you ned Remallah when you've got Tel Aviv?” I sniiled back. There was no seed to reply. Ile knew ny views. Not only didn't Israel need Ramallh. [was more convinced fun ever that it was in aur own interest, by treaty if possible and unilaiecal disengagement if nol. Lo remove Israel fron all of the ‘major towns and cities of the West Bank. 413 BARAK 128 Tissued a standing dircotive in the Kiva thal we should agres 10 anything Tayyad asked for, es long, as there no seeurity reason 1o say no. We ended up arranging a direct source of fuel supply to Jenin, on the northern edge of the West Ban, ancl bull nieve teaminals fo biandle 1. We facilitated construction permis for anew industrial zone. For a conference of international economists and business people. we set up VIP treatment at Ben-Gurion Airport, and limousine transport to the conference venue. | believed that if Vayyad succeeded in what he was trying 10 accomplish, it would be a benefit not just for the Palestinians, but for lsc] too. Ril was agnostic on Fayyad's efforts. Yet he recognized they did no harm. And in away, my support for them was politically convenient, To the extent the international community, especially the Americans, appreciated our efforts 10 help the Palestinians. Bibi and others in the goverment could, and did. claim credic. When there were complaints from the right. Bibi could and did say: “It wasn't me. 11 was Baruk.” My part in our relations with the Americans wes more politically delicate. As T continued to prod Bibi toward accepting a settlement freeze during the summer and aut of 2009, my de fucio rok became lo help smooth over the increasiyly cough edges in our Lics with the Obama administration. 1 knew key figures from earlier incarnations in their public lives and mine: Secretary of Defense Bob Gates, who head been President George H. W. Bush's deputy security adviser fn the int Iraq wav und then head of the CIA: aud Hillary Clinton, now Secretary of State. During a series of early rips to the US as Defense Minister. I met Gates, ITillary and other senior figures in the administration both formally and informally. In part because they were aware | Favored agreeing w a setilement freeze, they clearly found it a lot easier to talk to me than to Bibi. On one visit, to my regret and Bibi’s evident frustration once I'd got home, the press highlighted this dramatic difference in mood. Emerging from talks with me at the State Department, Hillary told ceporters that our talks had gone “wonderfully.” She added: “As longtime friends do, much was said. And much did't need to be said." Still, 1 was careful to avoid any explicit criticism of Bibi m my meetings in the LS. 1 wauld point out the domestic political pressuces on Lim in deciding how 10 proceed. Aad in any case, the Americans knew that no matter what L might say to chem, ic was Bibi's actions that ultimately mattered. He, nat I, was Prime Minister, swans is surprised as they were when he Finally announced w selllement freeze in November 2009. As with nearly everything else he did regarding the peace 414 {BARAK 129 process, it was hedged with several conditions. The freeze would not be apea- ended, but last for [0 months. as a way of boosting the effort Lo restart negotiations. It would apply to new construction, nt work already underway, And a would exelude the posi-1967 neighborhoods inside the expanded city limits of Jerusalem. Like his other moves, it was also dismissed as insignificant by the Palestinians. Though there was a formal restarting of the talks. they went almost nowhere during the period of the freeze, which Bibi ciled as a reason for uot extending it further. From then on, the negotiations produced even less. {dida’t buy the narrative that this was entirely Bibi’s fault. Abu Mazen remained steadfastly. deliberately passive, Obviously not inclined to tale the risk of further widening his sill with Hames in Gaza, he was content to celio the Obama. administration’s argument that nothing could happen until there was a setdement freeze. Once the freeze was announced, he went through the motions, avoiding: all the difficult issues, in he expectation Washingion would ensure the freeze was renewed. President Obama's initial Mideast moves had made it much easier for Abu Mazen to avoid any serious engagement. [n contrast to past presidents. Obama had placed almost all of the onus for progress on Israel, But the end result also suited Bibi. Though T never entirely gave up hope of persuading him it was in Isuel’s interest to seek a resolution of our conflict with the Palestinians, it became mare evident as the months went on that his aim was simply to keep things ticking aver, and wvoid aay major ew erisis. Ie appointed an old personal friend — a corporate lawyer named Yiczhak Molcho as our negatiatar. [ finally realized how pointless the exercise was when, during a visit to the United States, | found mysell in New York at the seme time as Molcho. We met at the Israeli consulate. We spoke in detail about the state of the negotiations. With Molcho still in the room, 1 phoned Bibi in Jerusalem on the scenre phone line. 1 said 1'd just been updated on the talks, and if seemed lear there were a number of suggestions Israel could make. with no domestic political risk but with every prospect of improving the atmosphere and accelerating progress. “Yitzhak is one of Istael’s top lwyers.” 1 said, “Hes struck dozens of deals in his life. But he strikes a deal when that’s what his client wants. Fou are the client. If you tell him: bring me back the best deal you can - not a peace treaty, just a deal on a specific issue he'll da it. But if his brief is simply to negotiate, he can 120 on negotiating forever, And it's preity elo me thist’s his brict.” Bibi sisted | was wrong. Ile said that what I saw as time-wasting was simple prudence. to make sure the negotiations bore fruit. But his approach never changed. Whenever it came 415 {BARAK 130 up int our innee Group of Tight diseussions. T could usually count only on Dan Meridor, and occasionally a handful of others, to argue in favor of any (orm of initiative on our side. In private meetings, Bibi did sometimes engage in discussion about what Iszacl might do. But he invariably sieered the conversanon elsewhere, insisting that the real issue was the Palestinians” lack of any interest in making peace My main worry wasn't the immediate future of the negotiations. For now, the chances of an ugreement. seemed close 1 zero. [1 was the longer-term damage Bibi's approach would do in further delaying any serious move by Israel to put our relations with the Palestinians on a more stable and sustainable footing, The dithering, delay and deadlock suited him politically. Ironically, my own clos on the security (ront had also made if easier for us 10 do next tw nothing. Intermittent outbreaks of violence always remained a threat, Yet the West Rank security fence, aloag with our military, police and intelligence measures, meant it was very unlikely we'd see a return 10 the full-blown tercor war of the second intifada. [was also working to secure US support for our development of increasingly eftective antiemissile weapons 1 reduce the threat from Him in Gia The overall result wag that for many, if not most, Isvaclis, the confliel with the Palestinians didn’ impact on their day-to-day lives. It was unseen and largely unfelr. Still, the effect of the stalemate on our relationstip with Washington did mutter: both for our seeurity cooperation on things like the suti-missile weapons and, crucially, the challenge which had led me into Bibi's government in the first place: keeping Iran from getting a nuclear weapon, «ss It was a mace agains! lime. he Inmians were producing mors and more velloweake, building more advanced centrifuges, accumulating more low-cnriched uranium, They were petting better at hiding and protecting the netwark of facilities being used 10 try to produce s nek weapon, And in the carly months of Bibi’s Prime Ministorship, the question we faced wasn’ even whether to take miliary action against Iran — something T knew. from Bob Gates and others. that the Obami admmistration viewed no more favourably than George W. Bush. It was 418 SHARAK 131 whether that would even be possible 10 strike before the Iranians entered their “zone of immunity” ~ the point at which the amount of damage we could do w their nulear program sould be too negligible to be warth the operational, political snd diplomugtic risks from such an altack. In the carly months, my prionly wis lo cosure we al least had a militery option. A full year before joining Bibi's ‘government, as Defense Minister under Olmert, I'd first tried to put an operational plan in place, only 10 find that the lack of heavy munitions and refuelling airerall made it impossible. [at was especially frustrating because at that poi, our experts calculated that a successful strike could have set back the Iranian nuclear effort by about six years, Given the Iranians’ knowledge we could attack again, and their need fo restart clandestine efforts 1 secure key components abroad, that meant a very real prospect of ending the nuclear program altogether. On joining Bibi's povernment, | began working, both with the £tvu and the engineers and techuolugical experts in our military industries, 10 make swe we had the weaponry and equipment, aod an operational plan for a surgical strike. Tt was not until mid- 2010, a year into Bibi's government, that [ was contident we'd reached that point, part thanks to Istaeh-produced heavy bombs and tanker wircraft, Our experts estimated we would still be able to set back the Iranian nucleac efforts by up tv four years, almost certainly encugh to end chem indefinitely. Yet making military action possible proved to be the easy part. The question now became whether we should be prepared tw launch 2 strike against Iran's nuclear facilities. Answering it was like a contest of three-dimensional chess, involving both an internal debate among: Iseael’s political and military leadership and discussions with an Obama administration whose priority remained to negotiate an end to Tran’s nuclear program. On major security decisions in Iscael. tw ministers always mattered the most: the Prime Minister and Defense Minister. Neither Bibi nor | doubted we had to ready to strike if thi proved necessary, Nor did Foreign Minister Liberman. Tiven for us. it was an option to be considered only when all other ways to rein in the Iranians were failing. We also apreed on twa ofher preconditions. We would have to secure international legitmacy, most of all from the Americans, for what would be a clear act of self-defense. And we'd need to demonstrate an imperative urpency to act. with the approach of the “zone of immunity” that would tke any military option off the fable for ood, Ideally, we hoped the US-led empisign of economic and diplomatic pressire would get Iran to abandon its nuclear ambitions, as Libya had done in the wake of 47 FRARAK F132 is teror attack on a Pan American airliner in the late 1980s. Or. as in South Alice, that a change in nuclear policy might come [vom a change in régime in Tehran, Yet realistically, we couldn’t count on either. And there was na doubt in aur minds thal i nul Ten reproseuted a hugely serious threat. 1 the Shi‘ile Muslim cegime in Iran did get a nuclear weapon, Sunni Arab states like Egypt and Saudi Arabia. and Turkey as well. would try ta go nuclear. Neither they nor we could assume that Iran was developing a bomb as & mere act of deterence. We couldn't exclude the possibility that, especially in a crisis threatening the survival af the avarollahs’ rule, Tran would use the weapons it was developing. It could even send a nuclear device in a container smuggled on board a commercial vessel docking in onc of Israel's ports. While few in Tsrael disputed the seriousness of the theeat, a numbee of Lop political und military figures had deep misgivings about military wction. Given the aeed for secrecy, most of our discussions look place within the so-called Group of Tight, olen also including the chief of stall and other top geaseals from the Airya. Both Dan Meridor and Benny Begin, Menachem Begin’s son and a minister without portfolio, were opposed 1 zn Isak attack fom the start. They were convinoed that the implications for the region, and for our relations with the wider world. were difficult to predict and potentially dire. Dan raised a further concern. He feared an Jsrach altick might actnally intensify Iran's effort lo get a nuclear bomb, only now with political cover, because it would argue it was acting in self- defense. The view of those opposed to an Israeli strike was that we should rely on American economic and political pressure to deal with the threat, And, if that Riled, on American military action. Ta November 2010, the intecnal debate came to a head, al a meeting involving the Group of Eight as well as the chief of scaft. the head of military intelligence amd the communder of the wir force. We convened in a villi that the Mossad kept for clandestine foreign visitors, near the coastal road north of Tel Aviv. The meeting began with a presentation by the generals of our attack plan. There was still core of ministers opposed: chiefly Din Meridor und Benny Begin, bul also Boogie Ya'alon, a former Sayeret Matkal eommander and chief of stall who Minister of Strategic Affairs. But the confidence and detail with which the plan was laid out, and the fact that Bibi, | ieberman and | were in favor of being prepared to act, pave me the sense that a majority would back militasy ection if it became necessary. The proviso would be the need for the chief-of-statt. and ideally 418 (BARAK 133 the heads of military intelligence and Mossad, Lo sign off on the operational viability of the plan That was what now ended any prospect of military action, at least tor a few months, Bibi, Licberman and 1 withdrew into a side room to talk with the chief of all, Gaby Ashkenai, ag well as the heads of military intelligence. the Mossad and and Shin Bet. We emphasized that no final decision on whether to attack had been taken. That would require a further meeting with the Group of Fight, and then the full cabinet. But we wsked cach of them lov their views on the operation. We Inew they had political reservations, along the lines of those voiced by Dan Meridor, On an 1ssue of this magnitude, it was accepted practice that military and intelligence commanders coukd weigh in on the political implications as well. But their formal role was operational and professional. Ashkenazi and the other generals did concede that in every area. planning, materiel, training and intelligence — vue attack plan was far ahead of where it had been a year cadier. Yet Ashkenazi, in particular, concluded tha the prepacations had not yet “erossed the threshold of operational capability”. 1 was furious. 1 respected the considered opposition of ministers ke Dan or eny Begin. had no problem with the ehieF-ol-stalT or other generals expressing similar views on the political ar geo-strategic implications of an Israeli attack, even thonizh our intelligence wssessments suggested the cangems were almost certainly unfounded. Yet whal | found astonishing was Ashkenazi’ suggestion Lat the “operational threshold” had not been crossed. Yes, this would be a demanding mission, [t was not without risks, Na operation was. But having followed every stage and detail of the preparations — and as « former ciel of stall and intelligence chief myself T believed it was simply wrong on a professional level 10 say that we lacked the capacity, and a workable plan, tor a military strike if the order was ven Ashhenezi’s objection did mean there was no way we wore 20ing 1 attack at Teast until well into the new year. Our discussions would continue, as would our refinement unl strengthening of the attiuck plan. So would Iran's progress toward ils “zone of immunity,” which wee now believed would begin late in 2012, a couple of years away. As that point drew closer, we'd face an ever-more-pressing need to decide finally whether military action wis necessary. 419 (BARAK 131 Yel the delay in getting 10 that point had serious implications for my role as Labor Party leader. Since the negotiations with the Palestinians were stuck in neutral, | was under increasing pressure fram within Labor to pull out of Ribi's government. What on eth was the point of siaying, they asked. All | was doing, Trom their perspective, was giving Bibi political cover for abandoning any serious effort to ger a peace agreement. Their argument was entirely reasonable. My frustration was that, due to the need for militacy scereey. {he counter-argment was impossible for me to make: that 1 felt [ had a responsibility to stay at a time when there remained a real possibility Israel might need to take military action against Iran. Ta a mix of constemation and anger among many Labor colleagues, 1 ended up taking what seemed we the only realistic option. In January 20111 lef the Labor Party. With three other of our ministers in the government — who were. of course, aware of the ongoing Iran discussions I set up a new “centrist, Zionist” panty called Ha Atzmagt, or Independence. We remained in Bibi’s goverument. «ee My main focus was now on the Amecieans. In order 10 seeuce the “‘futeenational legitimacy” any sraeli attack required. we had to win at least their nndersianding that we might feel 1 necessary to wel. Foriumtely, © had built up a good relationship with the key figures in the Obama administration. That had vot always Deen easy, given the tension between the Americans and Bibi. That wasn't just Decause of the deadlock in the peace process, still a priority for President Obama. “Tere were other complications. ver since the initial pressure for a seitlement freeze, right-wing politicians and commentators. and Bibi himself, had taken to portraying President Obama as fundamentally unsympathetic to Israel. After the Republicans” victory in the mid-term Congressional chections m November 2010, Bibi went a step further. Tle began cozying up Wo congressmen and senators on the other side of the aisle. This overt meddling in the internal politics of our closest ally was not Just a breach of longstanding tradition, but of common sense. Members of the Administation began privately calling Bibi “the Republican senator from Rechavia™ - a reference to the Jernsalem neighborhood where the Prime Minister's residence was located, 420 {BARAK [135 Yel especially with ny main points of contact in the administeation — first Bob Gates and then his successor, Leon Panetta, as Secretary of Defense our broadly shured views, mutual respect, and the strength of the US-Israeli ulliance awwerghed any of thal. Nather tiey, nor indeed President Obama, wavered from their commitment to the principk that Iscael needed to retain our “qualitative ‘military advantage” over any combination of threats we might face, nor to the $3 billion package of annual US aid that underpinned it. We were even able to agree on additional US backing for ouc increasingly effective range of anti-missile systems: the Arrow. against long-range ballistic missiles, developed in coordination with the LIS defense contractor Raytheon; “David’s Sling,” to target enemy forces” mid-range missiles, cruise missiles and airera(l; and our new Jron Dome system. integrating sophisticated Tscaeli radar and guidance technology and designed to deal with the missile threat from Hizbollah on our northern border and Hamas iu Gav. [had not vel been used in battle. But from test firings, we were confident it could destroy incoming rockets with nearly 90-per-cent success By late 2011, cae issue of Iran had taken on much greater urgency. There was will no sign the Americin-led diplomatic elTorts were succeeding in removing the ouelear throat. As foc an American military strike, though the President intermitently declared that “all options” remained on the table. I knew from senior administration members that it was exiremely mlikely to bippen. Iran, meanwhile, had been acquiring thousands more centrifuges, more ueanium, and heavier protection around its key sites. And the “window of vulnerability” was now only about a year away. Operationally and politically, al east now # majority of the key players in Israel agreed that we had 10 be prepared 1 take military action if there was no alternative way to rein in the Iranians. Ashkenazi's successor as chief-of-staff, Benny Gantz, usd signed of on the attack plan. While the mins were getting ever closer 10 auelear-weapons capability, the strike force thal we were assembling was also ‘berrer equipped. trained and prepared to mount a complex. yet almost certainly successful, operation. The damage To Ina’ nuclear ambitions would be considerably less than if we had aeted caclicr. But our jtelligence analysts still estimated we could set back the Iranians” program by about two years. The immediate problem turned out to be timing. A major joint military exercise wilh the Americans, greed ou wo yews earlier, was due w fake place in 1srecl in April 2012. Tt would include Patriot missile batteries, naval vessels, and thousands 421 BARAK {136 of wiiformed US personnel. The focus was, of all things, on defense against & missile auack fiom Tran. T contacted Leon Panetta to see whether we could delay i The official reason cited by the Americans, when they agreed to do it, did have the merit of big Ine: that Bibi was coming imder pressire to stil our budgetary priorities away from defense lowaud social and economic issues. Bul Panctta understood that my request for a delay meant we were ac least considering miliary action. Le also realized that if we did launch en quack, it was in the Americans’ wa interest for theie troops he as far away (om Lsracl ag possible. We agreed to reschedule the exercise for October 2017, That meant that if we did decide fo attack, we'd have until well ino September, shen significant numbers of US troops would begin wiving. As we weighed our final decision. T held a series of high-level meetings in Washington: with Panetta, national security adviser Tom Danilon, Hillary Clintan, and President Obama bimsell. Though aut explicitly saying we were ready attack, Tle no doubt that we were seciously considering it. and explained the reasons we believed our country’s fundamental security interests might make ic necessary. The message (rom all of the Americans [met ws hal the administration shared our basic goal: wo prevent, or al least seriously impair. lran’s drive to get a nuclear boub. But they contited to believe that non-military pressure was the best way lo dol. Vie Americans knew we were skeptical thai the non-military soue would work, and that we were deeply worried about the implications of not taking military action if it failed. | discussed our thinkmg and, in general tems, our plans mn my mcetings with Panetta. He already had preity good idea of the broad contours of what we were contemplating. since US radar systems and electronic intercepts had been recording the volume and nature of ai force exercises we'd been camdueting over recent months. Leon and 1 had by now vol to know sich other well, baviog fist met when he was in charge of the CIA at the stadt of the Obama administration. In one of our early meetings at CLA headquarters in Langley, there iad heen a small bunch of grapes on his desk and | plucked a few in my mouth with obvious enjoyment. Now, at the Pentagon, he had a big bowlful ready whenever we met. The fact that he opposed an Israeli miliary operation made him no less of a pleasure to deal with, He was unfailingly calm and even tempered. He had an cneyelopedic grasp of issues of defense, intelligence, budgets and policy. Tle was always rock-solid in America’s commitments to Israel. It's worth. 422 {BARAK / 137 cemembering that. in spite of Tsracl’s insistence rom 1948 ouward that we would never ask others tv do our fighting for us, even as Leon and [ were meeting, US radar operatons were working around the clock fo provide us with early waming against ny incoming Iranian missiles. Patniol bufieries were ready lo deploy in Tstael within 72 hows of any attack. ALGIS naval vessels were withis 96 houss of our shores, to reinforce Istael's Arrow missile defense syscem with sea-launched weapons Panetta nade no score of the Get he didn’t want us to launch a military strike, effectively killing off the many months of intensive work the Americans had devoted to butldme international political and economic pressure an the Irunins, He urged me fo “think twice, three times,” before going down that road. Bul he recognized that Israel would be alfeeted far more deamatically by a nuclear lean. “It's your conflict. It's your neighborhood,” he said. At one paint, he asked me autright: “IC you do decide to attack the Iranian facilities. when will we koow?” T told hin we coulda’ give him move than a few hours” notice. Otherwise, the Americans would have to alert cheir bases in tae Gulf, and worldwide. That might well pul Irn on guard before our operation was lamnehed. But 1 did recogmize our cesponsibility not o leave the Americans in the dark. not only because they were a Key ally buc because their own military and naval personnel might be at risk from amy Lamia retaliation. “We know your commandos deployment and the communications protocols with your forces.” {told him. “We'll make sure you have enough time to tell your people.” I said. “We won't endanger a single American life, any of your positions or your personnel.” My most important uecting was with the President. | hongh | knew him less well than T did Panetta, we had met on & number of aceasions. The isst time was when he was still Senator Obama, on a visit to Israel during the 2008 presidential campaign. As Defense Minister, | escorted him lo Sderot, the town in southern Tscael bearing the brunt of Tamas cocket aliacks fiom Gaza. Back in Jerusalem, we spent a half-hour talking in my office: about Iran. [ argued that a unclear Iran was a ellenge not only for Enact and the Middle East, but for Ammeriea, 100. 1 urged him, if elected. to commission ao cacy study of what the Iranians were seeking to do and what could be done to stop them either by diplomatic means or, if necessary, by force. Also, what the [ranians could, or mare relevantly could sos, do in cesponse 10 an American or indeed an Israel attack, since our intelligence assessments suggested their options for recaliation would be fairly limited. Obama 423 IBARAKI suck me from tha first meeting as strong. cool-headed, highly intelligent and intensely cerebral. Though we didn’t go into the details of the Iranian auclear threat, he did tall at some length about the implications for the region. and about broader Middle kastem sceurily challenges. He displayed a grasp of the cultural aad political nuances of an increasingly diverse and comple world that was more impressive than many of the other American political or military leadess whom I'd met Whe he and | now retuned to the issue of tran, iu the White House, he had an undeniable command of the details of Iran's miclear program, and of the American military options, should he choose to use them, He opened by summarizmy the US position. He cnphissized thet his and our objective was the same: the keep Inn from developing a nuclear weapon. We were already coapecating to achieve that, for instance through cyber-attacks to slow down the nuclei program, The difference, he said, was that Isreeli leaders seemed to feel an urge need to reach a decision on military ction. Ta Obama's view, such a move would be both premature and potentially harmtul to the coalition he'd helped assemble to exert diplomatic und ceonomic pressure on fran. Maybe you had 10 be an Iszacli truly to understand our urgency about Iran. I the early years of the state, the explanation we gave for our preoccupation with seenrity our near-obsession, as some nun-[sriclis saw it was that we were surrounded by Arab countries pledged not just to defal us, but erase us from the map. Tigypt or Syria, Jordan or Iraq, could afford to lose an Arab-Tsraeli war. Israel"s first defeat, however, would be its last, That picture had changed dramatically over the decades. We no louger hud to worry son! the prospect of losing a war. The “qualitative edge” we possessed over all enemy amis in the repion ensured that. As Israel's chief of staff, Prime Minister, and now Defense Minister, | had made it i major priority lo safegiard that advantage, of just through our alliance with the US but with the remarkable domestic resources we possessed in military engineering, manufacturing. design, invention and high-tech. But the new-owder challenge represented by Tram wis not just theoretical or academic. Though we had a policy of not commenting on on our own nuclear status. it was widely assumed in the Arab world and internationally that Israel had. atthe very least, the capacity to manufacture nuclear weapons, But whatever auelear capability we might possess was for deterrence. Liven when threatened with conventional defeat, however briefly. in the Yom Kippur War of 1973, itis 424 {BARAK 139 worth noting that the conflict remained conventional. fran was different. Only the most naive observer would exclude the possibility that if the Iranians did pet 2 nuclear weapon, they might use it, And even if they didn’t, the entire strategic metre would change, wiih The need fo find a response nat just 10 @ nuclear hun, but potentially a nuclear Egypt, Saudi Arabia and Turkey. 1 was not about to lecture President Obama on this. While Bibi liked to portray Im vamously as weak, naive or fone-deaf to interests and sceurity of Israel, | knew: from our previous icelings thal hie was none of these things. Yel | did, in a deliberately non-didactic way, raise the issue of our different perspectives on the Irymians getting nuclear arms, “You see it m the context of the whole world,” 1 told the President. “If Iran, in spite of all our efforts, gets nuckear weapon, yes. il will be bad. But for you, it’s just one more nuclear state. Tt won't dramatically chunge the situation far America. For us, it can turn into u real, existential threat,” He srced tht we inevitably looked at the situstion differently. But afer pausing a few scevnds, he said: “Lihud, think of it this way. You get 10 school in the moming and there's this big, nasty bully. You can take him on. maybe give Tm black eye. But you have this bigeer, stronger friend, who ean knock him out cold. The valy problem is that your friend won't be there until the altermoon.” would have liked nothing more than to wait for our “bigger, stronger” friend, especially since | knew through my contacts in the American military and intelligence establishment how mich bigger and stronger an American intack would be. During the first couple of years that Israel was working on acquiring the capubility for a military strike, the Americans had been no mare ready than we were. They did have the tmker siren and the heavy bombs. Bul their plan — kind of [raq-style shock and awe — was so obviously prone to lead to a wider conflict that it would never have received the go-ahead trom President Obama, or robubly ny president. | used fo joke with collegues in the Pentagon that while Iscacl's idea of a “surgical operation” was he cquivakt of a sealpel, they seemed to favor a chisel and a ten-pound hammer, By the time | met the President in 2012, that had ehumged. Under Gates and then Panctia, an intensive rescarchemd- development effort and enormously improved planning and taining had yielded results. The Americans now liad high-precision heavy nitions we couldn't dream of, and stealth ar-attack capabilities we lso lacked, They bid an operational plan which, within a period of hours, could push the Iranian nuclear 425 {BARAK 140 program back by years. Aod even if the Tranians knew it was coming, they'd be able to do nothing to stop iL “Our problem, Mr, President,” I said, “is that we can’t be sure our friend will show up. Since fran is already very carly m a zone of immunity against an Isracli attack, we can’t afford to wail until the aflernoon. By then, with our capabilities, we won't even be able to give the bully a black eye.” [ said [ trusted what he'd just told me, “1m sure it genuinely reflects your intentions now. But there are no futures contracts in staiesmanship. There's no way thal you, or any leader, can commit yourself to what will happen in a year or two. When the moment of decision arrives, nothmg will be able to fee you from the respansibility to look af the situation us it is then, with American micrests m mind.” Ile aceepied the point. But he reiterated bis view that “kinctic action” — US security-speak tora military strike would not only remave his ability to exhaust the non-miilary alemanives. He sad it wonldn’t be in Israel's interests, either, “We hear that even people high up in your military, in military intelligence and the Mossad, are against it.” “That, [couldn't deny, “We highly respect our top people m the military, and in intelligence. We make a point of listening to them before Laking action,” T said. “But here's the difference. When they look up, they see Netanvahu, or me. When Ribi and 1 look np. we see heaven, Whoever is up there, we clearly can’t gro to them or advice. te ue responsible for Ismel’s seeurily.” ‘The president smiled, buc brought the discussion back down to earth. When he again urged us ta consider the American position in any decision, 1 replied: “Mr President, | feel compelled to tell you Graukly how | sce the situation. We highly appreciate. and are grateful, that America supports Tsrael in so many ways. T believe we're doing our best to support American interests in the Middle East as well, But when it comes to issues critical for fhe security and future of Israel, and ina way for the future of the Jewish people, we can’t afford to delegate responsibility even to our best friend and ally. When we face such situations, we have to decide on our own, and act on our decisions. | would expect the United States, and you as its president, to respect that position.” Tle did not seem especially happy with what I'd said. But he showed no anger. Though we differed, it ws clear that he understood and respected our position. In any case, [ believed it 426 BARAK 141 was important Lo convey to him honestly, face-to-face, where Iseacl stood on Tran. Orat least where [stood pose With our joint exercises pushed back until the fall, the logical time for us to attack was the summer of 2002, when the atmospheric and weather conditions were optimal. Operationally, everything was ready. Politically, those ministers who were against military action had not changed their minds. If anything. they seemed mare strongly opposed. Tronically, they now argued that becuse we'd waired so Tong, the Iranians were loa close Lo their “window of immunity.” Even some senior membecs of the militacy and security establishment, though in agreement over the technical aspects of the attack plan, retained political reservations. But as I'd tld President Obama, now that we had the operational support of the military and intelligence professionals, the decision in elect rested with Bibi and me. The fact we were ready to go ahead in those circumstances was ot unprecedented. When Menachem Begm ordered he bombing of Saddam Hussein’s neler reactor m 1981. he had acted against the advice of the thea-heads of both the Mossad and military intelligence, the chairman of our nuclear energy commission. and of Shimon Peres, wha was head of the Labor opposition. Bubs we neared our final, formal decision, we were forced into another delay. Tn the summer of 2012. an uarelated flare-up of tensions in the Gulf caused Tran and several of its neighbors to place their forees on heightened alert, Though the peakealnt plese passed quickly, (rans military was still not hack on fully normal Tooting by the start of September, and when small American advance teams began arriving for the joint exercises. Iran's alert level went up again. Technically, we could shill hive gone ahead wath the atack. In all probability, it wonld still have succeeded, selling back the Iranians” program by at least a year and, depending on how quickly they could rebuild and resupply clandestinely abroad. perhaps for significantly longer. But as more and nore American soldices and sailors arrived, | finally decided against an Israel strike — not because I doubted the damage it would do to Iran's nuclear efforts, but because of the dumige it would surely do to our fies with the 427 FRARAK F142 US. No mater how we might explain our atack, with the joint excreises soon begin, it would come over as a deliberate attempt to implicate vue must important ally in a potential conflict with lean, against the explicit wishes of President Obama. 1 Gel his even more strongly when, s few weeks er, was contucted by ane of Bibi’s close political allies. Te sounded me out on the possibility of Iaunching cur strike against Iran efter the joint exercise: barely two weeks before the 2012 US election. Politically, he argued, Obama would then feel compelled to support [sala action, or at the very least to refeain from erilicizing it. In other words, we would be setting a political trap for the President of the United States. I couldn't quite believe he was suggesting it. But my reply ta this last-gasp suggestion of & way for us lo attack the Iranian sited required no hesitation, and only two words: “No way.” Bibi would have known [would oppose such a ploy. But as with so much else in the years T spent in his government, T thik it was he polisics of the scheme, ore than the substance, thal enticed him. Almost everything be did seemed increasingly about creating a kind of grand narrative to secure his position on the right, solidifying i bse which he Fignred would sustiin him in office. Als core, the narsative presented a picture of vulneuability and victimhood: a kind of “fortress Istael” threatened by terror, missiles on its northern and southern borders, and now patcatial nuclear annihilation fom lan, white our main ally, the Unled States, was under the sway of a President who neither understood noe fandamentally supported us. In day-to-day policy terms. this allowed Bibi to insist we couldn't Fish serious enyeagement with the Palestinians. On domestic issues as well, like the widening gap between those al the top oF vur high-tech economy and a painfully squeezed middle class, the sense of crisis hie encouraged gave him license to hunker down, warn of impending: doom, and da virtually nothing. Effective though the narrative was for him politically. it bare no resemblance to ceality. Yes. President Obama disagreed with us on issues of policy. both the peace process and on how to deal with Iran. But he was unquestionably committed to America’s alliance with Israel. | had deh Gaee-to-Face with four US presidents: both of the Bushes, President Clinwa and sow Presideat Obama. In teens of Iscacli security. none had proved as consistently supportive and helpful as Obama. And yes, Israel did fice un array of security challenges. A nuclear-armed fran would undeniably make things worse. Bul far from being under existential threal, we 428 SHARAK/ 113 were a regional superpower, with a military as effective as any in the world, and a high-tech economic seelue justifiably compared wo Silicon Valley Every few weeks, Bibi, Lieberman and I would meet for a wide-ranging discussion on the patio of the Prime Minister's wsidence. Shortly afler we'd abandoned the idea of a military strike, | raised head-on my objections 10 the skewed image Bibi was promoting of our country. It wasn't just inaccurate, 1 said Fspeeinlly when his rhetoric was in full flight, und he compared the prospect of a nuclear fran 10 8 new “Holocaust,” if struck me as a betrayal of the core Level of Zionism: an stare in which Jews were in control of their own destiny. “We @e in that position naw,” [sand It was nonsensical to argue we were so threatened by everything wound us, for instance, thal we couldn't “isk” taking the mitiative cequired to disentangle ourselves from the Palestinians on the West Bank. “T don’t get you,” | said, fuming to Lieberman as well, “Your rheioric suiests you have spines of steel. But you behavior is living proof of the old saying that it’s easier to Lake Jews out of the gals, than take the galut out of the Jews.” Galt is Uebrew for the diaspora. “The whole Zionist project was based on the idea of taking our fate lo or awn hands, ane nctively irying 0 change the reahity around us. But yon beliave a8 if we never left the gall. You're mired in a mindset of pessimism, passivity and anxiety, which in terms of policy or action, leads to paralysis. Of course, there are risks in amy action, or any policy mbative, But in the sitaation where Israel finds sel, the biggest risk of all is being unable or unwilling 10 take risks. as if we somehow on the brink of destruction.” L was especially upset by Bibi's increasingly use of Holocaust imagery. “Just think of what you're saying,” 1 old him. “You're Prime Minister of the State of Tscael, nol a rabbi in a shied, or a speaker Urying to aise funds for Tseael abroad. Think of the implications. We're not in Furope in 1937. Or 1947. If itis a “Holocanst,” what's onr response: to fold np ind yo back 10 the disspora? (7 Iran 23a bomb, it'll be bad. Very bad Bu we'll still be bere. And we'll find a way of dealing with the new realiry.” Yet “fortress Israel” wars iresistibly comfortable for Babi pohucally. 1 now had 10 accept that, while he and [had known cach other for move than hal-a-century, nothing T could do or say was going to change that. With the next Israeli election months away, in January 2003, [confided to Kili, and then to my closest aides, that 1 was not going trun for a seat in the Knessel. Israeli military action agaist Iran 429 (BARAK [141 was off the ageoda. The diplomatic process with the Palestinians was stalemated. T could see no point in cemaining in the goverament. Like my last period in Olmert's government, my final few months were dominated by finding 1 way lo end Hamas attacks from Giza, During one 24-hour period in November, Lamas launched more than 100 rockets at towns in the south, while also attacking two military units across the border. Especially since our military response would be the fast during my time as Defense Minister, | was determined that, this ume, it would have a siricily defined objective and a finite time trame. The overall objective hadn't changed since Olmert's premiership: to hut Hanna hard, bring down the number of rocket attacks ta as near zero as possible, and reach wn agreement, through the Jayplians, which established a period of calm on our border for as long as we could. Bibi's “vietimhood™ narrative notwithstanding, one aspect of the military balance in the south was now dramatically different. With my backing as Defense Minister, we now had [ron Dome, which T was confident would help deal with the inevitable shower of [Tamas rockets that would follow our initial attack. Again, I felt ir was essential to scare with w quick, unexpected damaging fins strike. Ther, tongh snstuined sir bombardment, 10 keep up enough pressuce to scour the political arrangement we wanted. And. unlike under Olmert, to end the operation as soon as we'd achieved hs aim. On the aflernoon of November 14, we lannched a targeted air strike on Hamas's de facto chiel of siafl. Ahmed Jabari. We'd gone afler Jabari in the past but, for ang reason or anather, had failed. We alsa hit nearly two dozen other Hamas targets, melding all of the main missike sites we had identified. The whole operation lasted a week. TTamas fired nearly 1,500 rockets into Tsreel, not just locally manufactured Qassems but longer-range Iranian Fajr-5s and Russian Grads For the first time since the 1991 Gull war, several were tneted at Tel Aviv and Jerusalem. Fortunately, they were not signifieantly more accurate thao in the past. More than half landed in fields or orchards. And with Iron Dome deployed around aur major owas smd cities, moe han 80 per cent were infereepled. We hit nearly 1,500 targets over the seven-day period, mostly launch-pads, Tlamas government installations and weapons stores. but also a number of apartment complexes bem used by Hams ws bases or firing pomts, Bibi rightly pointed out that we were forced to fight & fandameutally symmetric battle. While Tscael began with the principle of directing ou fire @way from civilian areas, 430 {BARAK [115 Tlamas based its launchers in precisely those places. So it was not casy. AL one point, we announced a call-up of reserves. We hinted at a possible ground incursion, But both Bibi and [ knew we were gong to avoid that if at all possible, and we did. Though there wae inevitable civilio casualties, most of the Palestinians hilled were [lamas fighters and leaders, including not just Jabari but the head of [Tamas’s racket program. By limiting ourselves to air strikes and naval fire, the Palestinian death toll was around (50, about one-tenth of what it had been in 2008. Six Lyraclis, including four civilians, lost their lives. On the 217 of November, the cease-fire was announced. Yet with the election approaching, and my time in public life drawing to a close, 1 had na illusion th this laiest military operation, or futwe ones, would bring us eloser to the negotiating peace with the Palestinians that had eluded us since Oslo, Nor was | confident that, havi been unible ta mount a military strike oF our ow on Iran, Obama’s “bigger, stronger kid” in the schoolyard would take military action. T did trust him to do all he could 10 use diplomacy Lo constrain Iran's efforts to get a bomb. I feared he might tail ven if he succeeded. I figured the best case would be un sgreeraent thal, st least on paper, deliyed the Inmins™ development of a weapon. My hope remained that Iscael's relationship with the Americans would be sufficiently strong for us to reach a formal understanding of whist form of surgical mihtary strike cach of aur countries might tke 1F Ino didn’t honor the terms of a negotiated deal. When I ficst left political life after my election defeat in 2001, I'd described my status ws the equivalent of a reserve officer, 1 said, and believed, it was unlikely I'd elu for the foresecable future. But [knew it wasn’t impossible. his lime was diffesent. When T announced publicly that 1 was leaving politics, five days aller the Gaza cease-fire. I painted that I had spenc the sreater part of my lite as a soldier 1d never bid i bring desire 10 be a politiciun. Though [believed tha what I'd attempted, and achieved, in government would prove to have safeguarded and suwrengthened Israel, 1 knew that important challenges and decisions still lay ahead. So did our unfulfilled decion of being a country thal was not jist strong, sceure and prosperous, but socially just and at peace. Yel I believed it was right to draw my time on the front line of politics to an end. Though I didn’t say so. I thought to ‘myself: this time doesn’t feel like u step back into the reserves, but genuinely like the end of something. Though my dedication to a sceure, sttong. just, democratic and ultimately peaceful Israel would not change, whatever contribution T might 431 BARAK 16 ake 10 our getting there would no longer be on the baulefield, in the kira or around the cabinet table Asa number of reporters pointed out. when [ made the announcement 1 was relased, 1 looked content, und | was smiling. 432 From: Larence kau: [EE sent A7E12013 063 0 bet he Importance: tie Let's do a men or the world contre Hill Clinton Woods Allen Lawrence M. Krauss Director, The Origins Project al AST School of karth & Space Explorarion and Physics Deparment Ariza Sine Lnivarsing pO bos N ~ oo i eriginsasw.cdy | (vitter.conylkeauss! | kesuss.facultr.asu.cdu Sent from my iPhone On Apr 5. 2018, ut 2:04 PM, Lawrence Kraus I Tojo Lawrence M. Krauss Director, The Origins Project at ASU Foundation Professor Arizona State Univsrsiy, 2.0. Box 871404, Teunpe, AZ S525 7-1404 ZINES (WWIECOmITCFAUSST | KEAUSS Ey. 4s0.can On Ape 5, 2018, at 1:41 PM. jetfiey b. <jecvacationgemail con wrove: L— Fre Tis Brn 1h armen ec Wor Sara en AP Fans an Ap win ros ost sro rank He dee brs sir Poe aoe ole merry Conn seve snows her [ETop— Alb Nese preven pris cdrasi en ager prey hc ous inka yc Furman: Bus Alki Comoe Vong Come fst Fi Lacy Chine Moti Che Gute: Fist Leh Conti Mofokisa Dias Don rope Ua Kansan Demian Dulce cas Dm obama Pee Temabaes Beds Keacody: rien Tetranio ©: Feza abi Glia fd os fee: Hila lu, Thay lari Tne Rede Toe frog oom Rare Totncd Joy Towne Bd prin Inmate. Kei Cone Keay Tut Kin tirkel Same Kaa GE Trot Le. bed Var Fenar Lak Busca frostrinas ees Lisi Suse Sioa akin Naeem Nargaet Arwoed Koukes Sao Rak Arn Kaen Tic mim Kone sc Kili Aci Riehl mgs Davis Nill midi Kin Coins: Neo Walls rT Noh Dorel acai Evia fir Por Ply ed Rokats Hen oa, Foran forse Ren Td Sold Bouse Say Vu Son dawn Sho Nevis Sep: Grogs Trade Stole Moe Sune Ki sh: 7. Siaeme Bra Toons Ceol fens Creme Topas Sars ith Dis Yossi Alot Zann Siw Tina Brown | Founder and C0 Tina Eicun Lvo Modiademor in tho ard please note: “The information contained ia this comanmnicatioe is confidential, may bs attorney-client peivileesd, may constitute inside information, and is intend only for the use of the sekdressee. T i the property af jad Unauthorized use, disclosuns or copying of this communication or any part thereof is swictly prohibited and may be unlawful. If you have roccivod this communication in emor, please notify us immediutely hy return e-rmmil or by e-mail to jeevcation@ymil com, und destroy this comamication and all copies thercof, inctudiog all amachments. sopyrigh -all rights resceved From: Nichol itis I sen 5712015632270 To + esuscaton Sqm com] bet ne Importance: High ore bid news for aur Trend From: | maihaevacation @gmai. core] Sent: Tuesday, May 07, 2019 12:29 AM To: nichatas ibis J Subject: ipa nytimes.cami201 940506 splits rump-imngsstion-stephiniesinston= wolknlhimiZuction click &modale Topti20Slories&petype Tamepuge plosse note The information cantsined in this communication i conlidential, may he utlomes-client privileged, muy constitute inside information, and is intended anly for the use of the addressee. It is the property of JE Tnauthoried use. disclosure or copying of this communication ar any part thereof is srialy probibited and may be ualawtl. Jf you have ceived this communication in error, please notify us imaediately by return e-mail or by e-mail to jeevacution i gmail.com, sod dearoy this communication and sll copics thera. including ull aachments, copyright -all rights reserved [BB TIE CIRCUIT COURT OF Thi cLEVENTH JUDICIAL CIRCUIE N AND FOR MAMI CATE COUNTY, FLORIO. C3 m1 COUNTY COURT 00 Fo Mk S08 COUNTY, Fon Be CAL ACTION SUMMONS bin Seor (00 Form so Pmt Semis on Weta Parvo pt [SEH Ero [ —— Ee ne mL werner, | a. men cous RR TERE COT AGH SHORTY FST, YoU ANE COO 7B Sr 0 4 fe FE TE y= e ree aTe Fe LT Rag i = mt or 110 10 10 cd he ces ari 1 + rs ssf or er a em = ny et, yo sp. 7 EE £0) Pet en i Ae ar Ca fon a sh, 1 ey Ss et Le pe ed hk Carty mac Tot mien fo 0 cope, eh oer wes slo rv coer | | [opm — Bauomommm Dpscmcmon a T— prt pt mt cm Olga som om com ay 00 pn mame coe [=— pry To GE Tome 215.25 37H STREET, FONTAN BEACH, FL 2080. in a 82 y . —— iA BANCHFY Sarr er I... RY Yi AMFRICANS WITH DISABILITIES ACT OF 1950 EE ADA NOTICE, “If you are a Brom vith a disability who needs any accommodation in order to parbiciin in (Lis proceediag, vou are ended, at na cos to you, to the proviekn of certain assistance. Plea conacl the Eleventh Judicipl Circuit CourCs ADA Coordi ator, | Lawson E. Thomas Courthouse Center, 175 NW 1" Avc,, Suite 2702, Miami, FL 3312¥, Teluyhone (31) 140.7175: TID (305) HOT174, Fax (3057 349-355 ul leat 7 hor ford your seieduled Ewart appearance, or immediaiely upoy receiving this noiiffeation ff the | ime before (he scheduled appearance Is Jess than 7 days: if you are Bearing or [volee | impaired, call 7117 pee J——— rm ER CORTE BE GRGUTD 02, UNA GHEY GIT DISA EY PARA FLEA 0 02 NAW UAE AFL ENEL THEA EL CHDADD EY Ak EL CONDADO HAM M06, CAFLONI i bikie EMPLAZAMIENTO DE ACCION CIVIL MMERO DE CASO fom 15) NOTIFCACION PERSOUAL A PERSONA NATURAL | 1 om H DEMANGANTE(S) VS. DEMANDADG(H) Ta Le pg— PS S— [RBenmiast Torin —— ES les dmtet pees e 2 cts tc oe loi, i cr rss, St ee Se By, ts 08 15 ee op Fe Se nts a ee eS mee y mkt, SF en Sn Tn Sept Cn me Le Sk Sm 4 gs rs as | ne hc do snc out Lag 4 Cen © snes dane emg $minoy Radel wn) ue 3 - | Ee | nl ct 0 pe roo 1 TU Aa a Ent SH Sear) er ci 5 Sr Ses 8 Lh rd eb 3 oe an Car 0 os Dos cr 8 Cr Go EA met i St fn LCA UE 108 TAPAS Co. C00 [Ee NS [I Tr 0g ora cu me i © an cin out Coe 5 EE anda i rrr e— Beinn i= Nr 4 Cogn de cgi |” ELEGTADD OF LATLORIA A cal vt oo Erma 5 cia ao igen ios i us coin y of | tc rt ees Sry Foot HARVEY RUVIN OA Suonuipel Tbansia POR i YS, I Ley paru Entadounitlenses con Incapacidades “Si usted ex una persona minusvillda que necesita hacer arreglos para der partjcipar Pion torligd sig gr db bog ats eum 3 WISE pass puder po ta. For Tavir pindime "en’caniacto coh ef Cooréimador’ de ADA ol Once Tifirito Judicial ubicado en cl Lawson E. Thomas Courthouse Center, 175 NW Ist Ave] Sala 2742, Miumi FI 33128, Teléfonos (305)349-7175; TDD (305) 349-7174, Fax Hinde 7355 or a menos 7 dias antes de Ja cita fijada para su compareceucia’ en Jos (ribunsfes; [imediotamente deapuie. de. Tocioms etn ‘oihomiin oer. Hone seer 3 Ih Sompareceica que se ha propramario es menos de 7 dias; 1 ited Gene discapacifuen del 0ido 0 dc ka vir lame a1 111. A BNL BSH AHS EVENT USCA, DON FOUN D3. we HLF JOGEUCNT CT POOR WATERY sed Are LORE avin ; Bp Corr ie rn SE we i © am | } fe? iad TTS i AG ACCUSRT | aviEame 2 ml fi pe i tt i Yi he Si or ose i om me oo ee Bein Scr, esis ‘same = ot on fs | urs 5 4 vou, 5013 G8 0 Vol SNe Yio CC. SI ach 2 Cops goes mre. pes nite GUTS Jo ed Tou] i re pp ada tk ies fr as oem en em Yop he em ltl me ee ot van gr cir car wa: a rcp, more mbm pao rn ome po ST 2 El TR A Ee ee | pu— Cipro Bggeet Oggi sn Hem LLL Bra. Sho. Upmann Dg ommioust © ga mann Plaimaibvocat du Plante Hiliepry TTRTOE UA FIORE A shoe fo vo Gn Tl 8 nr Gr a 2 DL ro ever won ore Fv | er — = ACT DE 1990 POUR AMERICA INS HANDICAPES AVIS DE ADA “S] voux ies une personue handicapée qui a besoin d’accommodement pour puvoir parliciper i cette procédure, vous aves le droit, sans aucun cofit, d’avoir de "aide af votre disposition. S'Il yous plaft contacter le Coordinater de PADA du Tribunal de I me Cireuit Judicisire, Lawson E. Thomas Courtbomse Center, 175 NW 1" Ave. Suite/2702, Miumi, FL. 33128, Téléphone (305) 349-7175; TDD (305) 349-7174, Fax (35) 349-7355 an moins 7 jours avant la date de comparution au tribunal, enbien jmmédiatement japres. Voir resh it avi i Iu date avast Ia Comparution cs mains de 7 jours; § vous 4viz ne incapucité pour enteadre on parier, spelt le 711.” 5 AN TRIBUNAL ONE YF RRONDIGHAN IS YE NAF POU AWE DRO COURITY, FLORA. CHV THBNAL 10 TO KALNAN MARL GADE COUNTY, Fain L Eid 1 KONVOKASYON POU KA SMIL EL ous (0) BIELIVSE FERSONELMAN BAY YON HOW ior PLENTIF) VE. KONT AXizE(S) KEE: ® ADRES: " = io 0 eon shay rnd cum. Ou ge 2 04 ros 7 ou cv Esta sn vege dora i Pp pp fe EL aah Rd] ee mam Loa tsar Tats pe sige wn. Cora ou ev ev rs sete So i ens ely oy hi yore. yun eprom, et i pata rh Bi ts np heres Bp Pa ne spree Wr iat Til Adres ark ha Sete 45 Co68 Go Cova, AF 4. mk orc lyse pias petites ADRES TREAAL NAN BADE COUNTY Upc tarnms Oprmcrime 2 gps smmicon zaman Upmmasmionot Cpunamtminin Um amr Priced i Phi TO LT Numero do barge go 3 © onde: mi rE — ETI bo hk ra cn 2 vey i TS TS, rh SET —— Sohrvie donarat Tribmaria | BY re | ] LWA 1996 POU AMERIKEN KI ENFIM i ANONS POU AMERIKEN KI ENFIM 253 ou se yon moa ki anf ¢ ou bean skomodaiyon pon au paispe nm posed) a ou gen dwa me ba ou kék d san ou pa gen pou ou peye. Sitvoupl: kodtakie Kowddinati A pou Tribinyl Onzydm Distrik Judisyé a nan: Lawson E. THomas Courthouse Center, 175 NW 1 Ave, Suite 2702, Miami, FI 33135, Telefon (305) 340. | J175; TDD (305) 345-7174, Fax (305) 349-7355 omwen 7 jou anvan on gen randevo pou ou bucét wan tribunal la, oubyen imcrivatman 1 ou resevwy otifikasyan sa a 8 of en | Pens ke 7J2W Pou ou pardt nan tribuual bn; si ou geu difikilte pon ou tang o ibyen | Late role 711.7 ! De 1 Filing # 22956396 E-Filed 01/26/2015 12:26:55 PM INTHE ELEVENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR DADE COUNTY, FLORIDA CIVIL DIVISION JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC Civil Action No.2 1421348 CAL Plainills, JETEREY EPSTEM, TYLER MCDONALD, TYLER MCDONALD DR/AT Y1.0RG Defendanis. DAMAGES COME NOW the Plaintiffs. Jean-Luc Brunel ond MC2 Model & Telent Miami. 14.C, by and chraugh undersigned counsel, and suis Defendancs Jeffrey Epstein, Tyler Mefonald. and Tyler McDonald d'bla/ ¥3.0rg for legal cell, equitable relief and defamation, and states as follows: 1. Venue is propec in Dade County. Florida as Defendauss Tyler McDonald aid Tyler MeDoneld dbs Yi.Org da business in Dude County, Plintiff Jean-Luc Brunel resides in Dade County. Florida, and PlaintilT MC2 Model & Tales Miami, LLC. las an office in Dade County. The causes of action and dimazes ngainst Dzfendunt Jeffrey Epstein soared in Dade County. Florida. due to specific acts by Epstein there, and accordingly, venue is appropriate there. Florida Statute 7.011, 2 Florida State 48.1930 Ka)( 1} foug-ann™) authorizes service oo both out-of-state Thefendanis (Tykes MeDonald, snd Tyler MeDrnald dibad Yi.Ong 1 3. Jurisdiction is proper in he Cicuis Court as tis action soaks rlicf in excess of fifteen thowsand dollars (15.000). FACTUAL ALLEGATIONS AS TO} DEFENDANT JEFEREY EPSTEIN 4. Dloiadiff Jean-Luc Brunch isthe ewnee of Plaintiff modeling agency known as “MC2 Model & Talent Miami” (“MC27). MC2 hegan operations in October 2005 and hs offices in New York. Mian. sad ‘el Aviv. 5. Defendant Jeffiey Epecin (“Epstein”) is a hedge-fund manager with a residence in Palm Beach County, Floida. Defendant has bees the subject of significant media coverage dus to charges brought ugninst him insalving sexual camact with minors. (Composite Fxhihit A atsached) 6 Plain Brunel sad Epstein have known one another since the inception of Plaintiff mez. 7. Plaintiff Buunel operated his modeling agency. Ploi(ff MC2, without incident until Fpstzin was Tis charged in Palm Beach County with unlawful sexu) conlact with a minor in 2006. He was convicted of soliciting prostisution from a wiinor and sentenced to cightcca moths in prison. of hich he served thirteen months. Te remeins registeced sex affender in Florida us of this das. 8 First after the initial ceimind] charges against Gpstein were filed in Palm Beach County. Plaintiffs were widely implicated in che media as being “linked wo Epstein. These false stories caused both PRntifs 4 tremendous 1055 4T business. 9. Plaintiffs Jose multiple contacts and busincss in fhe modeling business as a dircet result of Epsicin's legal autions. Tor example, sevecal photagaphess will aol work with MC2 due to the adverse publicity surrouniing Fpsiein an Wis ileal activities. und the publicity fulsely linking PlainifTs with thuse saivities; namely, sex rafficking. (Composite Exhibit A). 10. One example of such a photographer was Michael Avedon, who worked wits MC2 en phot shoots. Avedon stopped answering Plaintiff emails and phone calls aftr having known Plaintiff for some time. Upom aneeting Avedon out one aight. Avedon stated to PRintifl Brune! he had “found out some information” fom same friends of his and tht he could not associate his name with MC2. 11. This statement by Avedon was mo doubt a reference ia the wlleged and fuse links berwieen Plaintiffs and Epstein’s ilicgal activities with under-aged gies. “This incident cleaely illustroces an example of lost business on Plaintifs’ behalf 12. The second example of s business relasionship tat was terminated due 10 Epsiein’s invencional and iflegal activiies was a very recent oni. involving an overseas agency. Modilines Male] Agency. The owner stated that the model be placed with MC? “found some ancl in intemnce, which changed her posiian and she pesferred (0 be placed with ancther agency.” This was relayed tu Plaintil Brunel by email dated October 15,2014. This amply demonstrates that Epstein’ intentional 4 sal activiios continwe to cost PlaindTs” business income. (Exhibit attached). 13. Athied example of a loss business rslationship can bs found in an e-mail dated October 17,2014 (Exhibit C attocised). The disector of the | Mather Agency. Vidor Yulushkin, sates that specifi model will mot sign with Plaintiff MC2 due fn her fear that Plaintiffs” will force ering illegal activitics. The model bases her fears upon the siories on the internet falsely implicacing Plaintiffs as being involved wich illegal activities wirh young models. This is 3 noche example of a false link becween Epstein and Plaintiff, costing Plains” business income. 1. A founh example of a los business relarionship can be found in a sesand s-mil dated October 17. 2014 (Exhibit D attached). Manuela Martinez of Mega Partiess. a Brazilien modeling agency, statcs to Plaintiff Brunel that her agency has been unable to work with Plaintiff M2 fore the pst five Lo sis years because of the sex talTicking allegations against Plants. This rerenes is clearly fo the false allegations online regarding sex trfTicking thal were bused nthe false link berween Epsteic and Plaintiffs 15. A fifth example of a lost business relationship can be found in an e-mail dated i Phaindi's behalf was an &anail dated August 27, 3010 from Michelle Stockman of Agence Frunce Presse. (Fxhibit F uuched). Agence Prince Presse is & newswire service with a world wide reach. Stoeknian wanted to meet with Plaintiff Bron! to arrange a model shoot with MC2. However, due 1 the adverse publicity suerounding Plaintiffs a5 a result of Epsteie’s illegal accivitics, Plaimiff Brunel was forced to foreya (and lose) this business appartunity becuse he needed to keep a low-profile a this time. 16. A sixth example of lost business dus to Bpstein’s intentional and illegal activites can be found in an e-mail dated December 12. 2014, (Exhivit ¥ anached). Michac) Sanks, a takat sent wha had sworked with Phaictills for » ruraber of years, iforeed PlaintiT Brune) that he cannot sign any new medals for Plaintiff Brunel's MC2 agency due fo the false sex trafficking allegations online. Sunk goes on la state thal Plaintlf Bruoel’s MC2 agenwy will not allt any ew models if Plaiatiff Brune) dees not clear up the false allegations. 17. A seventh example of los business due to Bpstein’s intentional and illegal activities can te found in an cna from Fax Fashion Agency (Exhibie G anached). This c-mall clearly states : that Fax has placed models with Plaintiff MG? in the pst with shealutely no problems. However, because of the falsa internet trafficking links between Plaintifi's snd Epsiein. Fo sites that it cannot place anymore models with PhaintifT MC2 until the allegations tee cleared up. 18. Before the false links between Plaintittand Epstein surfaced. Plaintiff Brunel was corning s great deal of revepus fom C2 Miami. 19. The fase links beeween Plaines and Epsesin began 0 surface online in about 2005. 2006. Then, in 2006, PluintiTs received a Jeter of ecedit from Epstein at 5% interest. Plaintifls then made an investment otaling one-million dollars with Flite Paris, tn sturt 4 company. 20. Next, PloiniT Brunel started the company. “E Maragerncor™, fa work with Elite Models in Paris. Plaintiff had 10 close it almost immediately. because Elite didn’t send any models to PlintiTMC? for eas of being linked to Epscein. 21. Beene the ule links between Plains und Epstein began to gain suength online. Ellie Paris severed the agreement dh entirely o these false Finks. Plaintiff Beunel lust his investment of ane.million dollars because of tis Joss of business. 22. Plaintifs lost pocemially fen-millian dollars in profits due Lo this initial sme-millivn dollar Toss. 23. Addiomally, a former financial controller of MC2, Meritza Vasquez, sated in a 2012 depesition thal PlaiotIT Brunel bad never done angwhing inappropriate or illegal with any under- age model. (Exhibits H1 & H2 Transcripl of Depasition of Maritza Vasquer). 26. Maritza Vasquez was fired from her job ac Plaintiff MC? for embezzling campany fonds. aod had criminal charges filed against her (Composite Cxhibil 1 attached). She vias also the source of the alse information Linking Plaintifls 10 sex teafficking in the articles writien by Conchita Samo of the website Jezehel (Composite Fxhihit A. 72-7). F 25. Ui deposition tstimany of Maritza Vasquez referted to above clearly dmonsirees that Plaintiff Brunel bes clean hands and was nevec involved in sex trafficking. All of Plaiotfls’ damages came solely from Fpausin's conduct. 26. Additionally. Plaintiff Beuncl has had significant delays in obtaining his vist to come to the U.S. These delays were ata the resull of the fabs link hetween Plaintiffs and Cpsiein. As a tesult of these dofays, Plaintiffs lost a considerable amount of xime & money. Intemational vel isu significant component of PloindiT Brunel's MC? modeliog business. Plainti) Brunel as been forced to cancel his latest visa spplicasion as a result of the delays. (Exhibit J — Composite - Visa Doss). 23. Asaresult of the notoriety and sremendous publivicy surrounding psiein's criminal charges. and the media linkage of Epstein to Plaindits regarding illegal activities, Plain lost a tremendous amount of business and revenus, 28. Plaintiff Brunel’ agency MC2 has lox: millions of dollars in revenue since the media vevedled that Pluietin and Epstein were associated. In fut, Plaintiff MC2 was worth millions ut dollars; now, duc to the illegal actions of Epstein, MC2 is almost worthless. 20. Aun lime did Fpstein ever publicty state Uiat Plaintifs hid no rule whatsoevec in the Epsicin’s illegal activities. 30. Asa result of Gpstela's illegal acdivities and his association with Plaintiffs, Plaintiffs continue 10 105 money and suffer damages to this day. (Lichibit K. wsached. Jeff Fuller email, 1-12-14), 31. Plaintiff Brunel will need to spend millions of dollars in ander en restore his wines fo shat it 53s once worth - money thal the Plain(ll Deus] does not have. 6 32. Plaindff Brun continues 0 own and operate Plaintiff MC2 3 this day, their names mover having been cleared trom the massive and totally negative medio coverage imalving Epstein ants his illegal activities. PlaintiTs have been, und continue ta be, imparably harmed by these fal invcrncrebased links to Epstein. (Exhibits R é 5 attached). 23. Second. Pluintft Brunel was also ld by Epstein to leave the Palm Beach rea in amicipation of a deposition of Plaintiff Brunel in a criminal case against Epstein. On the direct advice of Epstein, Plaintiff Brunel went 10 Gurope and Asia for period of time. This wos done for the sole purpose of delaying Plsintiff Brunel's deposition. 34, Asa direct result of Plainifl Brunel's travels. bis deposition vas delayed twice. When it as finally scheduled fir November 2009, Plainiff Brsncl was in fact svailatle (Exhibit i. arched). However, a medical emergency in the family of his anotncy fuahce delayed iis depusiion (Exhibit M attached). [1 was never rescheduled und he was never deposed. 35. This was » blatan example of abstruction of justice inthe criminal sase, Epstein was solely responsible for telling Plaintiff Brunel to leave the acea. Plaintiff Brunel lost & huge opportunity to clear his mame, and that of his agency, Plaintiff MCZ. 36. Third, os a cesult of all of the Facts stated above, Plainkill Brunel was under tremendius psyshulagical pressun: throughout his period oF ime. 37. This psychological pressure tesulted in Plaintift Brunel avoiding business contacts as set forth above. Tis pressure also directly caused Plain Brunel to avoid certain socio) contacts during this pericd of time. 38, PIainsifF Bruncl became extremely withdrawn and anxious at is tie. 39. Epstein’s contut was the direct cause of PlaintIT Bruncl’s psyuhilegical state. The press was reparcing extensively on the Turd details of Epsiein’s illegal activities with the under aged giels 7 0. As stated above, the press ceports were roneusly connecting bith Plain Epstein's iflegsd setvilies. (Cempusice Exhibit A attached). a1. Epscin's illegal activities were outrageous and extreme: they invelved eeceiving massages from the under-aged girls while the girls were nude or nearly-nude; penetration of the girts with a finger or object; o full-intercoucse. 4. These activities described shove cused PlainglF Brunel severe emotion disaress. Tn fact, PlaiatifF Brunel has recently undergone psychotherapy with a local psychologist, De. Ruyee N. Jalisco, us cesult of Epstein’ actions and the negative resus om his business. (Fxhibics N & © tached). 43. Claincitt Brunel Is emotionally destroyed as @ result of Epstein’s actions ond the resultant ffsts on his business. He has been on medications to deal with the effecss of this. (Composite Exhibit ? - Medical History). M4. PluintifTs have been damaged hy the conduct of Defindant Epscin, und have sceordingly etsined undersigned coumsel ta represen him in this niatrer and are obligated to pay counsel a ceasoutble Jee for his secvices. EACIUAL ALLEGATIONS AS TO DEFENDANTS TYLER MCDONALD & TYLER MCDONALD D/B/A YLORG 45. Defendant Tylee McDonald (“McDonald") is the ownerfoperator of Y1.0rg and also docs business as Y1.0rg ~ Defendant [yler McDonald diva Yi.org ("McDonald d/bfa Yi.0re') Defeiduit McDonald resides in the state of Washington. ¥i Ore in x website hosting service hased in Vanemver, British Columbia, Canada. 46. In aboul 2009. Yi org. by and through the actions of its owner, Molonald, began hosting websites tha contained hyperlinks that contained blatant false and exueniely dispacaion information about PlaintifT. (Exhibit Q stathed - hyperlink screenshot) 3 4%. These links elendy and falsely associated Plaintiffs with illicit escort services in the sue of Florida: information which Defendants MeTanald and McDanald dia Yi. Org knew, or should hav known, was false. 4B. These links have damged PlainGif Branels reputation a5 an owner of a well-established ‘modeling ageney with affices in New York and Mian, Plaintiff MC2 49. These links have also damaged the reputation of both Plaintiffs 50. the combined damage to the reputation ta both Plaintits has tssulled in a significent boss of revenue Co Plenty MC2, ond accordingly, Plaintiff Brunel. SI. PluinsTMO2's revenues have fallen fo 4 mere fraction of what hey were before the appearance of the links on Y1.0re. 52. Doth Defendants McDonald dv Vi.Org and Mebonald assist! in the dissemination of the false and negate information that damaged Phintitls reputation and directly caused daonages to Plaintists 53. Plains Grune continues to own and operate Plaintiff MC2 to Unis day, both aames sil Raced by the flse and negative association with escort secvices in Florida $4. Acconlingly. Plaindifl have heen severely damaged by information on websites hosted by Vi.Org, which ls mvintained. owned and operated by Defecdams McDunald dfbia Yi Org and McDonald, 55. “Ihe informacion disssminated by the websites hosted by Defendants MeDanuld dia Vi. Or: and McDonald was false and defamatory to the extreme regarding Plaintist alleged involvement with cscort sevices in the state of larida. 56. Defendants McDunuld dbia Yi.Org and VicDonald have made no attempt to clear the names of Plaintiffs with regard to the false and defamatory information disseminated by the 9 websites they hosted, 57. Plaintlfs contimie to do business 10 his das their names never having been cleared from the negaive information disseminated by Defendants MeDonald diva Yi Org and McDonald. 58. Plaiadifs have beea damaged by the vonduct ot Defendants McDonald hia Yi. Org and MacDonald, und have accordingly retained undersigned counsel to represent him in this mater, aud arc obligated to pay counsel a reasonable fee for his services. COUNT I EQUITABLE RELIEF FOR | 08S OF BUSINESS AND REVENUE - ASTO DEFENDANT JEFFREY EPSTEIN 59. The allegations conained in paragraphs | through 44 above are re-alleged ond incurporated herein by ceference 60. Plaintiffs have lost n significant amount ot business reveaus because of the actions of Defendant Epstein set forth shove. G1. Plaindiffs fave no adequate legal remedy to make him shale 55 a cosh of ths damages sulfiered in the form of ost business revenue due Lo the actions uf Defendunt Epstein, 6. Accordingly. Plaintii seeks to become whole by the payment of damages by Defendant Epstein to compensate him foc his losses, WHEREFORE. PLAINTIFFS roguest judgment against DEFENDANT as follows. A. Damages in excess of fifteen-(housand dollacs: cial by jury ad B. Geant ther such relief as is spproprisie COUNT IL OBSTRUCTION OF JUSTICE — EQUITY - AS TO DEFENDANT JEFFREY EPSTEIN 63. fhe allegations contained in paragraphs 1 through #1 above ore e-alleged and incorporated herein by cefecence. 0 64. Plaintiff was forced to commit illegal aces by traveling away from the sight of the deposition and during the Gms period of the deposition. 65. Defondant Epsicin stempled to subvert juscice and this atten contribuced to the destruction of Plainsif's business, PIintiff MC2. Plaiodief Buunel lost subsisuinl ime away from his business and incurred expenses in following Fpsiein's commands, G6. Plaimiffs were substantially damaged a3 a Gircot sult of Epstein’s actions. WHEREFORE, PLAINTIFFS request judgment against DEFENDANT as follows: A. Damages in excess of fifcen-thousand dollars; ial by jury and B. Grand cther such relief as is appropiate. COUNT II = INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS UPON "ELAINTIEE BRUNEL - AS TG DEFENDANT JEFFREY EPSTEIN 672. ‘The allsgations contained in paragraphs | though 4 sbuve wee re-alleged und incorporated herein by reference. 08. Defendais Epstein cocklossly inflicted emotional distress upon PlaindT Brunel by engaging in illegal candiset with under-sgged gicls, which ws falsely linked 10 Plaintiffs, 69. This illegal conduct was extrerse and outrageous by any standard. 70. This exiceme and outrageous conduct was the direct cause of extreme emotional distress in Plaindiff Brunel, WHEREFORE, PLAINTIFF BRUNEL eoyuests judgment ugaiost DEFENDANT us follows: A. Domages in excess of fificen-thousnd dollars; tial by jury and B. Grout ther such celie is is appropeistc u COUNT IV - EQUITABLE RELIEF FOR LOSS (IF BUSINESS AND REVENUE - AS IO NEFENDANTS TYLER MCDONALD AND MCDONALD I/B/A Y1.ORG 71. The ollegations contvined in parageaphs | through 3 & 45 through S8 shove are re- alleged and incorparated herein by refercuce. 72. Plaintiff. trough i agency MC2, has lost 6 significant amaunt of busisess revense because af the sctioms of Defendants MeDanad diva Yi.Org and McDonald set forth shave. 73. Plaintiffs have no adequate legat teimedy to rake hit whol as a sesult of the damages sullen in the firm of lust business revenue due to the uations of hath Defendunes. 7a. Accordingly, Plaintiffs seek © become whole by the payment of damages by both Defendants to compensate him for his losses. WHEREFORE, PLAINTIFFS request judgmen: sgainst DEFENDANTS as follows A. Damages in excess of fitesa-thousand doles iad by fury and B. Gol uher such relief us is uppropriaie. COUNT V ~ DEFAMATION AGAINST PLAINTIFFS — AS TQ DEFENDANTS TYLER MCDONALD ANI MCDONALD D/A VL.ORG 75. “The allegations concained in paragraphs | rough 3 & 35 through 58 above are te- alleged and incorporated herein by reference. 76. Defendants McDonald d/h Y3.Org and McDonald published or causes to be published, false setaincats about PALS using Weir domain host service. 77. Defendunts MeDonuld dfhia Vii Org anil Mofonald knew, or should have known, that the statements aba Plinifis were false. 8. These published statements were read by che ekemmecs users who viewed the lsc statements. 0. Plainuiff business reputations were severely damaged as a result. 3 WHEREFORE. PLAINTIFFS request judgment ugsinst DEFENDANTS as follower: A. Damages in excess of fficen-thousand dollars trial by jury and B. Grant olhec such celief us is uppropriute. COUNT V1 FOUITABLE RELIEF FOR REPAIR OF BUSINESS REPUTATION - AS IO UEFENDSNTS TYLER MCDONALD & TYLER MCDONALD D/B/A! YLORG 80. The allegadons contained in peragraphs 1 through 3 & 4 through 8 shove are re- alleged and incorporated herein by refeccnce. BI. Plaintifts have also suffered a significant lows of their business reputations us dicey esol af the actions af Defendants McDonald dia ¥i.0rg and McDenald. 82. Plaintiffs have no adequate legal remedy o make then whole as a rosult ofthe damages sullsced in the form af Jost business ceputations due tn the sctions af bith Defendants, 8). Accordingly. Plaintiffs sccks to restore their business reputations by the payment of damages by both Defendants to compensate them for their loss of reputations. WHEREFORE, PLAINTIFFS request judgment against DEFENDANTS 3s follows: A. Damages in excess of fifleen-thousand dollacs: triad by jury wd B. Grunt other such relief as is appropriate. ts Joe Tilone, Joe Titone Atceiey FL BAR 5: 203882 £21 SF. * Syreer Pomgano each, Florida 33060 (954) 729-6450 (954) 9412232 (FAX) Toctiwons 8 @somesst net eamesTio Stas os ORDA ) com oni gar) HEANLIC BRUNE. bing ly vcctor ds hr a ri sri me itis mind ern A ha oan es hemi tt kl ‘Swan an) subueribes bale oie his dy of Zrdg apr 20M. a A, LETT Ee. NOTARY FR 1 COMPOSITE EXHIBIT A Bitpzifemw.thedailybeast.com/articlesi201 0/07/29] effrey-epstein-feds-probe-possible-child. traflicking-churgz. btm] Epstein Faces Sex-Traffic Probe The Tuscice Depurtment is investigating Jefrey Epstein for child trafTicking. The Daily Beast has. learned —and has widened the seope of its probe to include u fsmaus modeling agency. Tledge-fund manager Jetfrey Cpstein completzd his sentence for scliciting prostitucion with a ‘mina last seek. But it appears his problems may not be over. Now The Daily Beast has leamed. that: Fuleral fnventigators ction ts investiga Epaein’sweiitie, 1 se whether there is cvidence uf child ra Shea far more serous sharge than the wn in bi noe. Drosscution agresment, th arrangement between Fin and the Department of Justice Slowing Din to lead guilty to lower.(evl State crimes. Trafficking can carey a 20-year +The FBI is also investigating Epstein's friend Jean Lug Krunel, whose M2 modeling agency appears lo have been a source of girls from overseas who ended up on Epstein's private jets. Because Epstcin's predatory habits stretch back many years and involved dazens of young- looking gitls, here may well be more cvidense to uncover, who accepted cash sefttements in these civil suits agreed not 10 testify against him or speak publicly about the case. However, new evidence developed by the Department of Justice on other offenses aot covered by the agreement. including allegations by additional victims who come forward, could lead to new charges. There is no stanwe of limitations wn the federal sex- uatticking law. which was also enacted by the state of Florida in 2002. Beceuse his predatory ‘Tuhits stretch back many years und involved dozens ul young-looking gic, there may well be morn ever 9 inceve. (Severs young women hoc is be Pgein viet have ecenly contacted a Fr. Lauderdale Lawyer, but to date no new civil complaints have been filed.) + Gonshira Samet Le ilionaice lies es. en « Billionaire Pedophile Gocs Free ‘These new developments come one week after the publication of twa adticles in The Daily Beast about Epstein’s pattem of sexual contect with underage girls, which Palm Beach police began investigating in 2003 and the U.S. Aftomey”s office then scttied in 1.2007 plea deal, The first 16 ariel: quoted a deposition by then=Talm Beach Chief of Police Michae! Reiter, ic which he stated chat Epstein, a billionaire with many powerful friends. bad receives special treatment in both his plea deal and the terms of his inacceration. Although federal investigators at one point produced a draft 53-page indictment against ipstin. he was eventually allowed 10 plead guiliy 0 only two reladvely minor sta charges and teceive a short term of icoceradion. 13 months in the connty jail, during which he went 0 the ¢HTice every day, und on y2ac of community control, during which he traveled frequent to New York und his private island ic the Vicgin Islunds. “The Daily Beast hee now discovered another ingtaaoe in which Epstein agpasensly ceceived special consideration: AS a convicted sex lfendee. he is reguired by law tb unde un impartial peychclogical evalustion prior t sentencing und to reeeixe pychialric treatment during and afier incarceration. This s because child molestors fend to be rep offenders with Bigh rcs of” recidivism. According (0 a source in law enforcement, however, Epstein was allowed to submit a seport by Ais private peycaologisc, Dr. Stephen Alexander of Pains each, Florida. whose phone bos since been disconnected with no forwarding information. “The Daily Beasts second anicle provided details abous Epstein’s systemadic abuse of undecage girls at his Palm Beach mansion. shere members of his staf allegedly recruited and paid a parade of teenagers, most of then 16 or younger, 10 perlorm oily massages that devolved ints smastuchation, 2ruping, sad sometimes full-blon soxusl contact, [also revealed « monetary relationship betieen Epstein and Jean Lue Brunel, s frequent visitor to wham he gave $1 million around che same time that Aruncl was starting his MC2 modeling agency. Some of the Young girls MC2 recruited from ovarscas—often from Easter Europe and South Ainerica—are Known have been passengers on Epsiein's private jets. “The 11S. Atormney General's Office in Florida says that itis against policy to contin ox deny the existence of an investigation Jeffrey Epstein’s lawyer. Jack Goldberger. says he has no Knowledge of an ongoing probe, end he told The Duly Beast. “Jeffrey Epstein has fully complied with al state ad federul requiremees that arise from the prior proceedings in Palm Beach. There are no pending civil avsuits, hore arc nos and should not 06 any peciding crimindl investigations, given Me. Epcin's complete fultllen of al the teas of his nun-prosecution aecesiment will te ders) goverment,” Conchita Sarnaff has developed multimedia communication programs for Forme SHO compas cnd has produced three ctrvent-cuens debate TV programs. The Ameticss Toram, From Beirut 0 Kabul. and a segment for The Oppevhzioer Report. She is writing a book cho child trafficking in America bie hess benscconyarceles20100722iellev-<pstein-pedophil-billiomire-and= bissexden im The Billionaire Pedophile’s Sex Den Hedge fund mogul und sex affender Teffrey Epstein, whn went fice this week, lived ina depraved world of thricc-daily massages. pornographic artwork, and hush motcy—that's only now being evealed. Conchita Samoft reports on the sordid deals in part two of ber exclusive exposé. Hedge fund mogul and sex offender Jeffrey Epstein, who went free this week, lived in a depraved world of thrice duly massage, pornographic artwork, uad hush money —that's only now being revealed. Conchita Sarno reports on the s0r6id details in part twa of ber exclusive expose. Alsas + Nude images of young girls were scattered around the house und the bathroom soap was shaped like sex organs + Staff trolled for fresh recruits to make sure Epstein bad two or three massage appointments cach day +The house manager has been scatenced to a longer prison term than Epsteiu—{or trying to sell uotes regarding massage uppoiatmeats + Fpwtcin gave Si millon to his friend Jean Luc Brunel when be was starting the modeling agency MC2 + According tn farmer hrckkeepar, young girls were brovght fa the L$, by MCZ-—often from Eastern Europe—then traveled on Epsiein's private jets Jetfr Lpstein's Joyal friends say that his prosecution was unduly harsh, rather than outragecusly lenient They insist that his sexual habits. although obsessive and unusual, were mostly legal and essentially harmless. As the police records aticst. the girls brought to EI Brille Way wesc routinely told they could “say no” al any lime during a massage as Epstein escalated. contact in a step-by-step assauit that was remarkably similar in every victin's statement: First he veld be ake to emo her shir, the her pnts, He would tempt 1 foal her butocks and hreases ay he mesturhated, then bring out a large vibrator. There was sometimes digital penerration, and the more willing girls were lured into full-blown sexual relations with both Epitein and Nadia Maccinkona. who was refered o in press accounts and police reports 5 Epstein’s live-in “sex slave.” A foie baokdesps in the Mian offic, wha als sere vss for is ras lm the (15 wonlirmen that MC? girls hecame frequent guests on Fpstein’s private jets. 1s o's tre that some underage girls may have lied about theic age, and sowe cane o the huuse voltarily sever tres although, duovrding 10 Florida statutes, mone of thal has any hearing on the criminglity of the contact. particularly 3 the irl wos 16 or youngee. But what is marticulurly disturbing xbewt this case—judging by srrangemens at the Palm Beach house—is that Epsin, a billionaire hedge-fund manager, organized his life around this sexual compulsion in an open and mcthodival way lat suggests he fel he was beyond the lav. + Conchita Samofl: Epsicin aces Sex Traffic Probe + Billipnair: Pedophile Goes Free According to police wha executed a search warrant. the house ws decorated with large, framed ‘Phatos of nude young: irl, and similar images wre found stashed in a armor: and on the computers seized st the hous (sltough police found aaly bare cables where other computers had been), Some batiooms were stocked with soap in the shape of Sex organs, aad variaus sex toys, such a5 8 “twin orpeda” vibrator and Crean end 1ubticats availtble ul exotic specially shops. were stowed ear the massage tables set up in several roms upstairs. Fite alin enlisted his staff in the predaveey activity, and four—Saerh Kellen, Adriana Ross. Lesley Gro, and Marcinkove—figured in the FBI investigation. The Non Proscuution Agreement stipulated that they would mot be charged. According to police reports and swom Matements in tho civil suits all four women, amon their ather dutics, worked 0 ensue thac an sppuiniment baak for twice- ar theice-aily “massages” was stoked with fresh recruits. Ghislaine Maxwell, daughter of the arc Czcchoslovakian-boen press baron Robert Maxwell, who was for many years Epsein’s live-in partnee. also recruited young girls Since his |3-month seneence for soliciting prostitution with a minor. Epstein as seticd aoe han dozen lawsuits bought by underage girls. Seve victims ceached a lus-minule deal last wick. days before a scheduled tial each received well over SE million—un amount that wil hurdly den Epstein's 52 billion nel worth. “The victims told polics they waited in the kitchen to bs called upstairs for a massage. and the house chef often gave them a kite eax. House manager Alfredo Rodriguez said in his sworn Statement tt & maid named Lupita, who wes a devout Catholic, wept when she complained to hin about cleaning up after the massage sessions, picking up soiled towels and putting away the sox toys. And she was upscc that photo of Epstein with the gone hung next @ ene of him wih a young girl Tronically. Rodriguez who ran the house on £1 Brillo Way [n 2004 and 2005. ended up being seneneod fo more il ime than bis boss 25 a result of tbe omplex investigation into Cpsiein's activites. Lie was lied, he says. Gor inadvertently drawing police stention ta on of che girls shin she arvved ut the house unamamunced to collect money. He sav an unfamiliar “beater” in the drivewsy onc evening and called 911. When he left Epstein’s amploy. Rodriguez ook awoy <ome pote and crnils about massage appointments as “protection” against his own prosecution, and failed 1o produce them ducing the Palm Besch Police Department's initial investigation. Unable to get work as a house iuanager elsewhere in South Florida. he says. Rodrigues later tried Wo sell his “golden nugget" his erm—tor S000, @ be used in the victims’ civil suis. 9 Lnfortunstely, he made the offer to an undrvoves Gop, and was subsequently chieyed with “obstruction of official proceedings foe withholding information that could have advanced the ciminal invesdigation of Epstein— which Ly that point had been setied in a plea deal. Rodrigue, as sentenced to 18 montis in fede] prisan (Epstein wax allowed 1 serve 13 months in the Pals Beach county jail), and naw awaits an additional sentence an Aug. 24 in federal court in Miami for ranspiring firearms, another deal he says he made te pay the bills ates he lost his nb. In a degorition given for the civil suits. Rodrigues testified that hz was instructed to always have 2.000 im cash on hand. 50 ths he cculd pay bath the girls who gave wassages und porters such as Haley Robson who brought thew to the hase. He alsa testilied thot Epstein rae large conaibtions to the Palen Beach Police Deporimen. onl in return was given PPT baseball hats 10 put on the dashboard of his various cars to avoid being stopped or ticketed by local police. Retired Palice Chief Michac Reiter, in his own deposition, acknowicdeed that. i addition to carlics donations to the police departient (which ace fairly commen in well-heeled Palm Beach). Epstein had ruscntly given he department S100.000 for same saphisticated equipmens. The police were still cesearching the purchase when Fpicin came under suspicion. and Reitec andersd the money retumed. (Guy Frostin, one of Epsicin’s local atomeys. told police that Epstein elo gave $300,000 10 the Florida Hallet for massages, because he was “very passionate” shout massages being “therapies and spiciually” beneficial. Yet victims lold police they had no massage maining.) Perhaps mast disturbing, in terms of possible sex trafficking, was Epstein's relationship with Jean Lue Brunel. ower of the MC2 modeling agency. According 0 a cainpiaint filed in the U.S. District Caurt for the Southern Disteice of Floride, on alleged victim seid that Epstein, Maxwell. Brunel. Rodriguez. and Marciokovu “deliberately engaged in u puttsm of racketeering that involved luring minor children through MC2, mostly girls under the age of 17. to engage in sexual play for mancy. (Which would amount to trafficking.) Brunel is a S0-plus French playbuy wha was formerly part owner of Karin, a Paris-based mlefing agen. He lives in New York and South Beach, Florids, snd owns 5 percent ol MC2, which has offices in New York, Mises, and Tel Aviv. {The remaining 15 percent is owned by his parince. Jeff Fuller) Brunel is been observed as a house guest a Gpsizin’s Pals Beach home and may well have had contact with him also in New York. where Epstein owas a lavish home. and in Paris. where Epsicin keeps an apartment on elegant Ave, Foch. CBS reporter Cai Pyes, who investigated Brunel far u 60 Mimutes broadest many yeors ago, it quoted in Michael Grass” book sbout the modeling industry, biel: Tho Ligh Husiesy of Buundiful Homen, Pyes told the suthor that Brunel “ranks among the sleaziest peaple in the fashion industry. We're talking aban a conveyor bel not a casting couch. }undreds of girls were not only harassed but molested.” Now The Daily Beast has learned tha: Epstcin had made a SU million wire trausfe to Braoel’s offshore hank aceount in September 2004. just os he was setting up MC2. Whether this was a gift or 1 loan o a backdoor investment in dhe new venture is unknown. A French citizen who nianaged to avoid giving evidence in the Epstein investigation. Brunel declined to coimient on any of this. us ues Fuller. Asked in April of Brunel's activites, 0 Fpstein sid *)'m 100 percent convinced that he doesn't traffic childen * (Bronel hos never been charged.) An American fashion desigrer who bocked het gicls through MC2 says they were very young and very beautiful muty were fiom Eastern Eucope and spoke litle English. A former oukkeepec in the ueowy's Miami ullec. who alo arranged vives for girls traveling t the 1S confined that MC? girls became frequent guests on Fpstzin's private jets. Pilot logs obtained in the civil suits show thal some of the named plaintiffs were on the light eanilosts. Othe lies, Lhe piluL would just Fist the nther passengers plus "female." Kaliror's Note: An earlier version of this article isidentfice the sublet uf Craig Pyes' investigation and the tie of Michael Gross” book. The Daily Beast hus corrected the subject and tle ani regrets the error. Rend Conshild Sarmofls vrivival runt on Eptein, Conchica Sarnoff hav developed multimedia communication programs for Forme 500 companies and has produced three current events debate tolevivion programs, The Americas Forum, from Beirst to Kabul, aid a segment for The Oppenheimer Report. She is a contributor 0 The Hufingion Past. She is welling a book abou child trafficking in America 21 hicpifashioncopious.cypepad comHashioncapious 2010/0 /enc2-mudeling-agency-involveidin-sex- trafficking bem MC2 Modeling Agency Involved In Sex Trafficking August 11.2010 On Avigust 4h Jezebel ran the following story: Te Se. Tealieking Moule Secu. Perhaps mast disaitbing, in terns of possible se cafficking, was Bpsiein's relationship sith Jesn Luc Bruncl. own of the MC? modeling sgency. Accunding lo » complain fled in the 11.5. District Courl or he Southern District nf Finrida. an alleged viotim said that Epstein, [asistont and yicriend Ghisluine] Maxwell, Rruncl, [hovse mamager Alficdo) Rodriguez. and Marcinkova “deliberately engaged in a patter of acketcering that involved lucing minor children thraugh MC2, mostly girls under the age of 17. to engage in sexual olay for meney. The previous paragraph in the siory read: ad raking [spescing of JelTrey Epstein] frequent $106,000 damations to the Palm Beach Police Department sould fnsulass him from prosecution for his various depravites ‘Which included. for tse record: busi a 14-yese-okd Yugloslavian named Natalia Marcinkova feoun he pares in onder Lo keep Marcinkova as his "sex slave: paying a retinue of wonien to trawl Palm Beach for teenagers economically desperate enough 10 agree to give Epsicin “massages” that aficn led to sexnal contact: eceiving two 12-year-old French gies as » “hinhday present”; and heficating Michael Wolll 2 hpsihca Fokker wondpress,con?20 10/08:20/hesshelping-others-gec-meay-with-child-sex- mafficking/ He's helping others get away with child-sex trafficking Posted ou August 20, 2011 by Betty Fokker Let's dhcuss that billionaire doucho-fuco child-rapise, Joey Epstein fora moment shall we? Ho's someone wh likes to have scx with venerable inderage girs. including 12 yeae old air wh are raffcked into the US under the guise that they will beeonie models. is partner in erie was Joan Luc Bruel. owner an “talent scaut of the MC2 “modeling agency”. Epstein coincidently vested a illic bucks in the MC2 Kiddie-parm-sing modeling agency and lez Teunel use his privet jel “The FBI sinks Epstein has ussuulted/molested abut 40 ur su youn wirls. So he's going to prisun for the rest of is if right? Wrong, Whe faced wich the best defense lawyecs mouey could buy. the prosecutors wimped out und male & plea bu goin su light it hggles the mid. This kid-raping bastard amly hud 0 please ity 1 vo MINOR charges und geo private cell, a cell he ges tn lease on “work relesse program” hy the way. ow, 1 am not blaming his defense atoeneys. They were doing their job and, undec ae constitution, ¢ festering: anus like Epsteio has the right to the best attorneys he can afford, Jam livid with the prosecuting attorneys, It was their job to do everything in their power t bring this vonit-inducing ahit-sack w justice. Instzul, they decided to gutlesaly pander w his wealth, privilege, sou powerful defenso team. They rolled over and did everything hut send in annher Kid 10 ive thix fucker & handjob. So this vermin got away with raping 12 year old girls because the prosceuting adameys couldn't find a single testicle/ovary to shies aniong them. And do jou know what their chicken-shit kowiowing to Epstein bas wrought? Ics opened the oor for other child-scx teaffiskers to get lighter seniences for ther cme to. Wh should they have (0 pay when be dida’t? Aer il. it was just ics they were trallicking [or sex with disgusting older males ( refuse Ls call something Bike Epstein “man it insults men)... they: weren't harmicg anyihing of any valu in our cole! I'm a feminist because | thiok, girls & women have value. What a crying, fucking shume there wasnL une feminist in (he prosecutors office 10 go after chis monster and punish him, What pity aver hell-spuwn might get away with trafficking pils for sx more casily because of the shit- foe-brains attorneys who lec Epstein get aviay with bis crimes. My eyeballs are melking with rage. Never mind. They aren’ melting. T's just tears of helpless and despairing rage against an unjust Tegal syste ur the altura devabuaion of women and girls. 2 tye com S204 fosscneofidlee-cptenc es <hilt: iricling arses Revently-Freed Sex Offender Jeffrey Epstein Mav Face Child Trafficking Charges a mY 3 5 Doo wet: - Expand Ads by Guosle Jeffrey Epstein, the billionaire Bill Clintoo pal whe just left jail efter completing a sentence tor soliciting sex with a minor, may be headed back socn: The Daily Beast reports that the Justice Depriment venga i fo hl mck, Epstein. famous for bei rich, being friends with ili Clinton, huving un ee-shaped penis, and being a vindictive persen, can't be prosecuted uguin for the charges he copped to in his plea eal, But pecording to The Daily Boust's Conchita Samed, new charges might be coming: As we learned in Vanity Fai yesterday, Bill Clinton hes spent his post-presidenciat life, , Read Federal investigators continue fo investigate Gpsiein's activities. Lo see whether there is evidence of child rafficking-a far more serious charge than the te in his non-prosecution agreement, the ercangement between Epstein und the Department of Justice allowing him © plead guilty to lower-level state crimes. Trafficking can camy a 20-year sentence. Since there's uo stulute of imitations for sex-tesfficking, and Epsteir's predatory adventures upparently dute hack more than a few years, is likely there's more women who could come Soran (Apt Sem hove CARS uy. ut rhs bn Hed 1 t's mot just Cpstein, either—his huddy Jean Lue Brunel, head of the MC2 modeling agency. is alsa being investigated, and same of the models he represeaned (many from pverscas) may have: been enlisted as companions on Epstein peivale jet u ips huigton post can 21 406-63 elTisy-spsicin 1. 5439407 biml MIAMI (AP) — Nearly decals age, 3 wealthy financial guru came under FBI investigation. suspected of sexually abusing dozens of underage girs at his Palin Beach waasion. Then. abrupsls. Use iovstigation was draped ur felfrey Fpstein pleaded gaily lisa single sine larg of soliciting prostitution. [Te served just aver a scar in ail. Now, twa wamen ho say ies wes umeng bis victins bave wi a presedent-velling apoeh oust ruling ntiding Use Lo see all the dcumerts from Ure ples args discussions between Epsieints high-puseri lun yers and flees: prosecutors, Phir goal: use those flos 2 undo the agement. ceopen th vestigation and sucjeut Fpstein more eharges, The ssumen's lawyers contend Fpsecin got special seamen because of his walds and connzetians, His atorneys deny that. Epstein. 61. made Hundesds of millions of doles managing fusds for rich cliznis. Snorly after is 2008 guilty ples. it came to light fags Wis lawyers hag scot (cached a non-prosecution agreement maths earlier wids the U.S, Justice Departuncol that sped hin a potentially easier punishment, "Our complain alleges that, prodded by Epstein. the Bids prosseutoss deliberately convealed the sweetheart plea deal they made vith Ri tw avid public citcisin.” sid Paul Cossell, + Universis of Uta kaw profissor seh is represerting the bse women The US. atomey’s office in Mini would rot comment. But the LS, arorey at he tine. R. Alexander Acosta. seid in a 2011 leer delading his ollice that more evidence ceme Uo light after Epsteis made his deal. "Many wictims have spoken ous, filing detailed sateinents in civil cases seeking damages. Physical evidence ks bean discoveevd.” Avoata wre, “lad these additonal statements md sviduics bees hiown. (e wutgme may have been differen.” pin hs tried owsuics fo ondisclosed antunts with nan of Use women who say they wer: widens when Urey were pai fi ses. Th case represents the fist ime a feders) appuas uur bos led Sc the Crime Victims’ Rights Act of 2004 guatentees itis he ight © be informed ahout the details of how a ples bargain San relied. aecording to Tegal experts and lawgers involved in the case, The bi naked the culminacian of forts hegen in the 196015 1a give crime victims mone of 3 sy 25 “I hope that the case will ulimatels set an imporsant precedent that fideral prosseutoss vast ke ‘ictits in the deck whout the plea deals that they reach.” Cassell said. Epstein served 13 months of an 18-month sentence an the prostitution charge, sold hs Palm Reach Ran in 2011 tind now divides his time between 3 New York Cy home. a Caribbean island aad an partment in ars, 95502 10 court documents. He sls las a large New Mexico ranch. le donates huge sum exch sea, particulaely toward projects involving new sedi tratments and dctificial intelligence, His foundation established a Harvard Univesity progeam that uses mithemaics te stud evolionasy biology. viruses and disease. According to lusts Filed by some of i accusers. Epstein relied on assistants o 1oéruit wnlerage gieh to give him nrsssages and pertonm se acts, They were wally paid shout S200. Some girls tere norified about Use vestigation heginping in 2006. Hit they weren's fold about he negotiations with federal presecutors for ut least nine months, despite s reuisemest in the Crime Victims’ Rights Act thet they be kept inforined. The two women who were 13 and 14 ‘whe, the alleged assauls occurred — sued for the files and vor. “Although plea xegetitiens ane vital ta the fanctioning of the criminal justice systeun. & praseculor and get of x criminal prosecution 60 not enjoy a selatvnship of confidence and tous when they negotiate.” the appeals court said. Fedoral proseciiiors Rave begun tuning over the documents, pins attomay. Roy Black. ti celebrity lawyer wh is ala: representing lustin Bicber in his DUI and esisting-arst cass in Mismi Beach, declined to comment hat hes asked that the. documents be kept from pubic view. and so far they have been. In May 23 can ling. Black said hat then was no conspiracy between prosecutors und Epstains team to violate the vicdms' rights kav. und that the non-prosecution agement contained many provisions Tpstein stcongly opposed. such as registering is 4 sox oflender and agreeing nut contest certain lavsuits. “This #38 10 sw eettsort deol by amy stretch of the imagination.” Black said in court papens. Even ifs judge invalidates she plea deal. itil sil be up w federal prosecitons io decile what wa “The cur can't force the prosecutors 0 bring clases.” said Ma Alexrod. x former Reders! prasecutor na in pee practic in Washington. 2% hapz/twwr. huffinglonpost.conveanchita-s-surnulfiehild tra ficking_b_1269748.html Conchita Sarnoff Communieations expec Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Posted 021102017 £49 pm In 2010, Jezebel, an online site, publislid “The Sex Trafticking Model Scout” warning shout the dangers of dercgulated modeling ageacies in the U5. Given the grawing number of modeling agencies thet transport underage teenagers from foceign coumciss nt the Lite States nd th geowing sex tad of underage is the LS. why docs this industry remain deregulated? Since the sven of his business. modsling agancis have hc fe eign 0 Scout feenagess fom ‘every stake in the country as well as every nation in the world. Moay of these teenuge girls come from cconemically disadvantaged families aod are ofTeced note 1 very limited protection while traveling and working as "madels.” Jezebel reported that Jean Luc Brunel, one of re ust of charautsrs involved in the ongoing Jetiiey Epstein (a Level 3 ceisiered sex afTender). eight-year-longs cuse, has been working for aver two decades with a succession of agencies in New York and Paris. According 10 media reparts, Diane Suv ver produced n segment far CBS's 60 Minutes fearing a scx scandal that svenually le Eileen Ford (founder of renowned Ford modeling agency) icp wari With Brunel, Grunls latest vemurs is the modeling ageney MC2 based in South Beach, Fl. with satelite offices in New York and Tel Aviv. Since his agency is dereputated and "no criminal hares have been filed by any of bis accusers” — ulthouph many have tried lo serve him inching luswyers representing Epstein victims, Brunel continues tn hide behind his French citizenship ro prevent depositions. “Trawling for $11" underage teenagers to work for his agency. MC2, or anyons else who requests. Brunel is free to scout for very young wils without limitations.” Given his citizenship he also successfully avoided deposition in Cpstein's sex related cases. Like so many other reporters who have tried © report bis side of the story when Jesrbel contacted Brunel, "be did 510 respond 10 au interview request.” According to Jezchel: n we oie to nmr of peaple lo irked with his ancy and while MC? in considered a mor industry player, i rt exacly hotorm-shelF either. Bron) fst involved with he business cn a duy-to-day busis, although he owns sn 85 percent stake in MC2. nswad, he does scouting for the agency and tekes care of the interuatioaal relations with other wgencis. coparts one source. Scouts scout the world for unrepresented teenage pirls who could make it as models. They work lacgely wisupervised und ure generally paid s headhunting fee for every girl an agency signs. Even when ulliliated with sn agency, as Brunc| obviously is with MC2, scouts operate mostly independently nnd with litle oversight. The company blog refers to Brunel as a "scouting tsunami’ and MC2 is fairly well known tor the streagth of its international scouting. Model. Michael Groas's 1995 book, describes Brunel's activities in Paris from the late 1970s onwards, when he worked for. and eventually owned, the modeling sgency Karin. “Jeun-Tuc is considered a Gauge.” says Howe Barmousrie. “(rani Kevin wa dream [1 playboy: His problem i tha he Kiows exactly wha ir i rouble ar Inoking Fo. He's always been on he Clje of hesysiem.” Jahn Casablancas, founder of Elite modeling agency said: 1 really despise Jean-Luc as » human being for the way he's cheapened the business. There is no justice. This is a guy who should be behind bars. There was a little zeoup, Jeun-L ac, Patrick Gilles, and Varsano. ‘They were very well known in Paris for couming the ulubs. They would vit in arp og es Gren Erbe Knees fg were cepa Cop 02) professional rival wha was pushed mu of is agency for uesiomable conestns Katic Ford human raffcking abl nist and Eileen Fund daughter, eked the il Sees Journal magazine, In thal stury “A Mudel Trade Union,” Ford describes herselas a "roving ambassador” to help stap human tracking. Ford sold her stake in the family business in 2007 to the privote equity fiem Stone Tower Equity. “In har new life as a neaely full-time, unpaid, roving ambassador for the cause her job is an outgrowth of her former work. rather thao o repudistion of it. nr an aronemant. Her interest in human trafficking began when a representative ot the United Notions callzd to ask if she would participate in 5 women's Leadership group thor vias studying the issue af trafficking. “1 Sac. L can ome lk about i, becouse 1 dan know any hing shoul 41 Ford recalis. "Bur went. and after twa hours, | knew why | was there. The way people traffic across boeders is le 0 th why wt reget dels Aceotding to Fd The target ag 1 0.24 and su ts Simla to undeling 1 knw how Fach tht raat ah Sad. wat the Felmg of re but for the grace of God... The gitls who vame to us could have been those girls." ts ezsbeL ou SGO3638 mest he-mleling gent who raffcked am derage-gils-for-sex The Sex-Trafficking Model Scout 2 - dE] sand Iefirey Epstein, the billionaire financier who the FBI believes molested aruund 40 underaged airls. was assisted by a prominent modeling agent wad scout. Elere's what we know shout Jean Cu: Brunel. Jeffrey Epstein, you vill no doubt cocall, is the ine whe thaught tereying Bill Clinton an his Private jet, lawyering up with superstar Alon Dershowitz, and making frequent $100,000 donations ta the Palm Beach Police Department would insulate him from prosceution for bis various depravities Say you're rot a famous ox celebrated os Romun Polunski and you want a sexily assault... Rend mor: ‘Which included. forthe second: biiving 8 14-year-cld Yugloslavian named Notaliu Marcinkeva from her parents in order t keep Macciakosa as his "sex slave”. paying a retinue of women to awl Palm Beach for teenagers eroncanically desperate enough to sgree to give Epstein “massages” thal often led tn sexual contact; receiving rwo 12-year-old French girls os a "binbiay presen": and htricnding Michzel Wolf]: Butas Conchita Small wrote at The Daily Bens: Porhaps most distucbinz, i terns of pussible sex trafficking. vs Cpt’ relationship with Jean Luc Brunch, wisn al the MC2 madeling agency. According a complaint fled in the U.S. District Court for the Southern District of Florida, an alleged victin 31d drat Epstein, [assistant an girlfricnd Ghislaine] Maxwell, Brunel. [house manager Alfredo] Rodriguez. and Morcinkova “deliberately engaged in a pater of racketeacing that involved luring minor children through MC2. mostly girls under the age of 17. to engage in sexual play for nioncy. Tie FB] investigated Bpstein, snd identified wround 4 mderaged victims. Samoft reports that the FB] is lso investigating MC2 and Brunel for possibly engaging in child sex trafticking, Sine pleading uly 0 reduced chargss of soliciting sex with a minor and serving 13 months af 2 patetime jail. Epstein hus become the fous uf mmenus civil lawsics from his vietms. He has su far selled u deren ‘hes sane civil complaints allege that seune ick from South Americe, Europe. and the farmer Saviet republics, fev of whom spoke English, were recruited for Epos sexust pleasure, According to a former bookkesper, a number of the girls worked for MC2, the modeling ageacy owned by Jean Luc Bruncl, 3 longtine acquaintance and frequent zuest of Epstein. Brunel, alung with numerous young mundels, was frequent passe on Epstein privat jo, sccarding ly Tight manifests. The agency owner also allegedly received $1 million from Epscein in 2005, when he founded MC2 with his partner, Jefirey Fuller: although Fullec and Bruael denicd any such payment from the billionaire pervect in 2007, when rumors started swirling, SanofY ax confirmation from a former bockkaeper at the sgency, Whether the moncy was & secret investment in MC2, or & payment far Brunel's services as a procurer, is unknown, Brunel abso visiied Cpstcin in jail 0 who Js Jean Lut Brunet? Although he did ail respond w our interview request, we spake ia 3 number of people whi have svorked with his agency, While MC? isn' considered a major industry pleyer, it in's exactly bortom-shelf, ther: MC2 in New York most eceatly luoched the carer of Latvian editorial star Ginta Lapin (Beunel "isussend” Lupine via un MCD scouting competition For vous lees) and currently represents Fojaue Chins Eivergin Tia Dan. Worldwide, MC2 represen such stars as Sessile Lome. in Miami, and top models Candace Swanepoel, Maric 1 ynchuk. Natalia Chabanenko, and Elisa Sedntoui in Tel Aviv. Brune] isnt involved with the business on a day-to-day basis. although he owns un BS% stoke in MC. stead. "Right now he doss scouting or [the] agency and takes care of the international relations sith other ugencies.” sports one source. Scouts scout the world foc un-sgentcd wzenaged girls who could make it as models; the wok lagsly unsupeevised and ce generally paid 3 headhunting fee for every gir an agency sigs. Even shen offinted wilh an agency. 25 Brunel obviousiy is witk MC2, sceuts operate mus independently and with lik oversight — even relative (© the almost wally unregulated modeling iedustry ise. “He travels a ot," says unother person wha has warked with Brunel. {The company blog refers to Bruncl as 0 "secutin tum," ond MC? is ily wellknown forthe strength of Is international scouting) Models we spoke tu report mstly positive experiences with Bruns! — one praised his sense of humor and said he is “lovely 10 al of his models,” nd another described hirm as highls intelligent and cultured, adding. "he knows & lat about the opera und he paints” — although it should be noted that none of the models whom we spoke to had heen sold of cher his connections with Epstein. or his past. And what a past it is, Theve accounts from Miche! Gross’ 1995 hnok Model describe Brunel's activiias in Pais from the lata 19705 onwards, when hc warked for, and eventually owned, the madeling agency Karins, now known as Karin Paris: "Jean-Luc is considered a danger,” says Jésoime Bonmousicr. "Owning Karin vas a dieam fora playboy. His problem is that he knows exactly what gick in trouble are louking or. He's ubways El heen um the edge of the systema. John Casablancas gets wilh girls he healthy way. Girls would be with him i he wes the butcher. Theyre with Jean-Luz because b's the boss. Josn-Lue likes Gags and silent rage. I excites him." “1 really despise Jean-Luc 0s a human heing for the way he's cheapened the business,” says John Casablanca. “There is no juscice. This is 1 8uy who shauld be behind bars. Thiers was a lle uroup. Juun-Luc, Patrick Gilles, and Vacsano... They were very well-known in Paris for ruuming. the clubs. They would invite gies and put drugs in their drinks. Everybody knen they vere eres. should be noted that aside from beiog a professional rival, Casablaneas, the founder of the agency Flite, was eventually drubben aut of the industry for his ow inodelizing, How pervy do you have (© be tie John Casublancas to call you a perv? Pervy enough to drug and rape Dinners teenagers. accarding 10 60 Mimaes wid Diane Sawyer, ‘wha investigazed Brunel in 1988. The program interviewed nearly two doen models who said they had beso sexually wssaulked hy Brunel andor by his fellow. agent, Claude Hades. Even at hat tine, Brunel hud 1 reputation vs a man one could 0 to procure a *date” with a young model, CBS spoke 1 five madels who said Chet Brunel andlor his fricnds had drugged und raped ther. Suid producer Craig Pyes, "Hundreds of girls were nor only harassed. bil molested." ‘When Gross intecviewed Brunel, his Js vat he had 10 say foe himself. “You get lid tonight with a rol, is thi a crime? | done understand why people go into your personal life, what you lo yours” snd tn yourself and they don't lock at things that are really imponai” Sincz then, Brunel as been invalved with a suecession of agencies in New York and Paris. Alibough the G0 Ainules scandal exentially lod Eileen Font w stop working with him. he continued his invalsement ih Karis, Ln 1968, when pawerhause agency Next opened its ours, Brunel Ink an ownership stake. {le alsa “disce:vered” Christy Turliogton when she was 14. MC? i only his atest venture. Decause on criminal charges were ever filed hy any of his accusers. and because the industey hs a short memory — must models working today wecen't even born when Sussyer and Pycs started looking into Brunel's aeiviics — Bruel has been (ree 10 continue as he pleascs. A Fisach citizen, he even avrided testifying in his friend Fpstcin's ial, And 50 Brunel is sill eriss-crossing the alobe, trawling for $110" 13-year-0lds frum Fasten Europe und (the whiter pants nf) Souch America. And apparcatly taking the occasions! ride with them an Fpsweis private jet s there any better acgunent for the regulation of the modcling industry? Bipifuyposteomi201 11111 Kjefitey-cpsteins-level. 3-sex-offender-scatus-upheld-by-ny-uppeals- cour n Jeffrey Epstein’s Level 3 sex offender status upheld by NY appeals court By Dareh Gregorian November 18, 2001 | 5:Mam Multiillionaire ere Jaffrey Epstein may noc consider his Florida conviction for solicitiog a wninor a ig de, put New York dos. A star appeals cours yeserday upheld the inanciers satus us a Level 3 sx offdet — meaning he’s considersd “a threat to public safety” and a “high risk” to otfeud again. Epstein, 58. did 13 months in @ Florida jel for soliciting s minor ts perform a ses sf on him during a nasge Although he was never indiced or convicted for biriag any other underage Girls. the state. Appellate Division found thers was “clear and convincing evidence’ he had indeed done so. making the Level 3 designacion appropriate. x itp: ipagesix.com?2007/10/06/model-shop-denics-cpstein-tie/ MODEL SHOP DENIES EPSTEIN TIE By PageSix.coin Stall - October 6, 2007 | :00um THE. cnwners of M2 models arc denying industry sgcculation that massage maven Jeffrey Epstein is a scccet finencial bickee of the agency being run by scandel-scarred Jean-Luc Brunel, who was once accused of taking sdvantege of underage models. Epstein, who this week agreed to plead guilty to soliciting underage prostices a his Florida mansion ia deal that will send him t prisim foc shout 18 months, reportedly uve “millions” to start MC2, which opened in October 2005 with offices in New York, Miami and Tel Aviv. One af the girls Epstein, 53, was accused of soliciting massages from was described in court documents as being just 14, “E equals MC squared... get it. Fike the equation’ F. cquals Epstein. He just thinks overyone is tw dumb to figars it cut.” ssid a mode) industry insider. “He's 5 desperate ald man that fantasizes and takes advantage of young girls.” The trouble doeso't stop there. Karin Models foundec Brunel. who's currently a pistner in MC2. deaied allegations in 1997 60 Minuies” seinen that he look wana oT young models who were high un drugs. Brunel abu reportedly lef his Teump Tower digs in 1990 after complaints of night carusing, which he also denied Disgraced foemer Elite models exe Gerald Marie is sii involved with MC2. says our source. Marie was accused of having sex with underage models in a 1999 DBC documentary where he was lined saying; he bpd 10 seduce contestants in 8 modeling contest in which the average age a participants was |£. He also dated Lind Evangelista when she was a teen. “He's also involved io the agency.” said the Source, “Gerald and Jean-Lu like the same things, “They hang oul because they have $oung girls in common. ike tsa gays who enji the same. MC2 president Jeffrey Fuller confirmed Brune] wss a partner in the company. but denied any viorking lationship with either Epstein or Marie, “We have no relationship business-iwise with Gerald Musie. Jeftrey Epstein bax no ownership or involvement in Gur company und never fs. Jeun-1.uc Brunel and | an: the only two partners and anes af MC2 Model Management.” Fuller said. Epsteic’s rep snid he was not involved in the agency, “He has no business relationship with hem.” said Howard Rubenstein. n ty Owen palmbeachily cos. camino sins avaait-dacomentsAinkjofTey-equtcin- t-moddingiaMGaAl/ Lawsuit documents link Jeffrey Epstein to modeling agency owner Jean Luc Brunel 8 Mishole Derean Daly News Staff Weir New court filings in a civil case filed by billionaice sex offender Jofftey Epstein link Epstein and Jean Luc Brunel. owner of modeling agency MC2. The documents say MC2 employees told attorney Brad Edwards (hat Epstein's vundus u1 301 E. 6618 Sin New York City were owl 0 hous: young model. Edwards, who has sucd Epsicin on behalf of several women claiming 0 be victims af sex abuse by Epstein. was wkd MC2 brought underage girls in frum all over the world, promising them madeling walract. “Epstein and Brunel would then obsain o visa for these girls, then would charge the uaderage ails rent. he documents sa “Through the investigation of his lawsuits against Epsicin, Edwards learned Brunel “runs the ‘modeling agency MC2, a company foc which Epstein pruvides financial suppor.” the documents They alse allege Epstein ried to thwart Edwards from taking depositions of Brunel, Epstein's companion Guislaine Maxwell. and other high-profile names such as President Bill Clinton. Details are listed in more than 62 pages fited by atiorney Jack Scarala on behall of Edwards in he lawsuit Epstein led epanst Edwards. Edwards represents fur of Epstein’ inor victims. ee of whan have sell their uses with Epstein under confident agrees. Eprein ariomeys Christopher Knight and Joseph Ackerman declined 0 comment Fiday oa the court filings. ‘Edwards deposed Brunel, but his atcorny delayed it and then said he was back in Frauce with no plans to retura. But according to the couet popecs, Brume] was stuying with Epstein in Palm Beach during thut period. nu “The court filings deserihe Brunel as one of Epstein’s clasest pals Regarding Maxwell, the documents refer to sworn iestimony by Epstein’s fame louse manager, Alfredo Rodriguez. explaining how Maxswell ok potas of girls ithaul the girls knowledge, "kept the mages on he computer knew tho names of the underage girls amd thei Tespective phone numbers and ether underage victims.” Accarding i the documents; Maxwell allegedly lid sbout her moder being il and having tw fy hack 10 England onc day before & scheduled deposition in Edvard’ case against Fpsicin, Despite tat sssestion, Mawel] was ceplured in a hata for OK magazine. sending the wedding of Chelsea Clinton two days later, Epstein has sctled more than two dozen lawsuits and clims agains him by young women who say they were lured to his EJ Brillo Wey mansion as teens to give him sexually charged massages andor sex in exchange for money. The terms of all settlements sec confldcatial. Rodriguez took a journal {rom Epstein’ computer that listed the umes of hi nnderage victims frum around the country amd the world. Calling it the “Holy Gril,” Rodrigue tic to sell ihe Journal for $50.00 10 vivtims" attorneys. He pleaded guilty 19 obsiuerion of justice and is serving 14 months in federal prison. Epstein, 57, served [3 months of an |8-month state sentence, }ic ended his one-year probation in July en Stats charges of soliciting prostiwtion and soliciting a minor for prostitution. According to flight logs from Epaein's private planes. Clintun lew several times on Fptein's places, many tires with Muxwvell, Palm Beach resident Sarsh Kellen and Adriana Mucinska — “ul] employees andor cu-<omspirators of Fstcin's,” according 10 the court papers Tl documents show that Clinton few with Bpsiein, “then suddenly stopped — raising the suspicion that Ge: friendship ubruply ended .. “Epstein’s personal phone directory from his computer contains e-mail addresses for Clinton along with 2) phone numbers for him ... and what appears ta be Clinton's personal numbers.” the cout papers say. Allcgacions in dhe docunents say Epstein threatened victims — including Edwards’ client Jane Doe despite no-contact orders in effect Epstein had Dac tiled by a private investigator as her tial date neared, the court filings say. One tite. Doe was 50 frightened that she fled her home in the company of a teticed police allices aud was isken 10 a hiding place. according to the cour papers. rtpslaverytodsy. org that- gorge ovs-undecage-ademodel-may-be-lraflicked-und-cnwmed- cogulation-for-agencies-to-siop-child-sex-tralliking’ 3s That Gorgeous Underage Model May Be A Slave: Regulation For Agencies To Stop Child Sex Trafficking First came the knowledse that saves still existed and were present in larger numbers than ever before. Then she reaitzaion that a human being ould be purchased wikin « few hors of my: nome for undo STUD. Now only foe miles wes. Tn th followers ers T've heen learning. the tied fora, places snd pes of eves. The fit heeps lngrhemgt at with acl new form: Go me. Heim about, t ks owe, on mms 1 Siqrery Debt Bondage Sexual Slavary Child Brides. Forced Labor Chita Sordiers Adaption Traflickma. ron Traficing Trafiched Ailes Arnon a ve une {should he seus coming: Thave very yoieng, foreign madals you see” Some of them wer: irafficked by mudel seouts who itarally trawled thiaugh some of ihe most destitute ard vulnerable people om earth for them, Tike same methods as other predatory traffickers: Go tn politically or economically unstable areas; focate 5'11" beautiful young girls: buy them. import them, vwn thems, use them. Horrible irony to have tmages thal portray ws to the world possibly be of sires. It's hard to think of an area of owr societs thai doesn't adiire seeing it's most vented menibers with model an their aris. While tis observaiion does nol imply that those peaple were trafficked, imine hans simple that makes i to Gpproach child or its fumils anywhere in the world anc aff the this vet, for absolute conrol A te elckens uve ry spl und magazine phon is videcs on Fm not shocked at traffickers ustmg this method uf promises to lure nasuspecting girls into. slavery. I've seen ii, read about it, studied it. 1'm in shock that it flourishes in the wost Wsibis. laring sporiight of on cultave, the part that warhlus and presents vu current idea of heaty in alt everything we touch, These victims are on dhe mast prominent slave block ever. emulated by our children coveted by: our culoure-makers aud our 306iesy, an standin in the brighist nba spoulight in the world. plain sight, reported om in nunierous sories for decades and yes only escalating in usage until they ve become the gulden mean. We can quiealy ignore ths anes resold daly it our 10h. sho made ener clothes, chocolate, housewaras, provided the gold un our fingers and necks, elecwronics in our hands, labor in oe Fields. Here. finally, ave staves we fantasize about heing, emulating, allow ot society to be shaped by, conviden trophies, What wid this say lout us if we don’ drasticaily change it? All of Katte Prd sealked avy. on an empiye the first ime she learned about icvery. she s working 40 change with this ing she recognized (o be permeating the indsiry, That it Courage. Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Posted: 0241042612 8.99 pnt 10.2010, ezohel. an online site. plished “The Sex Teaffieking Mode! Scout” warning about the dangers of deregulated modeing agencies in the LS. Given the grusing number of modeling agencies that transport udecoge teenagers frum Forcien countries inka the United States and the growing sex trade of undecuge vies in the (1S. shy dots this industry remain deregulated? Since the advent of this husiness. modeling agencies have had fice reign to scoul teenagers from every state in the country 55 welh a5 Cvery nation in the world. Many uf these teenage girs come. from ceonomically disadvantaged families and see uifered none ta very limived protection while waveling and working os “model.” Jezshel pared that Joan Lue Brel. one of the cast of characters involved in the ongoing. Jeffeey Epstein (3 level I registered sex offendes). cight-ysar-long case. has been working Jor over two decades with a succession of sgencics in Now Yok and Pacis, According to media reports. Diane Sawyer produced a segue for CBS's 6 Minutes fealuring » sex scandal that eventually led Kleen Ford founder of renawned Ford mudeling agency) to stop warkig with Brunel. Brunel's latest vennure is the modeling agency MC2 based in South Beach, Fla. with satellite affices in New York and Tel Aviv. Since his agency is deregulated and “no eriminal charges Bove bec fikd by any of his accusers” — although many have tried to seeve him including Taviyers representing psiein’s viedms, Brunel continues (0 hide behind his French citizenship is » prevent depositions. “Trawling for 511 undenge teenagers uy work for his agency, C2. ar anyone else who requests. Brunel is free stout for very. young girls without limitations.” Given bis citizenship he also successfully wvoided deposition in Epscin’s sex rolated cases. Like 50 axany cher reportecs whe have ried to cepurt his side af the story when Jezebel contacted Brunel. “he did nal respand to qu interview request.” According fo Jezebel: i 3poke 10 & number of people who worked with his agency and while MC2 isn't considered 3 major industry player, it isn't exactly bottom-shelf. either... Brunel isn't involusd with the business on a day-to-day basis, although he owns an 85 percent stake fn MC2. Instead. he does scouting for the wgency and takes care of the imernaional rclations with ofr agencies, reports ane source. Sous sco she world far unrepresented tesnage irls wha could make it us models. They work largely unsupervised and are genzrally paid u headhunting fee fur every irl an agency signs. Even when affiliated with un agency. as Brunel obviously is with MC2, scouts operate masily independently und with lite oversight. The company blog refers fo Brunel as a “scqnutimg tsunami and MCZ i fairly well known for the strength of ts international scouiog; Model, Michael Goss’s 1995 book. describes Brunel's activities in Paris from the late 19705 nad, when be worked for, snd evenmually owned, the modeling sgency Karin, “Jean-Luc is considered a danger.” says Jéréme Bonnouvtier, “Owning Karin was & dream lou playbuy. His problem is that he knows exactly what els in trouble are locking for. He's ahwuys been om the edge of the system.” John Casablancas, founder of Elite modeling agency said: 1 really despise Jeun-Luc us u human being for the way he's sheapened the businsss. here is no justice. This i a guy wh should he behind bars. hoe was a ite group, Jean-Luc, Patrick Gilles, and Varsano. They were very well known in Paris for marking the clubs, They would invite girls and pu drugs in their drinks. Everybody knew they were creeps.” Cusabluncas was a. professional ival who was pushed oul of bis agency for questionable cancers. Katic Ford human trafficking abolicionist and Eileen Ford's daughter, tlked uw the ll Street Journalagazine, In tha: stor “A Model Trade Union.” Purd describes herself ss a “roving. aunbassador” to help sop human trfTicking, Ford sald her stake in the family business in 2007 to the peivete equity im Stans Tower Equity. “tn her new life a5 a nearly ful ime. wgald, roving amhassador for the cause her job is an outgrowth of hee formes work, rather than u repudiation of it. or an stoncment, Ter interest in human trficking began when a repuesentative of the United Nations called 1s ask if she would participate in & women's leadecship cup thal was studying the sue of tnficking. “15aid, | can’t corn talk about it, because | don't knuny wnything about it" Ford recalls. “Bus | went, and after wo hours. 1 knew why | was there, The way people traffic across borders is prac to the way we recruit models, According 10 Focd “the target age is 14. 24, and sa i's similarto modelitig™ 1 Knew how 10 reach that market she said. “It was the feeling of: There but For Ure grace of God... The gicks who cum to us could hve been those girls” El ‘hupifslavergtolay org/thut-gorgeons-indatage- ad-adel-may-be-trafficked-and-owned- regulstion-for-agenciessto-stop-child-sex-trafficking/ That Gorgeous Underage Model May Be A Slave: Regulation For Agencies To Stop Child Sex Trafficking Furst cume the knowledge tha slaves sill existed und were present in larger monhers than ever before. Then the realization that a human being could be rarchased within a few hours af my home for under SHO. Now only a five miles away. Tn the following years I've been leartitng; the myriad forms. places and tpes of slavery The lisi keeps lengthening ane! with vach new: form (to me). [learn about, it knocks me down, one more time. Slavery Debt ome Seva Savery Child Brides Forced Labir Child Soldiers Adoption Trafficking Organ Trafficking Trice Athees And now a new one I should have seen coming. Those very pours, freindly see? Some of ther eos ticked model scours who tterally trensled thrush some of the muss: destrsite ard vulnerable people on earth far the. The same method a ber prediony affickers Go t potato economical usable areas, incate 3°11 boautifiul orung tris: Guy therm, import them, own thems, see them. Horrible rom 0 hve mags hi portray 1s 10 the world psi be of ies, 44's hard 10 think of an area of wr society that doeve’t admire seeing it's niost vounted members with a model on their arm. While this observation does not imply tha those peuple were trafiicked, imagine how simple that owes it to approach a child or it's family anywhers in the world and offer then this in return fir absainte control Al the traffickers have ro do Is pull out a magazine or phone with videos on it. » Tor not shocked at traffickers using this method of promises to fure unvuspeciing girls into slavery, {'ve seen if read about it studied it. I'm in shack that flovrishes in the most visible, glaring spoligh of our culture, the part that orhips and proses ovr curent idea of baa in almost everything we touch, These victims ure on the mos! prominent siave block ever, emuiated hy aur children, coveted by our culture-makers and our society, and standing in the brightesy global sporlight in the world In plain sight, reported on i imerous stories for decades tr ye! only escalating in usage iow they've became the golden mere We can quietly ignore dhe oes rasald dit im our town, ho made our clothes, choclate. housewares, provided the 201d on ow fingers and necks, electionics in on hands, labor in ove fields. Here. finally. are siaves we fantasize about being, enrulafing, lie our society to be shaped by, consider rophies hat will this say about us if we don't drastically change it? Al of it Katie Ford walked vay from an empire the frst time she learned abort stavers. she's working to charge with ihis thing she recognized to fe permeating the industry. That is courage. Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Conch Sarnoff. Posted: 02102012 8:49 pm [n3050, Jezebel, an online site, published “The Sex Trafficking Model Scout” warming about the dungers of deregulated modeling agencies in the U.S. Given the prowing aumber of modeling agencies that transport underage teenagers from foreign ounces inlo the United States and the growing sex rade of underage girls in the U.S, why does this industey romain deregulated? Since the advent of this business. modeling wigencies have bud fr eign ws scout wcnagers fram every state in the country es well as every nation in the world. Many of these reznage rls come from economically disadvantaged families and ave offered none to very limited protection while waving and working as “niodcls.” Tezebel reparted that Jean Tue Brunet one of the east of characters involved in the ongoing Jeffrey Epsiein (a lovel 3 mgistored scx offender). eighl-year-long case. has been working for over two decades with a succession of agencies in New York ond Pacis. Acearding to media eeports, Diane Suwer produced a segment for CBS's 60 Minutes featuring a sex scandal tha eventually led Eiloen Ford tfoundsr of renowned Ford modeling agency) 10 stop working with Brunel. Brunel s latest venture is the morling agency MC2 based in South Beach. Fla with satelice oiMces in New York and Tel Aviv. Since hs agency is deregulated and “no criminal chores 0 ave been filed by any uf His wccusens” — olhough many have tried to serve him inchiding Towyers representing Fpsicia’s vietims. Sruncl continues to hide behind his French citizeaship to prevent depositions. “Trawling for 5°11” underage teenagers to work for bis agency, MC2. or anyone else who requests, Brunel is free t scout for very young girls without limitations.” Given his citizenship he also succassfully avoided deposition in Cpstein's sex related cases. Like 50 many other ceportets who have ied to report bis side of the story when Jezebel contacted Brunel, “he did not respond to our interview request” Ascording tw Jezebel: we spake to & number nf people who worked with his agency and while MC fsn't considered a maja industey player, it Jsn't exactly botrom-shelf either... Brun isn't involved with the business on a day-to-day basis. although he owns an 85 percent stake in MC2. ostoad. he does scouting fur the agency and takes care of the international relations with acher agencies. eports ume suuree. Scaues scour the world for unrepresented ecnage girls who ould make it 15 models. “They work largely unsupervised and are genaeally paid a headbunting fee for every git an agency signs. Even when affliated with an agency. as Bruel obviously is with MC2, scouts operate mostly independently sud with litle cyersight. The company blo refers to Brunel as & “scouting tsuaemi and MC? is fuicly well known for the strength of is international scouting. Model, Michsl Gross’s 1995 bok, desceibes Brunel's activites in Paris from the ute 19705 nviocds. when he worked for. sad eventually owned, the modeling ogency Karin, *Tean-T.uc is considered a danger." says Tértme Bonnawvrier, “Owning Karin was a decsm for a playboy. His problem is that he knows exseily what girls in imuble arc fonking for. He's always been on the cdg: af the system.” Jobin Caseblanuas. founder of Cite modeling agency suid: really despise Jean-Luc as a hunian being for dre way he's cheapened the business. There is no justice. This i 8 guy who sheuld be behind burs. Thece was u ile grou. Jean-Luc, Patrick Gilles, and Vaesano. They were very well known in Paris for roaming the clubs. They wold invite girls and pic drugs in their drinks, Everybody knew they wers creeps.” Casabloacas was a professional rival who was pushed out of his agency foc questionable concerns. Katie Prd human trafficking abolitionist and Eileen Fords drugher. tiked to the Ja Street Journalmagrzine. In that story “A Model Trade Union.” Ford desceibes herself as a “coving ambassador” 9 kelp 36p human trollickiog, Ford sald her stake in the family business in 2007 to the privete equity firm Stane Tower Tiquity. “In her neve Iie as u nearly full-time, unpad, raving ambassador for the cause her job isan outgrowth of het Former work. sath tian a repudiation of it or an sorcment. Ther interest in human trafficking begun when a representative of the United Nations ealled 10 ask f'she wuld participate in a women's leadership group that was studying the issue of tefficking. +1 said, “F can't come talk about it, because | don't know anything about tt Ford recalls, “But | went. and after two hours, | knew why Twas there. The way people traffic accnss bordsrs is paculel 10 the way we recruit models, According 10 Ford "the target age is 14.0 24, and so i's 4 similar to modeling.” Lknesy how 10 rach that masket” she said. “It wa the feeling of; There but forthe grace of God... The gies who came ( us could have been those girls." r) http:/files,wallstreetfolly.com/wordpress/2007/10/jeffrey- epstein-doesnt-want-to-be-branded-as-a-sex-offender-for- lifc-and-no-hes-not-a-modeling-agency-secret-sugar-daddy- or-so-its-owners-say/ Jellrey Epsicin deesn’{ wan( {o be branded as a “sex oltender” for life. and ng. he’s not a modeling agency secret sugar daddy (or so its owners say Pasted by WSE On October - § - 2007 = anne & '] bala \ i | Jeffrey Epstein, the billionaire money manager who's agrezd t plead guilty ta soliciting waderaged hookers and ga away for 18 mouths, does’ want o be branded a "sex offender” for Tie. Page Si. says bis luseyers are Uhinkimg about asking prosecutoes drop the requirement finm is plea agreement: To a eter draflc. but nut sent, 0 U.S. Attorney Alexander Costa and ahiained by Page Six, Epstein’s fawyer, Gerald Lefeourt, writes, "Doing 50 will have a profound impact (on Epstein] both iimediately and forever alter. Not only will he be restricted 0 a wholly nupproprinte pesal fecility, but he will be required for the rest of his life 10 account for his whersabouts," Meanwhile. aver the weekend Page Six suid that owners of MG2 modeling. run by Jean-Luc Prune] — whi's alsa been acew-ed of favoring imdcraged madels in the past — claim that Epstein is not the. scerce deep pockets behind dhe firm, ro matter what others say speculnes. a Epstein... .epomedly gave “millions” (o start MC2, which opened in Octobe 2005 with offices in New York, Miami and Tel Aviv. One of the girls Epstein, 54, was accused of soliciting massages from was described in court documents 0s being just 3. “E equals MC squiced.... get, Bike the equation? E equals Bpsicin. He just thinks cyeryone is too dumb to figure t ous” said a model industey insider, “He's a desperate old man that fantosizes and takes advantage of young girls.” “Jeffrey Epstein has an ownership or invalvement in our company and never has. Jean-Luc Brunel and Lars the only two parmers aad ownare Of MC2 Model Mansgeancac.” Wetfiey) Fuller aid, [MC President] w“ hatp:ww washingtonpost.com/newsvolckii-conspiracy/wp/20 1404/2 lieteventh-circuit-rules- Ta deOveryamOVe-Sorwart-onms-crime vim cight-achcast! Ihe Volokh Conspiracy Eleventh Circuit rules that discovery can move forward on my Crime Victims’ Rights Act case By Paul Cunsell April 21 On Friday le 11d) Cirenit nue tt discovery can move fone in on importa, Crime Victims® Rights Act case thal my co-vounsel, Brad Edwards, and T sre pursuiny, The nurrow issu befor the vourl was whether prosecutors and defense atiumeys could assert some sort af “privilege” to prevent crime victims from reviewing the comcspandence that lead tg a plea baegain. More broadly, the ruling means that the victims will have a chance to refum to the. disieict court and seek to invalidate a plea agreement that (we alleged) was consummated in olution of their ight. 1 bape that the case wil imately set an mporlant precedent that federal prosscutons can’t keep victims in she dark abou the plea diab that they reach. Lier ae the importa Fics. taken lor the 11h Cicuit's opinion: Th case case fn 2006, the FBI began investigating allegations that wealthy investor Jefivey Epstein had sexuclly sbused dorens ond dozens of minor ils. The 11.5. Aomes's Offic fo the Southern Disic of Florica acospted Fpstein’s case for prosceution. and the FBI issved victim notification leness to my wo clicats, mines Jane Doc No. 1 and Jane Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the prosecutors and Epstein. On Sept. 24, 2007. the prosecutors entered into 4 non-prasccution ugreement with Epstein in which they agresd not to file any Tera ch: saint Fp m exchangs for is gui pic 0 miner Florida offenses (c¢.. solicitation of prostintion). Not only did the prosecutors negleet ta confer with the victims before they entered into the agreament with Epstein, they also concealed its existence for at least ine months. Fur example. the prosecurs Sent post. rset else pth vithms reporing that the "case is currently under investigation” and explaining that *[cJhis can be a lengthy ptocess and se reies your canned piece hile we conduct a iorough nvesdgation. On June 27, 200K, the prosecutors informs my eo-zounsel. Hr Fors, ts Epstein planned 0 plead guilty to the Florida charges thice days later. But the prosecutors failed to disclose that Epstein’s ples (0 those state charges arose from his federal non-prosecution agreement and that thie pleas would bur a federal prosecution. As u result. the victims did nil attend the state court proceedings. 4 On July 7. 2008. Edwards and 1 tiled a periion alleging that Jane Doz No, 1 was a victim of federal sex erimss committed by Epstein and that the United States had wrongfully excluded het from plea negotiations. We also alleged that the fedsral prosecutors had violated her rizats under the Cme Victim” Rights Act (CYRA) — specifically het tights to confer with the govemmznt a be treated will Faimess, 10 receive timely nolice of relevant coust proscedings, and to receive information ubuut restiution. The United States responded by claiming that i used its “best offorts™ to comply with the rights affords to victims under the CVRA. but that the act id net apply to pre-indictmen: negotiations with potential federal defundnts. Aer Jane Dac No. 2 joined the initial petition. the district court (Mar. J) found that seth women quified as "rine victinis ~ under the C-VKA. The disteict cour [ate sejevted the ‘eon crument’s acgunon that the act only applies afer the filing of a federal criminal indictment. (I've writer 6 law reviesw article about the Jssue of how early crime victiene” rights tach im th eeimies! process. which can be downloaded bere ) Among other relief, we sought rescission of the non-prosccurion agreeient os a remedy for the violation of the viet” right. To make the case for such a emedy, we moved for discovers of the camesondense between the U.S, and Epstein’s attorays during the plce nsgotiadons. Fipsiin's altomeys intervened, arguing that Federal Rule of Bvitience 410 acd Fedérs] Rute of Criminal Procediie 1 create a privilege for plea negnliacians, haring release of the correspondence. [hey also argcd that the court should find th the evsterials ere prasected under the work product doctrine or, altematively, should be protoesod ndsr a nsw “comman- Taw privilege lor plea negotiations.” “The district court fist nals tha cs sion o€the ples gees nent was a possible remedy. under the acl. The court then ruled that we were enitled to taview the cortespondence. rejecting all of Epstein’s arguments. On Friday, the 11th Cireuir affine the disrict emits ruling that ws could re ew the ple cusmspondence. Atpp. 18-22 of its published opinion. the court concluded that ther: was no busis for cesiicting eotess 10 such corcespondence when crime victims have a lcgitimass need to review it. The court rejected. for example, the wrk product argument because pled discussions are not confidential; Disclosure of work-product materials an adversary waives the work-product privilese. See 6.8. dn re Chrysler Motors Comp Overnight Fvaluation Program Lig. 360 F.2d 844, B46 (8th Cir. 1988): in re Dow, 662 F.2d 1073, 1081-82 {41h Cir. 1981), Even if it shared the commen goal af ceaching u quick selllement. the United States vies undoubtedly adverse to Epsteia during its investigation of him for federal affenses, wad the inlervenors” disclosure of their work progust waived any claim of privilege. . The court also declined to recagnize a new privilege for plea bacguining, finding the relationship between prosceutors and defense attorneys dic nat ced special protection Asa lastditch effort, the intervensrs contend that [iI wore is needed in addition to the plain fanguage of Rule 410 to preclude disclosure o the eorespondnce o plains, it can be found 46 Jn the wunjunction of Rule 410, the work-prduce privilege, and the Sixth Amendment right to the effective wsstance of counscl i the plea bargaining process,” but this novel argument ails 100. As explained shave, Rule 411 docs not crea a privilege and the intervenors waived any work-product privilege. The intervenocs concede 100 that the right counsel under the Sixth Amendment had not vet attached hea the correspondence was exchanged. Lumley v. City of Dade Clty, Fi, 327 F.3d 1136, 1195 (1 th Cir, 2003) {1 Jhe Sixth Amesdmers right to sounsel ordinarily does not aise ntl hee is a formal commitinen: by the government © prosecute.” sul 4 a “formal charge. prelioinary hearing, indicoment, information, or acraigranenc.”). The “conjunctive” power of thres false claims of privilege dues nul resus the vorrespundence from discloses... The Supreme Court has identified several considerations relevant 10 whether a court should cecugnice an evideotiary privilege—the needs of the public, whether the prisilege is rated in the Smpecative for confidence und trust, the evidentiary benefit of the denial of the privilege, and any ‘consensus amang the ates, Jagee v. Redmond. ST§ US. 1. 10-15 {1996)—but none of these. considerations weighs in favo of recognizing a new privilege to prevent discovery of tre plea negations. Akhough plea negotiations are vita (0 the functioning of the criminal justice system, & prosecutor and tact of a ceiminal investigation do not enjoy & relationship of confidence and trust whe they negotiate. Their adversarial relationship. unlike the confidential relationship of a doctor and patient or aorney and click, waeanis ne privilege beyond he tecins oF Rule #10. See Jaffee, 518 U.S, at 10. But ie victims would enjoy an evidealiary benefit from the disclosure of plea negotiations to prove whether the United Slates vialated their rights under the Act, Mosing forward, his case raises the important issue of what kinds of remedies ice available for violations of the Criene Victims® Riz Atl. Ou complaint legs that, presided by Epstein, the federal prosecutor deliberately concealed the sweetheart plea deal they had reached with him to avoid public uriticism of the deal. | am hapeful that in future district court proceedings, we will besble ta prove that slenr viclation of she CVRA and then obtain dhe remedy of invaiidating the illegally-negotisted pica deal. Paul G. Cae t2aches criminal law, criminal procedure, and crime victims’ nghts at the $.1. Quinney Collzge of Law at the Universiy of Utah. Hefor: coming 1o Utah. he was President of he Stanford Las Review, a law clack for thei-Judge Antonia Scalia oa the D.C. Circuit and or Chief Justice Warten Burger of ihe Supreme Court, us Associate Deputy Attirney Genera with the U.S. Justice Department (1986-88), and an Assistant U.S. Attomey for the Fase Disrict of Virginia (198% a 1991). Cassell Joined the faculty asthe University of Utah College of Lave in 1992, where he taught full ime until he was swom i as a U.S. Disteict Court Jude for the. District of Utah in 2002. Tn 2007, he resigned xis judgeship Lo return full time to the College of Law. lo leach, write. and liGigstz on issues relating In crime viesims' rights and criminal justice reform. a ~~ Original message ——— From: Jolanta MODILINOS Date: 15/10:2014 4:48 PM (GMT+02:00) To: Jean Luc Brunel Subject: Deac Jean Luc. Hope that you slay fine As per our conversation abeut placement of her with you in NYC and Miami. she said she fousd some article in intesnel.. which changed hee position and she preferced 0 be placed with another agency. aun 50 s0eey, bua people believes in media moee thin in ws sometimes. what is sod! Warmest regards Jolanta Sadauskiene awner MODILINOS moat agency MODILINOS models. Paracas 7-4, Kaumas Sv.Stepono 7, nics (@WasST07I2E cal ATT069816103 Olanafimediizoncon: mlofymodinos com ww modiinos com EXHIBIT B From: "Viadimic Yudasnsin 1 MetherAgency” Cale: 711312014 10:48 Al (GMT~0200) To. dean Lox: Brunel Subject The situafion wih Liza Zazdaurih Oar Jeantuc, Unfortunately | need 16 ansouncs that Liza Zaasraunih refscisd Signing he contract wih MOZ United ‘Sates. nat sha intanded fo sign Ihe coniract, but ater on she came 8Ci08s that aici i lems aboul you involved in egal activities wih young models. This information somehow changed het intentions Completely. she s ready o be a model and consider contracts wilh ther agerckes, bul she has sussitions INat you wil orcs har lo gal actites and she made the decision o (On put her sel 14 isk. Lots kowp in zh. willbe happy work wit you 16 tims if we have another Tight made for you. Im upset hat i didnt work ut wih Liza Sincoraly, Vialimic Viadimir Yiidashic EXHIBIT C —-=—- Original message ——— From: Manuela - Mega Partners Date: 17/10/2014 9:36 PM (GMT402:00} To: Jean Luc Brunel Subleat: MC2 Dear Jean Liz, I'm very liappy to hese you're caning to the agency wilh Vii so we can talk about us working vith MC? again {don't need 0 remind you that the sex waificking allegations have stopped us from working with * your agency for dhe past 5-6 years but as Vinicius is uy frend, {will ey 10 ad a gil that alreaty kos and trusts him tw plage with you. ‘Thank you very much for the lovely bag and we'll see each obec on fashion week. Kisses, Manuela MANUELA W MARTINEZ Infemational Rekons Phone: 455 11 38184500 MEGA | De see smedear Cell: +55 11 38668.0000 PARTNERS | megamsodelbrasiLeom.br EXHIBIT D Original Message----- From: Lorraine <lonaine@mic2mm com> Organization: MC2 MM Reply-To: <lomaine@me2mm com Date: Friday, August 27, 2010 at 8:43 PM To: <jef@me2mm com>, Jean Luc Brunel <jeaniuc@me2mm com, Pink <pink@me2mm. com> Subject: FW: Press Inquiry from AFP {Agence France Presse} Videagrapher--ichelle Stockman N >—w-Original Message Fram: Michells STOCKMAN [maito:Miche le. Stockman af com) >Sent: Friday, August 27, 2010 11:03 AM >To lorraine@me2mm.com >Subect: Press Inquiry from AFP (Agence France Presse) >Videographer--Michelle Stockman >My name is Michelle Stockman and | am a video journalist for Agence France >Presse, the French newswire. We produce 1.540 2 min. videos that ara distributed internationally to broadcast clients in Europs and Asa, and >intemet clients workhwide. In preparation for Fashion Week, my print >colleague and 1 are interested in doing a piece an trends in casting models >of color. | was wondering if you could refer me to a model of calor and a >casting director who can comment cn her experience. > >My deadline is next week, so | would fie to set something up for Monday sor >Tuesday. | can come (a you as | am a ane-person camera craw. When you >have >a moment, please let me know. Id be happy to discuss with you over the. >phona ahead of time. >Best regards, >Michelle Stockman > >Michelle Stockman 747 Third Avenue, 35th Floor >New York, NY 10017 EXHIBIT E 917-533-3261 Su. youtube, CONVAFP > >Agence France-Presse Is the world's oldest newswire with journalists in 165 countries. We publish worldwide in English, French, Spanish, German, >Porluguese and Arabic. AFP delivers the news to thousands of media outlets worldwide from newspapers lo magazines, radio and TV stations and online services, It reaches an audience of more than one billion people daily. *This e-mail. and any file transmitizd with it is confidental and sinanded solely for the use of the individual or entity to wham it is addressed. If you have received this email in eiror, please contact the sendar and delete >the email from your system. If you are not the named addressee you should >not disseminate, distribute or copy this email >For more information on Agence France-Presse, please visit our web sie at >htip:ftwne afp com EXHIBIT E ——— Orginal message — From: Hichaal Sane Cole: 211202014 12:48 (CMT-05.00) To. Jean Luc Brunel Subject Soauiirg Jan Lu, How ae you? Aes 50 many years scouieg for you and having a great ence of sgencias ll aroun the world who enjoy to werk wit us, | wand o et you know thal we are on the way (@ lose evenyhing we oul and we aie gona have big problem now. Agencies, il war vo wit 1s Ut F410" ort WAN! hell GRUHITS Came 1.13, hecause nen hey Google your name and the agency name the only ings they see 's “Sex Traficking ll Its impossible to 39n # new l and f nothing i don 1 can el you the in 2 moths we we wil nt get any new gels end dont see fw the agency wil work withow: new faces. Alte agancies who know you con't have any problems wilh Yeu Siace hey al 0k] Me We Know jean Luc for mare han 20 yoars anc all Base years we hat so many ils place wi im wo 7d beter ‘oxparionco than in any othe agoncios wha wero roprasantin tom as well and we nese bad any problems whatsoever, fl our is had gfaal carers as a model when he represses thee 1 unaerstard those agencies bacaus fs hard for therm Lo al to parents and explain that fs nal the 1th when i al over the internet. ouneed la have ft stop and have the people write an affcialleter a say thal it's nat the uth. 1 will amp you peste of course but is really oad for us and the scouting Best regards Michac! Sanka 3104021028 EXHIBIT F a Sonim Bon M2 A ci mh il ty cn eta et eo Bnd a ne has wrk ih a on 0 yr ators wd evr sn pK Eaton neh as pbk. fe were of fe sh md sopra vei wel cd pts ow rr Bs we bv wench lk 10 pie dts hk ee adn md ofa: oy tld en J ing ot wie sw Twas rs ples 6c Be wt aod 50 gta 1 aT ofc for, 1s cn we ct ple ye oc EY 203 eto id ches 5 ik Bl ee 50 a ewe sr et rel poche 1 we wl Bs rc oe ose 1 0 Rc 5 Wo Bl e—— Saralaie Toon ages roman EE] ToS 4 Se ae SOE EXHIBIT G L 2 As part of your suployacst with MC Square 2 agen Vive in New York, Toy a tine? 3 B I'm snary, but I taks the Fifta, 4 © Have you ever heard any model of ¥: Square Sw at the time of being a minoy, that means under £ the age of eighieen, meds sn accusation that 7 Séan-Luc Butnel acted inapuropclile with hes? a £ Fever, and that is scnething that I will © not anawer. And T sald never because even whem 1: reoples come and ask me T will clays sey the trath 1 regarding that, 12 T know Mr. Rronel bor the foagest -- 17 maybe wight years. Aad § always sald what 3 kw 14 © ever saw and | weve: knew thal be id aoythirg. 15 S55 1 know that. Ard that's the truth. If Newer. T reve: heard anybody accusing Me. Bruce! 317 or complainieg about My. Brunel. Herhing 12 @ hat means -- Ast means at any time oi 15 model, no minor model come tn you and sald, you 23 keww, "Maritza, lech what just horpemed to me”, that, 21 "something had teppored to met. 22 A Mayhe e model came and told me, "Maritza, 23 lost wast happen 5 me. 1 don't have any money,” of 24 "1dcr't have a place ta liven. Or, "Lock, T didn’t 2 get my tieket”, ur whatuves. EXHIBIT H-t IH 2 LE TH PERE we sp— a ar ensuastances. © true oan: 5 3 We yeu sak: Refers That yun never heard 5 angrhong thet wend fndicats that Jean Lac Zurmsl Teed dnspaopkiately ML co will any medels, 8 eupmeially sng wien mele hal BE Biers may Have a has u Iv that sarmeced a 4 veah, Lomas wnat is the tzin, Mabey 2 complain tome. Nekoly Your Juection wac very 3 clear, zac any wal came Bu yan ere cnplete skal Lo emdy we Kaew, Sued wilh Bausel 5 3 mia % Bek my aneuer was mi Nehany ame ve tal © me evar aww. reve: knew. ig Fersonal Liza Ban no my pueden a 4 Tu gon have acy avtunl ke ubedge, tab 0 ta ay Ras po prevent vi did yen ves wlth yaks oa Teen, amy min msasie gn eich dean fee iced <3 © Mette Frreetnta yee, oo ang panty of hiss a HEL OBRINT: SLyeetion 1 TEE WITHEGED I mater, far © vake the EXHIBIT H-2 COMPOSITE EXHIBIT | NEEL CARIN CORE ab Tm LS IN enL ORCL Tb I A he OAT i a CA. fasting i ) san Dian Lo, Pre — CED KATHE NDE BLY, i Aare 6 ran a apain ah A eulan 1+ we. $m fc mia 1 phd gum Fo 1d Srna Tn ThA ust) BA {A CAA Ft EXHIBIT | a consemor maven atin ait oe, I Ei filed Vstyues by we | wo TF vad es a me i Ef EXHIBIT | EXHIBIT & i LED Bo 08 MAM CALCOT Hote, TALL TM dm fee— a ) EES 30m arm Tr — An Temas a. cota ev wwe ors RT rt a 1 or oA 3 TS EL Wr ig i ad fil a, ge e+ Y gr Ln - SETTERS LHR es Lol ” Nd aes Ta oe a DETIEN CI les CTI a Ti RC ——————— RT WG PEL) IE I RTT EE PM) | i alle fenpliiin 0 sie vee I eeeshos | EE a ERT EL AEN TYIC i tn a a raat oe he Tr tet smiley. | worse JF aw lat wr pd bi “rua. 9 pad bao EXHIBIT | COMPOSITE EXHIBIT J - VISA mmm Lr este st Ante DE a Er Sh |B I EE IS EE SR ws Sn ETT ime SE semen a yee tr oy SE a wa SUPPORTING DOCUMENTS EXHT1 Saad pres arc mei Gries documenting fe me of South Seen on ono of ia nied Sat mn sho Comma BRAM Pren aricins iagarding the mos and aches wha vere bol Coveied by and CurBes were lunchad by Th BANGIN. Mah {oc rune. BAITS Saved cco egorcing ne eesizous eoutahon of Kees oakt nomen ane log werk 30 3 GAC EXHATA Aol of of MCT css incicang saver nights compos fonlem some of MC lomion mocen. Gb rh 0 ei Bast Chop mon i as iu Gr sate mode SGencs EXAMS he bemwiciony’s Joon Luc Brel, miner curcum vie Velo Hi Vamos Cop anTerH Bain 16 1900 ond ose nh, EXHSIT 6 Seva rics egorang ihe 2008 Mocieh New Gansiaron Corvest {chung boric) 01 a 10 Banal 5 ANG 136 win i prion modi ovens LBB Sevimol ems aici seven nm presi 205 Mode New Goneraon Gorvoetilon. (neki rarvarom) ox wel ot ihe Benelio's ncn Lc Ms 0G 10k nn ie Svat EXNRITE Letter af Ciouio meio, Mesdant of Moder. o racemes moxiaing ogency BI Er — Managemen. ERHIIIO Sev pras crim retioc ir 80 rose ard gh crc salon les 51 nl rhoionac ming nc pach ACh hove lore 37 Canara hm min avers anh Ihe bemofcia. Jeon Loc Erni hos raat rough he pecs: HII Ffermoten regarding he oxpemely succantul ona sresious raged ne osnen Griocialon meroire Mode Toa Associalon [UATA). MODELEMIAMI ys, 200 "Deporiment of Homeland Sacuily Urled Stakes Cian and immigration Services Vernant Sevica Center 23 Houghion Sheet Sola Albers, v7 04478 HE 1129, Pelion lor @ Morkmigiont Worker ©] Ettaciinary Abily 63 am A Boches and Token! Gocrdinclor Potitonec WC2 Modeh Mian, LLC Beneficiary: Jean. Luc. Didier Menetfarie SRUNEL Deor Si Madam, Ine peesent teller ond ls enciouses ote suomiect if: support of the gitechod O-1 peiiion of MC Models Mian. LLC, on banal of vi. Jeon Luc Erol, hn pskion i based pon Mr. Samer standing os an “Aken of Exracerinon: Abily in #41 Diection 06 Talen! Coorcinaiion * Kindly nofe hat i. Bure! cummny huis O-1 slofs with ow organiiafon, The Sou Foc exda and Miam Beoch in pricy have become a mecca fof Ne tothion ard modu Indusiis. AS ecul, mony ol Ine agent inlemotionol mocising ugancies such at Ford. Ee. ord MCZ hove opsied ces in South Bedi and the oreo has became ane of he mas! porn! 11 {se modséing ¥custy In fact. Avani Boach hot become second only 10 Now. York Ciy in lars of empioymac opparhuniios fe fasion mack br he ved Slates. Atlachert 05 EXHBIT 1. pocss nd sever press and mado acres ‘SocumaInY he is of Scull Beach as cae i ine Unie Soles mais imran copicer 199 aur company. MCZ floamer Korn Mocket). exabished an office. tne hace of the atenc A Paco Disc! af Mom Baoch, “sou B80. nay fly boceme one of the word's modcing capo and we or pgased 15 be 8 Pot of if Ou agency hat developed & Mghy daengushed epatascn i 1a. modeing ricky We tpncciae in repraaniing numeious modes of nleinalionol acclom rieviag dacoverad foces tach at Christy luatngton ang oided dhe carmen of cwebriies wah oF Sharon Sone, Fileka Woven. MBG I i + E7233 ste 43 + mb STZ 0 E851 KU + amma 77 372 + SVS Javevh, say Hall and Rebieccs Romin, who cunently sang fhe ovcrc- ~anang ABC leiavtion sents Li Betiy, MC2 modes wi among the mos 1ought aftr ne incur. 3 svdonced by Maa caliber of hey Commerc red €SIoal books. Many of our laihion modeh have roced me pages of tascing lashien mogasines oi fu Unilad Sioies, Ewope. Lote Aric. Ala, ond Alto sen Gs Vogue. Teen Vogue, Ele. W, Glomols, V, Mcvie Clos Sitoce and Coumopoiion oa wed an many mora Ihioughout tne works. in oddifon {0 our Wom 880ch office, HCZ Medal no» oices m Kew York Cily ont Tol Avr, wast. As Aric Dsaclor and Toten! Coorinoor or MC2 Mods Mam, ILE. a: Bunt vil be (esponidia for Crersaeng (ho ortsic cipecs of ihe opency, ty ‘veneeng ihe arf ceparment i ihe agency A. BUNS! wil cect Ine wun aneing of Ihe mogok 1 Cian focuEng on no images plazed on bor he odes compote cords and thes porloios. Sol of nese Mo¥enng lock de aucial In morketng ation mace a Ihe coppice coli. edict. of macko chan. As Alalic Dxecr and lolent Coordinglr. pM: Enel wal thio ZEinole 159 palm of taifan modeh wih o perlictior phologropier Cents for fn cgency inciuxfz © mid of fashion Sublcaans, elo yore, conurmer produc compares. and [oshiar: houses 16 ham but © kw. Recent of fetened art pholograpnen who have tn cace ent unkderianding ul ha im. an oul” of ha modeling ann Ioihon may & Grice 1a he weceuhi 10g Of © 10 rorkeing ogency such on 1AC2 Moda Wi. Brunel wi dio Confae wiih hs amazing Wack record of decovemy 8 wokd's gOS! lefents ord DEGUNS = cider fc Qn hem wih MTZ Mode. Hs. Brunel wht Conlinvg a havel eround Ihe works looking lor new folrh. and fo gence 010uTG 1h werk in ore to aslo rekatonshios wit inca agence on ow IMC2 Models Ma. LE 0 Tapssent Terme: Ins Uviad Si0ie Me Buners cupresiva uaicaiom ai an An Decor awd Seni Cooomolor, estou ekptly as lo fe teguinlory Yandeads 1x fun ‘0sResion a1 @ lop Crolesonatia hs he. Mr Sel meets the O-1 caren as an nivxioal of ealtucreincry anil ihe Ars Gr Enarianmant Bek? os wed cr 9 twine enfrepianeur MC? Model Miami. LC & prmanty seatng o 30DREICGTA or CEC {of 00 Malo! COOXTNGIY. A tEvewing fw Extrgmnce Gnd accolades. we oro Conjent hal fhe bensheioey. Mi. Jeu Lux: Buna, wal POTION SO ic on uth GUNG is crc prctassnlm. LMR. BRUNEL'S GUAUNCATIONS 45 THE BEHTACIARY. In ackilon 16 bon uc Buel oxlenive Buisess auolicotions. he {SavBet a on divickol wilh OIE vaton anc cragiive ialenis Guclfes hee oh on O.1 Aen In Ihe Att on Enferioinment Feld 1 OY. arcompan eR SxpSnece 4 01 t Director Iain! Coxeinotor. intemmalionol enbepreneur or buss. ood in fhe mixielng. fasion. nieroirment, cutee ikikors. aan, and audi Incusiies hos made tr Reunel erally renowned in iness he di, Among a various occomplenanis IicuGhoul Tis coleer orm Ih Succi 0aeing agencies Ne Nas ounded bon Eau and i ine Und Soles. For examglo. io 1976. Mi. Banal Iounded and grew Kain Model Paris hor he ound Up 0 become a lecdmarkel agency wil © woidwkie praca Contueing G 5700 morkal shorn in Poss, wi, Brunel succesuly Creotod Kern ode’ 63 @ patio or morgue clients fo clon sophskealad pobk: rakalors services and impcian modsing conlroc cpporkuriies. M, Sumal’ aceon £403 30 97601 wilh Kerr Pa thal 1 he nox] 60 vac. ha founded Has! Madi Moncgament in Los Anges. Collrnia In 1980, Nexi Made Honagament in Mion Honk: 1 1782. Mode! Manogemeni Group otic mn Miami loi in 1986. and Rebecca Commercial Casting in New York Cy. = 1988 The fatter cng wos ‘apened of o olert one casting agency fo pedoimors. ofsang varices sek on voe-avers felevsion. ond cinema odverling work, gain. succentuly caning i 0 riche by which 1a make Nt mak and aires boc Commerc: Periarmonce tevull AmGugh br. Brunel kates soi 4 igh To Nex! Waragament i Fon Kalen in 1987, who porineced wih Josh Wikeaeld 0 couple of years falar. NOT 195055015 SOME Of fhe ms] prestigious weemen nd men in he foson wor today Stor talent ches renowned lashion modes Maly Sim. oni Peslove, Audiey Quock. Yamia Dit, and Molgotia Baio, MEX! conlinues 10 mainicin on nflvanicl intematiora kore in Ihe oshion ond madeing indUwY I¥Gusth fs uy Goer anc fives in New Yesk, Los Angeles. tom, Sac Movi, Maries, odor. ont Pass. a wel us i cffiotes in Akan ord Ausholi Because of siiong 1evenoe Gown an success) busiios perdcrmance. Gres! of is Gubsic viaon 03 on arts recor ond ioien! coca Me Brune! Faundad he vary success Karin Models of Amanca In New York City ond Korn Madls WA 0 Mami Seoch. M. Bruner’ cotvnercid venies i: bering Karin agencies «1 Para. Naw York ond tam hove baen exioincly succes generciling Combined onnud revenues cf Sweuly hee 135) Ten gokas. Evanlunly. Mi. Biunol kesmed the Keun nora 1a 0gencics 1 woe) Canna. Geran. and Span. Mi. Bruel’ estcdnory iank ore cof only 17166 10 IoUnching success modeling businesses. bur 046 i discovemng ora UNCing ihe Cicer of soma oi 15 welds mot weceasshL matish. tr Bust outs unched fhe extremely weceish. Coreen of spermoden such oa Chidy Tufrgien, Rene: Kuler, Shuron Stane. Mono Beles: alc Water ari Creinn Semonnoviya. Thess women oll piocesdar 10 become som of ne most PoloaraEhed anohor cover model; the won appeoAng on IPOUSNGA Gi MUGBNE COVES vive 01a SDCATING MAY YErmE. Al 6 -esut of 18 wepulGian 05 0 Ng wisbla, sWolepc ramane: who caves and Orch 5 LUNFSS 1 SHG Energi men] and beakers c1owe 080k many ap plays in “he fainon and enledtament kd roaueNBs hal Ww. Sime lunciion gs inet exchutiv asienl ore (upkesaniohve, Som of Hats top IoATer ont presen rofessicnal wormage! In ta famion fais cludo. Neom Campbel. Chity Tuingion, Rebecca Rorvjn. Aa Jovanovich, inex Sore, Meatarie Thieny. ant jany Hol. Atlachect af EXHIB 2. pleco tid press oricles mgording Ms maciel cng acbesaes who were both cscavernd by and cosas rato launched by ihe Leneficlary, Joon Wc Bunel. Addtonaly. aHoched gz EXHIB 3, pase 15 soyorel crlcies regarding nw pxesfiglovs Epuldlion of Sani Woclel ot omer can of the wor leading Oganciss. Mort scent in Ociober 2005, anc after his reign wih Kann wiodek, Wr Brunel bunched Tia esis MCI Mosel Manageran walkie i offs in New York, AOS Gnd Tel Aw 1 tune iarlad Ina High peafie C2 Mode! wGnogerr en in ordi Io represant high fost madels A & boulique gency telitg MC2 Model Managamen i okeodly being taucec by hon nsicrs G1 “ore of 1b hotles! agencies n Norn Ameskca® a: wel of “arorinerly posiined 10 be Gre ol th major payer of he 26tor bacouie of tid rearorkhins wih ne most infletiol photographer around. Wa Eile YO 10 vil rormanc Zn om outa to whe he high-celiber of mosh, MC2 reptesecls Some of ils most iecon! success booking: inckide Lis Dos aciuive conlioct a1 me lace of the Fal 2007 Gueks Campaigs ard Sammy. Jus Gaver stat lor Cesmapolfon Magee. Aflached ar EXHIB 4, eos find I of ol of MC's canis, cheng sevexdl hiphipeciie campaign: fagiteig 50m of CZs fa¥hon modets os well as severed pram Clogings 1ogErcing ny Prashgious ang isputable modelr; ogency. Jaan Luc Bonel's en'repraneunal ssi a riot only cantoined fo the tid cf axis baguly. oad fomon =n 1970. Gs G result i Ns business wail Mh. Snel founded cra grew Jean Luc Ration: Publius, wihah speciaized pass ond BUMCions Io fou apeloion and estourans Hance. Owing hls werk ivough Jean Luc Reloton, Pubiue. ML Nuno! iervasentedt varus key cents on colaboraled on numein piasiGious ever, Some of the preskgious Evenly wislurl: Ai Toul tnd Bore Veyoges. Jacn Luc Retalions Pukave ais promoted ON MOIkGIG Lo Toar I AIGEN. free 01 ruslaurant owned by Coe Toros ona. “The Gobelwesr, 3 MOR pice by George Lovey, Olher preess taken on by Mi Bunal ivugh his public rato: company wos ih Wolk an voruct agent for Jeon Cloucks Ky. 1965 Winter Omer Gal Mecha et 16 promaty Vai, Calan in Fence re “oursm polarlial ano oo drected a. of Ihe DOTIDOn or Finds Winisty of four. n 1975 Mv. Bniral rire ivesledt 2 ha Fane and Hospalohy sme! by Ciacing end cevaki El Aono Detuuigg”™ a legendary. nighcnd Bar 01 Me Hern Persia, hs bry was known Ioughou! he peainwic as etemely mickive ord Gmacied ob colebiiy Clwniele MO! irciuded erkes, Lisvio Andes. ard he Duchan 0'Aloa AfoGNce ox EXHIBIT. pias (1: The bunalcsy's. Jer 112 fame “paetive ucuum vice veriyig fa Wemandous accom plement i ball ihe loon crs meeing incusis, LLICIBATY EOR CIAMINCATION AS AN ALIEN OF EXTRAORONART ALLY I HE ARG Undiar ihe Macelnecu and Tecivica mmigoton ond Nafonaity Amanchenh of 1571, cellons lof clasfcakan a an Aven of Exbecrieny Abit 21h Al m9 Le supped oy mvicenca ol "CBILON" Accerang tah CR $214.2(0/(3l. “asfine lion” means © high level of achievemant in the fied of ori a1 evidences by o horeo of 5B Gre 1ecog ion slant abo nat inary Sncouniered Io Tne er he! o person dorcrbed ay provers Hs renowacd, teading. or wall-known In the eds of ah, Thi avcinch may omit of pact hl 1 Glan sl BS (6Cogn vc on being prOMinont I le 9) endochor as damerskatea by he ohoung. recy 10. 8 SF 204 203i: A Ecco tho ha ben hos bosn naminated foro hes bes he ecient of SgrAcan! nakonal of intenallonal avers a ites he perteuior Bid soch 4 on Acodety Awerd, on Emmy. a Graminy, or a Dheeler's Gull Award a 5 Aricanttives of tu tollowtng fora of documsriotion 1) Evidence Iho Ine alien hos performed. ond will parorm, sarees os o aad of tering paiciponi I poxdcions vor wn howe lngushad wpuloon as evidenced by cleo fsiows, Svertiament, Publicly recta, publications camaro andorsameri: 12 tkdonce iho the ose ot ac avec notions! o nermatorol tecogrton or achlevemarls erkisncad by cillcal evi of olher Pubithad mali by o about fe Ichvcuc i mole nevnpopars, ade fons, mogadne, or vor publcatons. 3) Exidance fnct ha allen has performed, and wl parr, lead. sfening, or eicai role Tot organization and ertabiyhesents bol hove a lsinguiied sop daton evident od by art< at Powspoper. rod Jaume, pubicatian or festmonials £4) bdance tha tha abe ha a record of majo commarciel or crcaiy ‘ncclolmed soccatsas os avidencad by such indicclons a We ong ‘shancing In the 1okd, box offic o receipts, meon picture or lalavition raings and other occupaons sehieyemant raperod m rede fours, efor newspapers, o aver publications: (5) Evidence Mat fe aken has cwcaivad signiicon racogrtfon fer ‘ochievomands fom arganialioni, eics. government agenclas, or olor acourizod experts n the Seid n which fhe alent angoged. Such Hesfimorials most ba in fom, whieh elecaly Indicate: ho authors ‘uthorly, expense, and Knowledge of the allen achievements, ot {8) Enc tha the: am has sliver commanded. high sei or wil ‘comand a hgh solar or ofter subsfonol remunevehon ot services In allo fo clon bn hi le, os evidenced by contract or cihar rafable evidence: or © he cto in parapmph (SXS)(H) of is secon do not ready apply fo he beneficiary's sccupction, he poker may wb companabis ‘wridance inorder fo exiobih the beneficiary's esl. EVIDENCE [HA THE BENEFICIARY MEL AT LEAST 105K OF THE PRONGS OF THE ‘CATER A UNDER SUSECTION 3 The fal orona that ne benefcory solfies 5 § GFR 214 2(oNSNMNEN)). WANN 180s ovidance Iho fhe olen has performed; on wil pero, servicos a1 0 lsd o raring pariclpant in productions or events which have © Siingulahed repulotion or evidenced by calical tees. odvertsement, PusBclly releases, publication conbicts, or endorsement. 513 105 Gf Ms Brona¥'s Combiand experi n lotion and foun, fo Sesued lo creale loin Mage! Poece's. now ncuron Models New ‘Gareralion to cross amos those key indus win interna! nol nas! end invesimen! oppor asic. A. Bunel as pomaled ond cud vriees Modsing corfu Iougnout Seu Amico clung moaning const Nogec 1 Eure: uch as Peru, Ec ado, Brad, AGO. and Chie, Concanved 1907 Ine Latin Mcciel of Ihe Walk: een wos a ngand mogeing ond enteianmen trou] 1a Oped fo upscale MYaMalora' Gudunoes AER neat 400 “an Idlomon waves wcddwide Thaughou ne Wie Gf 8 Ar inketraliri ovo pomCie: and cr: and ‘olan Coordi, Snel ha uschostoles muh ocoled puke realms, acertsing and mec campagns rel In onparaled llevakon mogasnGs propo AEE, and cer one Becomes; olobly WGIGRG for von: major beads us © moka fool Brunel's orule inoweddge of mortahig Gn proToRG BS hes fac hs vorious almOIncs Bees io gh Suce esl lic and bxaness ventures fo venous moje oer Lav, Model Pageants siocled macs fonds 51 spenson wen ox Amencan Atines, Ray-Ban Cara Colo, Frock & Garde, ond Ravin W: Buneis hes continued I wrlras as bo o promoter and panel #4305 when ha founded snd created hw inlemafional madning contest, Models New Genesalion lia! look praca n GLOYSAA ECLOSCE i F004 Hs. Brunel 1 on @ ponsl win free oiner peolessicant in 1ha fashion wxdusly ond iuddged aver fay mine young women hom over North ond Soul Amica. ApS. ‘and Europe. After fen doys of hash compeklian, Jeon Luc Brunel crowns fn winner Alyna Veber. a fifsen yaar old bem Bail wham ci dt of Soming 11 15 Place was worded ovie IHop hundied housanc! dolor werih of mated ‘conracls. “ha cit nf GUOYOQU. Ecuador wor els frown inka {ha inlemaliandt spolight 0s In hos cily far ha meceing contest. he todas Maw Ganarcion was broaricanied on numerous relevaior nalwork channel cluding. Fasrion V. which lions fo over 202 counties ough Ine ove. ho snire Assocation of Tnlevmon Channels in Ecucdos, Holorel Taienaon of Cha, an Rede Globo. Bad's arges] and mos) popuic lekeviion nelwod. Aflachad ov XH 4 presse fod severct oricius ragording The 2004 Models New Generation Conteris well 0 he banchciary's ‘sading oie whin th EEIg0 rodeing oven. £5. res | Ihe hamerdous success of the fl Mode Now Generar: thes 20k place In Guayaul. Ecuador in 204. i brunel arginine second Moric! New Generalion Canta which was hel in 2006 n fhe Ecuadcrion ‘copliciol Guta, In cre a select only tha very bes! new mode savers prolmirary” cuisiing ows were held in laren CURRY of Lin Ameca Including Boiwia, Panama ged Pas. Tne noi contest was hel 1 Gute, Ecuador ei fle haloeicol Poza Sor SONCECo, Me Brunel 164 on part 11 Ie other EGlES0OR in In fashion mdusiy ond fudged Gver lory-arat| young women torn fwenty-exghi claret courdies fom Norih ond South Ameo. Aus. ort Euicpo. Aer fen or of haish competion. Jeon Luc Brunel crewed Ino loner. Ginto Lupino. cn wghicon yaar Fam Lotvio, whom ot 6 rej of 20mg i la place wo awaaded aver Ihee Furcres fousand aka worn of ouwing Contois The cay or Aula ECuoder ws aso reown Inte he era ona spog 2 he nest aly ‘or Ih modeRy Conley, Aga. it fe the irr anie meds €xDONAE Guan 6 1 fn! Afoclels New Generolice, compatlian of 200%. ‘he 2005 Moin’ New Guneichon competion woy BAGO or nubrous Isienisn network clrannels eeluckng, Foner 1, whch tori 1o Gyer 252 Mlereal courives hioughou tne globe. Mix snive Associotor. of Telanson Charms 3, Ecuadc Nalonol Telewsron of China. and Rede Globo. Geai's 10GO 01ct mos! popula tose vaion newark. Atochied os EKHILT 7 cleo ihc ever press vices regarding fie mosis 2008 Mores New Ganeratn Compaition. 0 woh a ha beneiiciy 4 Jean LC Enunel leading oie va Ine svar. Tna 3006 Wodes Hew Genergion Moa wes broadcasl mn over X02 COUN Iu ul 1 woAd. M1. Bnet hos Gerract onc wil ost dain, contium ta pasar: sence a a ieating parizpan! 1 madeing evenlt Ach have @ didingaished puiofion ond wi bang more FUE wiematondl igh! fo MER Mods. For the Qos meno reasons, Ml runes sohshes NA §214 Zoli 8101) The second ona Wot ihe benclocy sola 4 § GI S204 2NINBNEL Wisc 16quies ovdonc hal The. clon hos acHioved meflonal or inierncliond recogeifon lor ceNevimesh evidenced by crivcal reviews or cifer publisned matariols by or about Ih indhddual in major asapasen, ade journals. magsains, o ofa publication He Bune! hod on inleialions! reputation ©) G vide, sreleg Meike! ne ake 0 CLTVTIe open ekaontis monogEmeN! Sk 1 cues 10 Cont Busing in a globol envroniment and broker kicrolve mol. Mi Brunel has 3 or hairy ih kg anc ociverang mor oon Campin Tvoughoul fw Neoby-fve yur covcer in Ins tan busners, fo Bunel hn devakoped wos sscisive moray ond cosmele compan. Smo of ee opr Somali campaign nicks, Bo Them wih supermodel Be McPhencr. PHAS wih Pebucco Pomp. Cheston Die wih Crasina Somonriovihaya. Mage! Asc wi) MoE Balkucc, Crane! wih Panic Von Rckenhwin. Angel Pacumo win They Muga. and Cacheres Pariume. ih ida Bafesiio We Bruno nas GHG developed mag KING Campaigns nd has devmiopen compoges and exciyire COTKOR wih som of the work's 1op Io4rvon designen such a vet SI Lauran, Chanel. Chesian Gor Goce. Poo Cri Mo Jacoss Peose se Tha enciosns rer of Clubs Mickle, Present of Modem, & onawmed madeing agoncy EXHIB § A a scdert Coonnates. Mr Bunal’s suc Cor 0nd shoud a be. M=GHed ih Ine CCS GarERS 1n8 Model. whose careers he knuncherd ove ace M4 violed hove, Mi rumet nos drcovered ond septeanied VOrius wpar mode Meoughou is career. Chily Tusagtan. wha. wa coved Ey Mi Buel tun peisoribed urallecied Doauty. repveserien Gale, Sorts Hagiaricen soc 190) Langton Of wel 0) onoher model (Borers by Wi Bunai. Noomi Compe becomy os af Tha lew SEIMEI. WHE MOU cum Gn way hanson fom he have glamoin of he. 1960 in he refarad spicy of the lowing Gezoda. Tecusho! her Exierave cores, and ob G tes of Mi Buel s “Far Savy Eve” Crety Tutor 41 Groce) ne coven uf hunches of Tower. magornes. wen Commonoita. W. Vogue. Shae. Fines Ere. Sata. Mi Clove. Homers €raure. and even fine Mogae, Please ste Ihe suciois lebor of Ala Among Dechy of Figera iiemallonal Managemen, EXHIIT?. n uddikon, Ihe modsing evoris hol La kanal hos been cigaNEG ffroughoul he: veces rece nol ory nolional. bul aso mlermatancs aifonton ‘ond oppar in mule pubkcosom around He worl Gna of ha most facet 460K ho organiza, ha Models Hew Gereroiion conles! which 100k place 1 Fcunrier woh publicized ond samsmiicd by verous lelewion netwerks ond cppacred on mulkie newspupars ond mogazines. omorg Mem Globo. Tefavixon Natwerss in Ba. Fashion 1 which & broadcas! Info 202 cauntnes Iheoughous the ves 4 Linens, Coss tar Roron. & Dicro. & Telagiofo. Notnorte Ecita. Hoy E Gran Guoyoqul H Cometh, Semone. orci 8 isms fo. nme o Tow. These mojor pUBICOIoNs Nove d Ke sbtongton rote whieh umes i Iw ary mons of readers. ANlochad as EXHIB 10, © ears G10 sven preys crfces riflecling Ine preslige and Nigh ckelion rales of Ine aborermenfionad magusnes ong pedocicals wch hove feaiued and Covcio0 tha modeling evens in which a banatciay, Jeon Luc Bunt, has gorizad throughout ie yaors Hence the beneliocy sulafos NA 5214 200 BIMIBIR) for having ‘achieved nal only nana: Bun a1 ReMaINGI (cognition 1 achievernees 18106 moduli ndusry. by NOYING 1a WOrK Pubishad 1 mcy nEwipopec and mogaanes INGUGhoUI Fe works The Jhitd arena Pol ih bonelicry sashes 4 CER E21 420MABIA) which scuias evidence that the clin bos 0 iacard of major commerclal or crfcoly acclolmed successes os ayidencad by such nalemors ox Ie, 10g, staan in Hw Rok, bos office (csipls, moflon piciwa or lelewsion toings, and other occupational achieves reparied in rade louns, malor nawsppen, ‘or slher publications. Ore of ie man reasons hot Hc &runs has Leen obie 10 nol onl survive. But 650 be exliemely wccesshl in fe ever-changing wad of loin i hit Uy 10 only 090 cul starauailly faent. As o sul of hs oly 10 scout oct “alerts, hk. Brunel ws wie 0 become member in ane of ne fashion lusy’s mest alte on impevior: oxoc fons, The Wnlermokonal Model Token Asiorfoin Ihevenallor BATA) 15 TATA 5 Gn miEtrional asiaciion of rang cenien for maces and 10 ant. IIA Gives aspricg modsk. ocios, dngsrs, ond Cancers specioc ior oppatuuslies 1 showcare Ina poll folens m Font of ion inher ona fotent gents fiom ihe moral Markel ol Ie inlew alone ostror indy. WTA also pionides is owociaton member voluoble mcr ekg 30 01d Hwa, re wil EAs 8 eels om Ground foe work SoveroI of 15501 Up ang com OCT Oi models hors ben dacavisa al IMA; 500m of hos Ghooes clu woTd-anownad alors such as. Hoh 3oacs. ANY Kulcher Kalle Hoes. [va Longo. Jessa bel, ond Seon Wilkom Scoll. Aflached an EXHIB 11, pleat fi inkmolan ‘spacing Ihe externely succents and pestlous modeing nd loshion ossocialn. MIA, Adaiicroly. please find soverct pogas Fom WATA's ofICiat webs a documenting Inet Secovery of tho obove menfaned Ad acters ona. ociieses, Whose member in WTA peoved lo be fhe Kurang pad far vir success ont High prolate coreers in fe im inhale Fuhrman. as previously menlioned, Mi Bruner hos launched tho SuCCosA coeess of many miamolionaby renaaned modes, nba have teen Hearne or hi 016 m oy Inkeénaliona ong national shan magazines. In addon, Te commcial venues. especioly MC2 Model omer Ken Mock. 1ave boon sxremely sUCCEi GENGOMS COMIGINGG GNVol evanuBs of Iweniy Ive 28) mfian dolor. Curent IAC2 & 00 of Ine most wk cessl onet wekknoun modsiog agencies in the world. vi. Grune! is one of ‘ew peaple 11 ne moaeing eines mat hove Ccveved a seme sanding aod Have bear: bie io alo or ver warly-Aus yeon, Fox Me bovenmmnioned tecsons. Mi. Bruner sales A §214 ei Hib: ‘EVIDENCE LAT THE BENEFICIARY MEETS CFR £2) 42(0MUHC) The peltfons: ha sobmilod o plaharo of evidence gang Me Bunsis swcsriznce in In othvon modieing indus, Mr. runes nas esiactanort MG Maciel, former Koti Models, which is piésenlly one of ho major mlamaionl mocicing Ogencies wi comainad Gal reverues of hyenly fun mien aks Only someone wei Mr Basmals @markse ono song Hiv or succets can Gove such mination’ Géciarilion in the incsty and beer cbs lo malnloin i 401s 01 eve: wen ve YEQR. 141. Bune! 3 i one (spon ox The launch of numeiaus supermodel Greer. Wich hove been mom: 8d in thc 103NigH lox sovorcl yours. Ho hos worked! wilh anownod Iaion designers ors phlogropRas, wha have: flied 1 widk Ged Wiifion In odddon. M. Bune! nos cvénestrotet many intesnckona and nolan! cee Xion vuiy Hol lave ceived imernationdl Geckmoton fox the above mentored aasons. Wi. Sunol mn GO! 16 misting of least Tao of lho Gita uf & CFR F214 2G; 3118] ne oso quaaties undies 8 212 $212 OIC) I CONCIUEON cio hi avid, Whol He Enel agit for closilicarion as rt Alon of Eslioordnaty Ani in All Direction an Tos! Conianaion oled upon hs meellay tha efgbily requirements under the inatgiofon and Natwamorion Act 103 (a) {0} ord © CFR 214.2lal, Mr. Brunel econ area proves hot ho 5.0 examen! leading ond wall kno pacson in Ine lsd of offs. Buel axkoordinary city in Ihe foi of oh, in which he wil continu fo werk n fhe Unded Sioles, has baen demarcated by wstained rabonc) and infemtobonal acclaim. Beved on the loresoirg. we: fipeciidy fous! your kind consderalion ond tovarie deipmiaton of Th Catton, 1 outer o Greer Me. Buact tha ciasiicaron 0s an Alen of exaerdinary Aulily in ‘An Diwciian amt lent Coordinalion. Apt. Kindy hate thal fho bench. Hi. Joan toc Brun, has held O- stats 4 fhe past. Hheralors. for 1a cbovesfolea recsors. we respeciluly request your Iavetasio adudicaton of he O-) nonimmisron’ via peliion suoMISS by MCT odo Mar, LC on benol of Me. Brunel. I you 1heukd have ory coestion: or iwauke any adalionct documantaiion, thos do bet Nelle 16 contac ow p= 00 you very mich fo your ken aftention rege ths mater Ty ons. HOUSE_OVERSIGHT_0119¢0 FP | J —— = — i Fre Ea 15 in eo a i pA Ne Re a EER TR tn J pte ETE ST el ite sd oe Fb i wie TL Cy mail to ban wrest erate. Sr ———— pt Ee PRO Cee at chon bh mB hi ae mere se ey se] — | u Fn Ene. Omron ii ——— ET Rn LL eR EE aril nL BE EE aT Raia ERO RR a Wy fe rn mt 1 pens ecm Mtl bert AAS EL a ae ETL EE ual Ey BY ET Th REE a pe ER Simm ru pg Cr Hr rests extraarimar dr, ghee (5:6 4 W ISRINT ks Tee. SREGKADILSTUDIOR Emm ———ihos wa LR rp Ea. [roma — pu S—————" pio De AR ep pe er rr Ce FE Tn SR tn ot Se en BS , TEI rh es sr re Eni I na Bunya ms me Re RL En —— — BC SEA rr ey oo Toe rs eed Er rr ei pe yy EL EE SE Rr Tl er ba Re AES SE A SS CV fealty mien ates a Zr fos montage A INIT LAREN WRAL EL 6 I A 21 0 va Vern Service Coote: 75 Lower Weldan Breet #2. ARens, VT 05479-0001 RE C2 Non luwmigrant Vies Petition of bebalf of Jes Luc Brun Der Hiroe Madam: WM ae 1 His Chm ef am Peet of Mortage Mesh ve 30 years of sxpericncs 48d 1 BI Co AOLy 15 contact with peofdletolials all aver the word. A few ok my ellenty fovkice Elle Magmdme, Snows. Ravana, Laue Shop, Osi’, Tha ley Stores. — aad 30 an. As such, | 80 qualified fo sorament ou Mr Jews Lue fcurels career ms a ant ivoctor ofextracedinar SM 118 not oaly because of his arvlamations ov hia tmpemsive bods: of wrk he a Mioariiog od sami an san) on wad choose a stikine Mr. Brunel's greol taisul For their reouwned acoourits, Mr. mage oh lh ms ep ot Bom 3 r. in nw a 13 phere Tes HE Se Frond is LJ 1 commend stble Srmptmbion for his work As compares ve io the buslacss Bir Bras raputation a & eemidsbie Sct wits 8 ermal dednaric: pene bin. He Is constarely researching, wn developing stiniclatinghy Dupo comply for ele liens and { Savy come ta rely 90 and frst him spd ‘le ability. Over the coun of Ma celeb sed carver, Josn Luc Fronel has detingiishe Timsek! mm oor of the leading fankice at directa. io the Hie Suma Loe Broo scr cris relationstip fo Le aesuiete, This quay manifests atl throsgh the toautihl wort he cro, tise afta time, Therefore. Jena Lis Brassd m chaaty one of the mon isleoted profesicrale working In the work today | look foreand to seeing ror of is ek bn the fre. [ Maver Nacsa Caonva ‘apr NEHRU TROM Sagtamime 17, 2014 | ues Vista Garmoo Cars 73 Lovie Widen Stat. RA, UT 0E479-0001 RE: Ou Naminmigrant Visa Putin on behast of Joo Lue Brunet mar oe Mute | mek Mee by sand vy 6 90 NGUEINIOS SPOON For 118 Rand nay bE O-1 vies peillon MERC by M4 Jan Lu Brunel As fw Sonex eked Prodees foe Nordstrom, 19m quoted 10 19y Ii W Jos Luc Brunel fn 0 art Cecior and Guan! ‘coondinlor of He Tighe! exalt wheee lection smelanca and eal vison have: i hm 0 fhe fap of Nis prosiesion. | Theoughoul M2 Jes Luc Srunafs delrguished Cato, dm hes. receved & high Ji ier bP mdsdiop bys rial coid ofl punt dn Focal Toes ould beard ences Bhat hve conor te del of orchaoed projecs in Eo Pram a 5 ht rv a Tn Tam 5 Conilend winn bo Tia chuive $0 oparsbenat Bilis of amy coho Srecion pean, ekoding ai dimeiors snd talent coorinaton. | te Bemis ry posse B recagnizs fy tetvatle taint nd soevemants of Mr. Jesr Las Aunel, He mesages. 10 8CHHve- ib STG reps from th med curse derveiapad croaiiva/conaepts end am. 18 bis very unin wisi 16 GORI, Wh Cachd analysis, I inten orwalve Wiseaaps of hee certs. 8 iu Clear that Wr Jew Lic Brunel is isenied fer ayond. De a a oy ot conscemd Indeed, M8 has worked wih some of Ie best-hrown relyurs, fein houses, Sd BIBQAZIONS 71 310 WOK M fn wBhOUl | Goud Ted 1 pleas lm §1 he Take ¢f forty edi t 1 cum cweidanty testy tl Mr. Jean Lu Brurale rept sdon nen sciveved ismatonal tahun. He Des renched § vel whens ndublyy KOON mew deacrie fin 08 & sla’ Joan Luc BUMS exVaoniinary CTeeT is 8 3 PONY wna Fare ig AC turing badd. \ id = | Sorvor Tat Preis See bun bo | Recommendation Letter 220314 uscis Vermont Servic: Center 78 Lower Wekden Surwat 8, Allman, VT 08475-0001 RE: ©-1 Nonimmigrant Visa Peticion on behalf of Jean Luc Bruel Der Si or Madam 1 du as extrecne pleasure 10 write s letter of recommenation for Mr Jean Le Brunel. | provide this recommendation based on 1 knowledge: wid experience in the field of modeling, due to my catwblished reputation and work in the field as the Viadimir Yudashkin, director of 1 Mother Agency. Kiev, Ukraine 1 have knewn Jean Lie Brunel professionally for several yonns through our work tageches snd, in my opinion, he it an exirpmcly talented Individual with superb professional reputation. He v wn extraordinarily able coordinator who strives for and atteine a level of merit in hus work: that only @ few of bis contemporaries meet. He hos the ably 10 recognize the croative vision of hus cliemt wthn the ume aod budget through bin careful and thoughriul choice of model casting combined with bis meticulous bility In the field. Jean Lue Bruoe! 4s a true find a aux induatsy. There are plenty of act directors out there, but none with the depth and quality that Mr. Bronel povseanca Hz is mlike aon in tia boduatry, 85d [ expect 10 ace him continue to find great models nv his aucceastul Ewrery. Someone overflowing with alent as Jean Luc Brune] should be given every oppartunity 10 work in the United Sates, where he will have the proper venues to showense his extraordinarr lenis. Please do not besitate to cotact me should you have ‘any questions regarding this matter. Thank you for swus time and isider ton ; A Sincerely, - / E20 a msm ——or Depart 7 and sacs txtws Cidtmnship nd tmmagration Services. Yamont Bernice Soler | 20 Houghton test Gait Amana, YT 33470 be ©-1 Eaboondinary Aly 6a an Art Diacior and Talend C ‘an bohof of palyii-lo ur de i lm ARAN ibepabigebiabromm gu dl iio bid Tem an 153 ogy Le Cn Ws a Ge es a Ce a as em nemo ok rn Bo ver oe Ee Ee a Ee rT rw Minter. cen Hore. Vinay Selucer BINED Wome Sod Shesies Jeeon oie Tes LA bd gb engi ra A ie CG TI Aig DA IN ar, nt Tir A NS ee frets a adh esent i Ihe Leted BSc obi Bagi ki 0 Soke 1h then ss ue aes mtont | WILLA TUR Gat RTE AT 1 A TE mre att (nampa wo md yeh Hamburg 8 July. 214 Daporment of Komelond Security United Shela Cihaeship nd Immigration Services Vermont Service Centar 30 Houghton Saat Son! AIDaNL YT 05478 Fe: O-1 Exhaordinary Ati as on Ar Director ond Talent Caordinatzr an banat of Jean-Luc Didier “ern Rene Sn.nek i To Whom ( Mey Concem As a President ol faccshvart. Ini leer «5 subimittes in Uppor of 1ACT WMadals Miami. LC. or banal of We Jean Luc Bane! 13 work a3 or AT Diratios ond Yolen! Coordinator. ML Bnel nods sa irtonotionnl reputolion on © welbia. SRalegc neIworeT who , Obie 10 Culivole expert relcfiorsho management skis n order 1a conduct Buse in a global ervianment and Licker WEIDHve dodk, Mr. Bub! nas a long HiT A MOKAING GNa COYertsng mar foshlon coMpoigns. TaLEhc. rir weniv-five yaar <arees In INR fosnen busingss, Mr. Bruna! has developed wo'iwidd, Sxciusive Incdakg 1d coumeiic compagns. Some al hese MIN COIMenc «amgaign inch. BO Tham with supermodel Bie Mic-hernan. PHAS wih Kedecca Kor, Chuition Dice vii) Chula Semcrvioviayn, Mare! AHIGH wih Marica Bebucci, Chong! wih Pais Vo, Ri kenneim. Ange Perfume veh Theory Mugler. and Cochoie Pedume wil Acc Ballesra. Mi. Sune has Jac developed mar fashior, onossze: ond NFS EeuS ped comaeigns ard SachAiva CCA seb forme of tha merd's Lig bison designers teh ny aces, in oddiion 1a Mr. Jean Lug Snel + erersive Duuness Neate, CORRBM 08 ON INTIAL! with STAC VISION ONG Credle nhs os helped him find top fasnion modes 10 1enresent in tf United S10 | Should you hive any Queshors obou’ Mi ian Luc Bri qualiicalony teal fee lo contact me. Shh (> ClaudB Midéls 1 Presidi<¢ 75650 23 100 Modelers, Modelagentue GinbH [im money saracans ral Opparttnen of uprans sae. hod Skies Clare cre iver Services Vemond Service Comer | 30 oughicn Seat Sok Asana, VT OMFS. 9.01 Etrooiciory ABR 21 on Art DRBcor onc Teen! Coosanaios on tobe of Lon Lse Okhn Mort bon Buel to Whom 1 Moy Cancem: AS © roaqent of Maioas Moses Marogenant. fe TE Srined IPRA OF NC MOGH MASI, (42 On DOROF OF M4. 1607 Luc BR KE Prk ac A Dvechor anc Tomer Cosredntor ME BONS DOE Dn Femotons feculonon G1 VEDI. KOe0C MESA Who s QS 10 CUMIN #4787 IRTAINND MGROQIKDRD 331 41 i Ka COUCH Curt 1 © GORA SORTA OG Dike” ae. Coal a Brel hai & ong NDGY I EEG Gnd ceiver mack aston cariptgr. Frcucnout bi bepmiy-bve year corees «1 hu (atin Eashibie, be Buns hos cilia worldwide, env desis ond Cosmatc Compolgns. Soma of sie Major Coumelc c. nce: 50 Tham woh uparmadel Be mePhancr. PHS wih Robe ico Gon. Orson Dior wh Crain Semonrowkon. Maa Aor wir: Mana Bein Cris wih PTS Yon Bc ESnheim, Ange Pedra vi TERY. Muggs ane Coca Perkins wilh Alda Boxesha. Me. Buel fon ale ‘UTHER mejor fasion COMP Cnc AGH GevEoed Capi Ord SHEN COTHOCH with Cth OCS 100 Kvn Swmcos Goch On Yoon loin Loum Cron. Chinon Dex. Gus Madd (ond More pty 8 Agctrs NATH 2° Sb cls 30 rn WAY tn) DE i rT Ag uy SCOALA, 38 ASN BANA, cm BENAGYED or 40 £30) OOK B10 + £0100 cu an Biol wih CrtAG ion Ge crete fotent] has Pend in ex 33m shiv, dels 3 MEERA nha Uimiect Songs. | Shenk you have cy cussions cbout Me Seon Lue Bamel quocations los Ree 1a contort me. a Erk sso | | | mie ct. BEd H EresC eae BE Go ev or Yi i a Sf Dlr foes ut ts i of em cn me, Te Roe om re fr meni TT Sn Se i ita ed i: Err oe i ST I a a — Tn LE ea os Eo eT Te eS A LE SR Fr ir : Sn Sn Th di ten Tr al in TA my Ent ER, TA TL EAR a Le eae Sol ad i we wet My pri 1 teres tt end ey rtd hi Tt ea ns Te tbe mare me rg er te fom a Fo ache ee, i 5 BE ] 168 a mtd ov a mt Ra or rte mio mt ln od af 3 £0 ay Ses Phiten 8 Bee [TET x Li ii saieie | i 2 rine Fare PRT. GL C11 War demerit Vim Fririnnt up 208 Sut vB et ' ca en Hoy ey ARs fhe SEE ST eb Sh Rr Th El ral eR on ed SRE is SIR DE i a LS Ee nar en rea Le rE Big ds syn, ep PE a be A OAEGRADELITUDIOS ESR maison wo Vepeicune fie te RU: 0-4 Mem siren View Ion wm bead of drum Lor Reuse vero: i —— rrr ele beni eB ode. en Ps Sos BG Fo rb 15 Biel ams Cay en sr em Le nd Bn nan lS tlm srt wb 6 BY ras) rb a td pha 3 Boat Eo ce a Sb ey Br merino Sama 3 sim to rho Bees pat OS ak 2 I teem ay en er ie Saf a Pai, ef Bem oreo home xb oe abi ty dh Sr ft i 1807 cpio, Jus Lin BE, ety 45 nd of poten iy tn nr ed of s,m le Lo one gh pe i re Sir EE re ae aed Se 1 eg 1 ka td purtian, 15a ood hw Finch WRIT SEPARA 15 the ia DEMS kolo Bo 4 took ET I op, Corot Mah ie, SB mo a pet glen cramer dp ny Tg pin a le hi Bt ee hm nh im ook hse te mds ob ry ha, ss ot I S——— fit Plot by wt hoi £0 med tn ih ay quASiODS Za of (= montage | SANS ALENT ma MONTRILAL TEL 16 200 15K 916306 i vec Vesrowet Bovvice Gente: 35 deve Windon Sion " BRO Nan mana vies Pbtion on ek of Sos Li Bruit. ear ir or Mader: iy marae Je Nadir Comovs ee § am Presdoal of Montige Models || dave Jus sCupieinse sad | am Am 8 ci lg all vor tit word. A few of my clients [orto Elie Megarime, Sonn, Rasta, Lats S00, Oho, The Bay Soros... ad wm. 4s sc, | om qualified 4 sorament om Mr. Josh Lue Beacels cower £2 83 45% ctor of extracedinars ably ts ut cly becase of hi acclamation of bis tmprassive Lod of work 1h i vetiing so pentane sound the, ob chose bo tae Mr. Brsoe gro lens fo els Froud moots, Wr. do Lo Bel ako ish of zat i ls vi Sdn 4 wr er me to compnd Ke penton Prov ay ex erta wall oalrased, Aaceringh, Mr Brune eh as opt fo Wo wet op others in the ens a So a og ud Cmiorioy #1 itis ability, Ove tbe cours of hia celebraiod carmer, Juma Luc Brune hes tigiabod bimeck as a of the fending ladon art directors 10 the Nr Ji Lae Brae ors om scious eaion 0 th sth Thls maly casita fk through the tri work i eats ime ar Spe. Thereioe, dom Lu Deve fs cewly oom o the ts: ieated prodessionals working i the work tod. | 10k ord 1 sslog piare of “hia work be the future. Sumy Yours, ava. | Wada Savova P= NOUS UROM Bagtambur 17. 2016 | vace Yarunont Dervis Contes 78 Lowae Viniden Sent 5 Aare, VT D54TS-00M AE. O-1 Raw yoowprant Vina Pian on haha! of joan Lut Brosel Durie vo Wasa | ‘mou bo anna ray ull nd uruid supp or he armory ey Ovi potion submeied by Mr. Jes Luc Biunel As he Sorwor Taiost Produce for Norsuom, } am quetiied io 837 het Mr Joan Luc Brunel is @1 an drodior and tment EetAshlct of Da highest aloes whose WICH vance Ind crest ilo Nava Wand ham to 0 109 of hia froheasion. ih prt Fares So share 8 Bo oN ne ner En ea 508 alo ain 3 mr an oitamert oh 1m 0 consent wine to be crass wn? stations! sll of may crass: diac People, inghudy at dhcions end (sent SoUGiNRON. 1 I Sherer my plese 1B cocagrins the remaster end wehiewgots of Ur fe Lut runs, Ha mans five “em ion shy do GrATLTSt, a ater Salil, Te vomied Salon Mssann of alr. 8 ear al Ue Jour Lic Brame fs cnt 1 owed Ba sverige hove for nn ovsty by he sreing Ne wd Wh ne walk conudarnd Tndmec, be has We ad 4d yo Tadon oaman, mod omacines 1 1a cid 41s ive 0.68 gh leew Wr 0 ros € ovary boat is prose 1 can caniaandy Watly fet Wr. Je Lue Sunt fepatstion "es achieved lamitioral ‘wishars, He Mus remched 5 level whese indusly leaders row describe hin 88 8 “uw mr 1 Brana weYaaeEaary catmt 80.8 rt vn U0 820 tri BAS. | wary, :, Ching Moto) Usa vi Sere Tot Prd peri Nmdbrna de i Recommendation Letter 2/09/14 sci Vermont Service Center 78 Lower Weide Street 1. Athans, VT 03479-0001 RE: 0-1 Non dmanlgrmnt Visa Petition on behalf of Jean Lus Bruel Daar Sir or Madam 1t 1s an extreme plessure to write a letter of recommendation for Mr. Joan Luc Brunel, | provide this secommendation based on my knowledge and ‘xperience in the feld of morcling due te my catabllshed rep:ration and work In the field as the Viadimir Yudashiin, director of 1 Mother Agency, Xie, Ukmine 1 have known Jenn Luc Bruel professionally for sever, years through aur work together and, in my opinion, he is an extremely (aieried individual with superb professonal reputaiion. He is an je raordinanly able coardinator who strives for and attains a level af merit fn his work that only a few of his contemporaries eel. He haa the ababty to secognise the creatwe viion of his client within the tigic and budget though bis careful and thoughtil chute of model casting combined with his meticuloun abllity in che field. Jean Lue Brunel ir 4 tre find 1m ur industry. There wre plenry of ast directors out there. but noae with) the depth and quality tht Mr Beunei possesses. He i unllice anyone In this industry, 80d | expect 10 see him continue ta find great models in ha successful career, Someone ovecllowing with talent as Jean Lue Brune) should be given every apportunity 10 wot in the United States. where hr will have the proper venues. (> shawcaze his extrardinary whens Please da oot hesitate to contact me should vou have any questions segarding this matier Thank yes fut yur (ime and eonuideration Serass” lr "ou vacate ge vanea wove ERA ember wiTIOY aE “a 2. 28 Deparment 6] Hometing Secudy Unite) Sisies Citlzanahip and Imrsratins Sermces rigor Soest 30 Houghton Balok Aen, VT 25478 | Tors | 307 Gul Ebene Asity an om Ar Dv ere Tend Comeioate} wm boat of Joos duc Dior Hon Fane rial SRA ATS mo Poh Au] 1, i HS A rh A Crach AIA om) soe 10a |e Se 4 vad certs 1 fel acces or fu ba ina awh he ze Comers Ta mode, <7 con rae Pe 1 bok avs Wes, A Baa Cs wd ORIOL ON ake Ca, Ten hv 3h pred Oy ME BA viene? naan BOs SENSES Coir Fi | Doe re 47,1000 0 wa 13 Gr ar MOG 01GB A Bl 1-0 ODM + 30M v0 0 I fo Bp 7 Tara 1 co 3 400 FAB pCR pro rant iA AA RY 0G =r mat 7 BAL Se Sarvs Rak San, Foren ron fea Ba ov SF mera OF for Teens BCH Lee Voge aa oa $4 Ba Vira Cove Harper 1 Eva vw 270 ovr ra 05 2 Mo Bt rn Gv 1d wy hs ye aun se intey Garon $m. Vora Sense] Eels Wok Sn Chino okra en OT 08 OCHS Dee KM PP ONS Cover Tw rn ON, RCP 1) 1 OIE Of 1B Soo eon rh ADRND TOY reg By ie abl 1s #000 tr WARY id Eager Lr 1 or 5 his BE arvarareaet thd one TE NT Bal fk 3) fr sabes me pr 8750 155 Dare inn up Gas mH ww A Lie Bes, ezrs Baer A Cl SE EA Pfs ordi ic Reg aay Svar == BAMERRAAICHA LE © 3 An TE MIT CA ett LS ranch | Haring 8 duly. 2014 Deorment of Homeland Security Unites Staten Clfzpnship and imei on Services Vermoni Sarvica Cantar 30 Houghton Stas! Saint Albans, VT 05478 Ra: G-1 Exfrooicinary Abiity 08 On Ar Director and Talent Caerdinalzr zn behatl of Joanie Didie: err Rana Brune! 1 To Whom IF Moy Concer As a Prasiciend of Mosewerk. this lefter & suDTiHted in supper of C2 Meclol Mic, UC. or behalf of M:. Jear: i.e Brunel ‘0 wrk G3 or Art Director ond talent Cooramater, Mr. Brunel nelds an ieealional mpulation os a valle, stolegec fiewerser who 1 able To Culfivale axpert refatianshin menagemant is order ta conduct busnest in a global ervionmant and Lecker NCIaTYE clocks. Mr. Brunel nos © lang Alor Moketng ord adveriivng Mar foanion cOmPoigns. MHOLGNC TIS wae. ive voor Corolin Ing Ramon businass, We. Brung! has developed wordwice, exclusive incdeling and CoUmaic: Campongh, Some of (hase Hor CONTIG CoriST 1s MC BO Them Wi supermodel Ele Mc heron, PHAS if Xebased Komi, Civisfion Dich with Clulihing Semaiiomizoys. Maigeel Asc wilh 42a BSc, Choe! wilh Prices Von Rictanine. Angst Paume vi very Muh. ond Cochase: Perlume with Alo Roliesro, Mr. Sure has olso divalopad mojor fashion co moaKkN ANG ACS Bev pid CRMRaIgNs ord Cit CGE win tome OF IE wees 4 fan Fras eh ' Yves Sonat Lowonl Chanel Covithan Dior, Gee) nadia. ood Marc Jocob. i addon fo Ar. Jean Luc Brunel's extensive Busnes: Quadioations, iis commer 5 On individuc wih GRE von GNG ersolive alin hot helped tiem find op fasuon model 1a «casen In the Uriled Sto Should you have any guestons obou® Mc Jean Luc quathcarent feel hee 10 contact me. p al a Nf far ok 4 Presi 1185 ve Modelwerh Modilngentier CGanbt§ i {im I | Deparment of Noreen Secufly essai A 3) Houghlon § ree Saint Abiors, VT 07S. A FEAF CC Smear As © Praskint Of NOG MoO MOnGgman). 1 fePar i homed La Fh py Shs SL 2 Sa tt ps aril ich Th bE I deck. Me Sure Ax © long Meicey In mateing ne advareng moor Tnshion campaigns Traughout Ns were yor Comes In the fashion a IRs CER 0 Them win aponmods Ble MCFMenon, PHAS wih Robedto Ramin EE oo LL aT Besos Chana wilh Palicia Von Pcianhalm, Angel Pariuma with Thisry TE EE Erar Dios on Es DLs acheive CONCH wih worm of the words 5p Keahion Usk rien Such 0 IE ET x Mk tarters MAT 4 Gti ol LBL (ADE DE A Hoyos ps, So Sera IEEE Ev ohn 10 MY. J80N LUC BAN) exferave BUSnes es on Canesr a of indivicles wih atic vigon and creotve hos hatped Te Shoei you hive ony quetions ctxt Mr. Jean Luc Brunel bere Stators Vert See oe cn ase ving us Cum fn Biz Shin Venn ors is Facsimile Transmission ween sumer main ec ger ess coms or Copa 0 rom mes Cone rn ar Po emt 5673 Eo mm Poo: 5585 Races JP ———— Lr TE —————] rego rg Ecc eo vey ce Ee 5 Dn Sm foi te tee er a le E01 ERS Sgn Sonate premio vm oo mere NW PACK OWDBR 8.94 pw mtr ¢ ons 5 Anon Ac nl 4 Dag Td Sr TE 3 td et ee 3 Ton vr ST AS A an 3 TE mln bog in Sem eG a UR TO BT TP — An eras Sg st ne esl ve Rear sne es 5 Aee e im coke eh lr oe i ae TT ko wl MRERE 5 Oi EES RLY Sei ee. ony yn cn rete rs si FEN TE oscar 3 pra hagts n re U3 Cig bo Ss wh [ ” p= Frrr——— dT J — = fh —- BAL 1422000804 = J = A msm = Err = E E = PENI = BE Eh nt Sm a 4 1 13 Commit aan em To Me ROE Be er re Ee TE — Be A reer Hare a eee 3 Snead Svan mt urn pst fs doe El Rp wr PE SMART — I ————— Ee v—— Ehmehnay ERICA A Us foams cin Soucuchnnn US Cri bl i bin tm Maal FT i Tie Ay wT Ea 0 = —] F190 18 bt sk = a C2 ina US teem. 129 Iron br Karr Henn wing 9 Aste — ee rate = = 0 1A i Sahai ds wc. aa = oad Nr ce Tc be HEA 1 WE Fr AI = prs i ] BE BAU 0 EN TE O82 BT RA Emme 0 HT Ry Nod BY Doe = = Sinn a ot a = Siu ee gone ow cio ic ee xan ran oem md A Bd th, sr mp bes Ir J A SR frre A rr pr fi Ca Rogurae B Nag ys I RL EO 8 Ar ote opens wea @ srs ad Commo sense dod Sov wagers sea sl er per a any Feels Aa A ns Semi tes De ert eth ant Wolo uses I pag a bg Wa nour U5 limp en rn 6 mid tse 3 ES Te EVES CAT. A Pt BCH I CEC oc tn 1 pot TRAP Sr ln ot Te ea re ph kg 4 G1 1 A eR 0 0 AEP 1 OE EIR NEG] ven EE, Nr IS A 16 Pod 5 Te i or 07 EN Jus = Ea = a Comes. = or Et ot = io bes asad TE —— Ut Sprain rate Seretpns UL Coin 0d rmrenn Sera a ans somssannm i = PE —————— -— rn ne = —1 Tibet bE ABE BERT 1008 0 A en you Pv cn en, hoes Fo wl FRE — = = frome ee — = = ri oh i ns 80 Er ppt pT 8 Ne. sare 4p a a = Sonch KC AOLHLP 3 RACE 0 oR = wants by pronto Brum tb = ARTE J 5 FONT LAW GRIP 0 S00 Iwo Blo, Se 415 Viswood. L326 Te 450 HARD Fa (950 240-0272 Nomber 1 014 Dist id Ses zaps igi Sever amon Sree Cota 28 Laver welkn Ss Sem Alm \T 179 Ki ROUNCATION OF WITHDRANAL OFT. 23 PETITION THOT PRE TACH FIR IONE hesreey Feat 0 HODELS MIAMI LE Busi SEAN LU DIDIER AERC ENE BRENT, De Si Madom Pls be asl at ns ice sees he ahs fiscd pac nd bin Ie te, ee ad O24 in go Te IE PETITIONER. WL MODES MIAN LLC HERESY NOTIFIER ESCIS THAT IT WISHES TO WITHDRAW 1113 0.1 P5TITION SEAC-11.23% S083, The pons Teast hdl of hs 20 ei hon pd lend me rns] 0 000 ic mre We eel, nt Gat you sed fin of the wind ran 1 he ei mito CAA See, 103 6115 iad sd a is eo oF ks three i sk Fost a Gao, PA, 4H 3 Br ste 115 liad FL 3031 The or ye erin fi he swe J et Cre ogdl — Original massage —— From: Jeff Fukar Data: 11/12:2014 17:48 (GMT-05:0C} To: Joan Luc Bruns! Suoa: RE: New York Jear Uc, 1am really sorry you feel <0 bad and | know It as been 2 mental and psychological frustrasion. As you Know | nase to partner wit, you due Lo your reputacion in the Susiness for Sein a top scat and developing a couple world class agencies in the past. | knew whal you could bring and kncw wat | could bring 7d contribute and 1 Fought would be a great partnesshin, Clearly, | never expected to ave the level of challenges ie have had recruiting new models over the last several sears. | could have never foreseen the problem of you frendship wih Jeffrey 2pstsin tuning inta the siuation «has. where you are sen 3: guilty by asscclation when you have never dane anything or avn been canvictec. ota crime. Frarkly, | 60r't understand the necassity for Concha Sarmof? or amyone wise tG continue to defame yaar nan:e and 1AC2 by association, 11 17 hat wa constantly have ta justify ourselves when racrufting new riodeks. The industry extremal; campet tive and 43 a parent myself if faced by the same information and having to make a touzh deciian bemeen 10a agencies | would net pick MC2 if | saw the article online about ja. You have to 7eac closely 10 see thera is not a chargs against you but the implication i strong and of course iow days everyone be eves everything they read online even morc than the traditional newspapers of the past know you are new fesfiag ike 3 labilty to 11C2. Sut you personally are net liability to MC out this published information aniine s 3 liabilcy. Ve are not 2 arge enough company, nar do we have tre capacity to light this on a global level. On 3 gaogle search i? America we have put enough infarmation online to not have it popping up 50 blatantly but we have no controls over the rest of the world or the finances to control ts situation und wo are affacted us ovary major model agency recruits i's best models Irom al Ure various couslies abroad. This es stunted our growth an our bil over the past Gor 4 years, Infact, we do not even know who avons us Laseed on 7nd hs information, | lieve beer surprised Fw clialensyog 1 1 0 US 10 RIO uk 10 is problen. 1 have elo had a tremendous amount af worries from ou: clients that we are vendors for that are large. American corpozaticns kes Kohls, C Penna, Sears, Nordstrom, Target, Neiman Marcus, Macys, Saks, Belk, and =a forth that require vendor agreements and for us t2 be consider an upstanding company. It rally worries me as same of those companies have disassociated themselves from shat EXHIBIT K they helieve to oe quastionable companies. So far shat has not boen a problem but t could come up in the future. Tre fact that you ae requested or so many scouting events In various countries and cannot promote. yoursel propery to promote MIC2 ia the press dus this problem has i's own sent of repercussions in cers of our global branding. In short, it has had a terrible effect an MC all sround. | really urge you tu solve thi problem and ge! his removed from tha internet so we can grow for the future. Ive fought For M2 and been exlremcly loyal but 1 must confess that | ave cen beer feeling inadequate and auestianing ny abllky a the leacor of the organization, | can only attrbute the fact that we have scraped by In the recession and barely survived in Fe past to you: hard wrk, my hard work, and the cenacity of bush of us combined. 1 can nly Imagine that 113m feeling Inadecyate and frastrated ower 4 ack of growth of our company. hat vou must Tel sven worse. a7 oll haves hal mh grater sucess in yous carver and have aserated at much higher standards In our Industry in a1 areas from reputation, respect, admiratios and monetary gain. 1 con even surmise you are probably feeling level cf depressicn and | have sean icin your highs and lows and when you have vaiced your frustration. Wile | know you well and recogeize you don's reall ga for the kind of adsice | will offer; however, | think you should at least speak to someans neatral such az 3 therapist or a counselor to let vour frustrations out and if yau don't feel better snd are stil feehn Hown of deprestad 10 4a medical dortor fer your condition. You are such » peste pear Tate 10 er you firing what you feel 5 » hopeless battle. 111 not hopeless you [ust ned find » wsy to Re that information offine and begin to repair your regutation. In the and | am afrald tne damages are alot more than you realize bt let's keep fighting and meving forward as we have na choice. Thanks, sett seth ler President 1MC2 Model Managemen: USA EXHIBIT K FLOM: JACQULE JOHNSON 4 JOTNSONTRRA-LAW. COM> DATE: SEPTRMIER 18. 2000 5:57:44 PM EDT TO: "EAMAGTRIUDALNTLAW, CON * EAMG DMANLAN COM CC: “BRADLEY J. EDWARDS” <BEDW ADS RIL LAW. COM> SUBJECT; EPSTELY - DEFO OF JEAN LUC BRULINEL eau conan for i. Buh eposion on 13. We wi commence a 600 a. thts ok with ov, Jacquie Jonson Legal Assisantto Brad Edwards, Esa Partner Ronatein Rosentele Adier 401 Easi Las Oles Bh. Suk 1650 Fon Lauderdale, FL 13301 Telephone 554 315 7264 Fax 854 527 £663 EXHIBIT L — Original Message— From: Toma Beth Kudmen <lame @tkudmariaw.com Dole: Monday, November 18, 2000 at 7:46 PM To" Jean Lua Brune! <2jeanhio@gmal com> Sujet: Re: Hi “All depos sre cancelle for now, A fier confining tis Is being S56 out today. We have ne Ides how; long this shal detay things 11 Slat Micheal know Sant from my Phone. Tama Beth Kaman EXHIBIT M From: "Dr. Royce Jalazo* <dynamicben@gmail.com= To! joetitone708@comcast.net Sent: Tuesday, December 23, 2014 2:40:58 PM Subject: Jean Luc Bune! Mr. Tioe. Please accept this email as my formal notification that Mr. Jean Luc Brunel attending an culpatient individual psychotherapy session with ma on 12/12/14. Thank you, Royee N. Jalazo, Psy.D. Licensed Psychologist Dynamic Behavioral Consuiting a DBA of Dr. Royae Jalazo, PA 1975 E. Sunrise Blvd. Suite §32 Ft. Lauderdale, FL 33304 Direct (With Voicemail): 954-232-7092 “Toll Free Fax: 868-236-6979 or 954-208-3400 E-mail: DynemicBen@gmail.com Webslte: ww. Dyoamicheh coin EXHIBIT N A Comes ihe Nain To a [Rens ix Ih 4 Lomardan, ks B581613 pres blog om Quapkrefin®o p= lela, wapnen Slee aly Seat, heer Thm S505 wip Ea pS ry [mies ee. TCT Pills, ‘ Neos - - 10 Gr eg 1 Ke - a al a TR TREAT eg 1 = yi NE Seen Gaby ah Dustin. LER Paprcaonsg bt Opin tinends EXHIBIT O COMPOSITE EXHIBIT P — MEDICAL HISTORY | -~ | =N BNH HOSPITALINR 31 0141221248 = Vea vue (onghoh using Kew Hawi TN MR. JEAN - LUC BRUNEL Be | E Prozac (20 Mg) Capsule # | E Take 1 Capsule URN = Once Daly After Breakfast RE = Tel. 02.66.2700 Fax. 0268205708 oo WS EXHIBIT Q EXHIBIT Q ‘hHp://www.palitico.comiblogs/under-the-radar2014/12icourt-filing-levels-sex-claims-at- Alan—ersbowia-200498 hut ‘Woman who sued convicted billionaire over sex abuse levels claims at his friends By JOSHGHRSIEIN 10s ess rv ST A woman allegedly kept as a sex slave by politically-connected billionaire investor Jefley Epstein, whe went to jail for having sex with underaged girls, is accusing several prominent [rieads of Lhe financier of having taken part in the debauchery. according to a new court filing. The woman —ceferved to in count papers as Jane Doe #3 leveled the allegations Tuesday against | larvard Law School professor Alan Dershowitz and Britain's Prince Andrew. as well as British socialite Ghislaine Mexwell und French model scout Jean Luc Brunel. Dershowiiz flatly denied the claitns bout him Wednesday in wn interview with POLITICO. u's tatally. unequivocally and completely false,” the celceated attorney said. A spokesraan for Prince Andras denied the ulegations Friday. while a lawyer who handled related matters for Maxwell did not respond ta an e-mail seeking comment. Representatives of Brunel's modeling firm slso did not reply to e-mail messages. The accusations came io u long-running lawsuit charging federal prosecutars in Florida with viclating 8 victims:-rights law hy filing to consult with Fpsicin's victims hefore signin off on a plea deal. That pact neled our smy federal prosecution of the investor, who agreed tw pleed guilty 10 twa stat: prostifution-relaced felony charges. Lawyers for the victims have described the. arangeinent 5 3 went deal the well-connsied Bpsiin and his high-powered legal team ethno by puting prevsure on prossastit, Epstein served 13 months of an 18-month sentence on the ti state charges hefire being velsased 10 2009, He's mow rested sex nender “The new court filiag, subrmitted by Farida lawyer Brad Edwards and former federal judge Paul Cassell ins federal court in West Palm Beach. Flu., usked thar Jane Dee #3 and another woman he allowed ta join the pending case over the victims rights claim. “Epstein... rafticked Jane Doe #3 for sexual purposes ta many other powerful men, including ‘numerous prominent American politicians, powerful business exsutives. foseiga presidents, a well-known Prime Miniser, aad other world leaders. Cpsiein requied June Doe 31 10 describe EXHIBIT R the events that she had with these men 50 that he cauld potentially blackmail tem, the court filing said “One such powerful individual that Epstein forced then-niinor Jane Doe #3 10 have sexual relations with was fore Harvard Law Professor Alun Dershowitz, close friend of Epstein’s and well-known criminal defense utlomes. Epstein required Jane Doc #3 1 have sexual relations with Dershuwitc. on numerous aceasions while she was 3 min. nt anly in Florida bat als an private planes. in New York, New Mexico, and the U.S, Virgin Isfands,” he legal pleading added. Dershowitz called the allegations “tntelly made up and totally fabricated from beginning to end. He said he vas not in the places described in che fling at th eelovant times, with one exception: I did visit Epstein’s private island in the Caribbean on one uccasion. “1 was there with my family.” the renowned law professor said. Dershowitz said in u follow-up interview afl this post int sppeared Wednesdvy that he's planning (© Gls bar complaints against Eabwards and Cassell for inailsquately vetting their clnt's story “ren planning file disbarment charges against the two lawyers who signed this petition without even checkin the manifests of sirplanes or travel itinecaries, ¢ cetera," he said, “Im also challenging the young woman and the lawyers to level those charges sgainst me outside of the courtroom, so that | Gan sue them foc defamation... Fialy. I'm challenging the woman wo fle criminal charges against me because ti filing of false criminal charges is ¢ crime.” ‘The motion aceases Prince Andrew of simitar actions. asserting that “Jane Doc #3 was forced to have sexual relations vith this Prince when she was a Binge it hese sepacate aeographical locations: in London iat Ghislaine Maxwell's apartment), in New York, und an Eputein's private island in Uhe LS, Virgin Islands {in an ory with numenous other under-ged girls). Previous press accounts have reported on Prince Andrew's friendship vith Epsein, who was &nown.as a philanchropist and supporter of scientific research befure the criminal inv:stigatians began nearly a decade go. llowewer, the earlier accounts stopped short of accusing the prince of sexual invalvement with girls Epstein procured. in # 2011 Vanity Fair sory. Pence Andrew denied any such contact. ‘While u Buckingham Palace spokesman did not respond to POLITICO'S query hoi the matter on Wednesday, the palace issusdd a denial fo several British nows outlets Friday. "This retes to long-standing and cngoing civil proceedings in the United States. to which The Duke of York is AOL party. AS such we would not comment on the detail. flowever, for the avoidance of dub, amy suggestion of impropriety With UnAETIge Minors is categorically uarue. the stxement said. Prosecutors said ina 2007 dal letter they’ d identified 40 young waimen who could be considered victims of Fpsiein's illegal acts. Many of them filet lawisoits or claims against Fpstein and reached Gutofscous sclements for amounts that were nt disclose EXHIBIT R While “Jane Doe #3" is unidentified in this week's euuet ling, her story appears us track with that of a women wh suey Epstein in 209 nd settled vith him later that year. She rpparently ramadan antberecord interview 0 Rrisin's Daily Mail in 2011, Some uf the ascinaliun with Bpstein on the part of tabloids and glassy magazines stems from his ties to former President Bill Clincon. In 2002, Epstein provided his 727 fo Clinton for a trip fo Africa to siudy anti-A ILS programs. Calebritics such as Chis Lucker and Kevin Spacey came aleng for th ride. The new coun fling rakes no taeation ot Cliston, Tucker or Spacey. The federal investigation obuained puanifists for Epstein’s private fot travel. but prosssiors neve: charged anyone besides the investor with involvement in obtaining or using underaged ils for Sexual purposes. The new coun filing says chs rosa i in par di 10 the face that Epstcin’s legab team —which includ sich heavyweights 33 former independant counsel and solicitor genecal Xen Starr, tial lawyee Ray Black. and Dershowitz—negatiated a deal thot precluded the feds chacging anyane 25 8 comconspirator. Lawyers for Jane Doe #3 argue in the new motion that Dershowitz put this language in the agreement 10 protect hase. However. the Ins professor told POLITICO he didnt negotfate thet deal and i wasnt aimed as protecting him. “1 hod nothing co do with drafing the noa-prosecution agecemeal.” be said Dershonit: added that the last dra of the agreement mentioned four people by name who wouldn't bs prosecuted and he was not among them. All were regular associates or assistonts of Epstein. the swyer said. adding that the final language removed those names ind sitmply barred federal prosecutors in South Farida from going after ony potential co-conspirators Epstein and his lawyers fought hard to prevent scconds about his plea acgotiations tom being fumed over Ko Vii” tories, However, U.S. Distriot Court Judge Keith Maru ruled lust ver hat the victims are enditled to examine hiss records fo prepare their case against the government. Epstein, Black and oxhers appealed that decision to the Atlanta-based 11th Circait Court of Appeals, but it rulzd in April of this year that no privilege protects plea negotiations in this sor: of dispute. Edwards and Cassell did nol respond to eyuests for coment for this pas, including an inquiry shout their response to Dershowits comments. Howaver, the pait appear to be pressing forward with the victims’ rights lawsuit, which socks to unravel the no-federl-prosccution deal cut foe Epsein in 2007. UPDATE (Wednesday, 7-18 AL): This post has bom updated with furthor comment from Dershowicz EXTIBITR wwe Original message —— From: Abi Schwinck Date: 16/01/2015 05:16 (GMT+07:00} To: Pink Jean Luc Brunel Jef? Fuller Subject: FW: Victoria From: Erk Bechto (malto erkSpageparkes cam] Sent: Thursday, January 1, 2015 5:12 PH Tot Abi Schein Subject: Vicmna Hey Abi! Hops vou're well, ©) T've just had a conversation with Victoria, and hs isn't comfortable reining with MCZ with all che drama going on right now inthe pross. She's asked me to camtact you on her belall. Please led me know i you see any issue with Dis. Thanks so nich! Erik Bechtol Agency Ditector Page Parkss Houston sv peepee com The Page Parkes Building 1535 West Loop South. Suite 110 EXHIBIT § Houston. 1X 77027 7:71 807.8222 F713 8071053 EXHIBIT § Did you write this 75 On Monday, August 13, 2016, Kathy Roernmir | Begin forwarded message: Krom: - I Date: August (5. 2016 a1 6:00:12 AM EDT To: - EE Date: Monday, Aug 15, 2016, 12:57 AM. Tas MEME ATES Er TW Tr i. ’ Subjeet: FW: Press: AmLaw Litigation Daily on Enucates Bank win rou: Haz, rk L) < —— Tine: Suma, Avg 14,2016, Tor Sehocter, Pune €0- a, Be. noaomenl CoD PS) p—— SY i. Isic - bo rer < +=, Harris, Nicole (CH) , Cirsonberg, Jofficy (LA-NY) ;: er, Spee (SFR) . >, Jennings. Ak (LA) ~ |<. ru (ST) Subject: Press: AmLaw Litigation Daily on Emicates Bank win Til oon send sn cleaner version af this and other cov ere, bat wanted 10 shure ihe sricle just posted in the AmLav; Litigation Daily. A personal thanks to Dan foe speaking to the reporter. and Nima tar feeding us case documents aad insights. apm iigiondaily. com #aniclo/ 12027650525 11/1420 Vasier#20a1%20 Work:#:20 Disseeling®420the ©420CHosing42DA runt i520 allum's26 20 Tuge2o 20Windi20lorti20Middlet 20 Fastern20ark A Master ax Work: Dissecting the Closing Argumsat in Lachans's Hugs Win for Middle Eastern Bank Jenna Groene 142016 Tor Latham & Watkins, defending a Midkle Easteen bank accused of sealing teade secrets from a plucky Amarican entroprenour sould have been 3 wugh soll to a fodotal jury in Orange County. Califoruia, [pews Ja comitmagesT Daily Dl Dieta fe The stakes were ighe-mare than fal Fa billion dollars in Wimagges—and same of the licts were, hem, clllenging, ‘How did Latham Lawyers fun 2 potentially unsympatheric naative info 3 unanimous win for Dubai-based Fanirates NED Hunk PISC on Thins? A Took at closing arguments by Latham partner Kathryn Ruel. who made her fist n-conr appearance since she stepped down as White House counsel in 2014, is covealing in a warch-the-master-at.work kind of way Along with Luthum partners Duviel Sthecter ani Deca: Dunluvey, she fixed viT sguinst an equally farmiduble oppor: Roies, Schiller & Clesner parler William lsuacson, sho wissmed u itgator of the ‘oars hutp: wy ameneanlaviyer com’id=1202745123270L itizator-of.he-Year- William: lsaacson-of: Boiss. Schiller by Ihe American Lawyer in 2015. Ruermmler purachued ints fhe case sn May 20, replacing Steven Baer. He had another case (an hehsll of Pacific Gas & Eloetric=hitp: isu therccorter.comeid 120276271261 1iSplic-Vendictin-PGE- Pipeline Blast Caseshienuca 2016071221538) going to tial at the same tune and couldn't convince U5. District Judge James Solna to puch back tho wial date, which had alrcady bos delayed sovorsl ims. Tien was the lay of the land: Tver weeks before, the Tos Angeles Tinves on May § hud run u lengthy Feature ip wow Jains comsbusinessla--infospun-livesuil-20160S08-story hum that was distinctly sympathetic to the plainttt, Farooq Bajwa. A farmer computer components manatactucer’ El Pollo Loco franchise owner. his test venture was company called InfoSpan ne. Thejost a portrayed we visionsiry whis had an ides ns allo farefgn wires 0 easily smd cheaply send funds back to relatives in their home cauntey via the internet or cell phone “8 realized 1 mighr make big difference in this work not only helping these underprivileged people who dont have hank scouts, 1 will also be helping bring an economic revolution,” jus, 64. told the paper. “Lad very big dreams.” Thu uller he smack a deal with Ernirates NBD tr voll out his prouct, SpanCush. he claimed the bunk stole his proprictary technoloa, killed the deal and mined his company. (Though it's had to tcl 100 sorry for hir-- he's pictured un front of his house. a mansion that would put Versailles to shame. In this David-and-Goliath story, he's a David from the 1 perscer} Thsjors sought KSS4 million plies punifive damages on rail secre misappropriation amd misrepresentation claians. Iial began on July 26 in U.S. District Court for Coutral District of California, On Aug. 1. Rustler and Isaseson summed up their opposing positions in closing srguments, Tats take a louk. Isaacson. who did not respond fo a request for comment, lod with one of his strongest cards: LSA! LSA! “We as a ouiry, made up of flawed pele, came together as ane of the greates! countries on Furth, because we are a nation of laws.” he said. accanding to a trscsceipt of the proceedings. “This was about hard wark and hat Happens whea your woes is destroyed and taken, ow you's entitled to be tecated uader the Jaws of the United States.” Tor Ruenunler, the appeal was nol emational or jingaistic. 1 was rational ull the way. ‘er fist ing: “Mr. Bajwa has come up with an interesting story, but its not what happened. And then, in the mast madler-of-fict, conversational way, she unnihilated his case. “There ace at least fivs fatal Haws in Ms. Bajwals case. and any onc of those alone sinks his case. Any one.” she said, according to the transcapr. Bajwa couldnt prove that SpmCash was ovr fully funtionsl and commercially ready, Ruemmlr ssid. In Tact, she argued, it was never even eal product Furthor, she said, Bajwa didn't prove that the technology or platform: wes comprised of any trads soercts; or that Emirates Bak stole SpanCash; or that it ver used it. Finally, Bajwa didu’t prove Infospan suffered any dames, she said. Same of her tums of phrase are cetivshingly non-lasserly. “Sham is going down ter... Its not as if these guys were cxaetly cubes... This is some flinaflara ching. On of the maa, many dog-ge-ny-homework Sxcuscs. Lis is an sbsolure double-dawn liv.” The averall elect: she simplified without being condescending. Butthere was stil a huedle for Emirates. Or as Lathan’s Schecter put cin aa interview, “Lhere are some facts we wouldn't sont,” Afler the hank terminated is ugreement with TnfsSipan and demanded its investment hack, Tfospan’s deputy CEO, Larry Scudder. was anvsted when be tried 10 leave the UAL. “Atthe Dubai Airport hat dav, the Dubai polics amosted Mr. Scudder afte he prosented his passport af an. electronic terminal. Police told Mr. Scudder hat charge of criminal fd had besa filed agains! him for $1,465,000. Mr. Scudder wus hundculTed und marched through the sirpart wid then held in police detention facilities and inteerogated,” the complaint states. Ho was handeusfed to a chaie, then teansfecred to a esl with 30 peopl before beng relcascd 19 bowrs later, at Tan. Aad then. the police kopt his passport for sux months before he coutd finally leave the country. Om the stand, he erie shen he spoke shou the ordeal Isaacson in his closing cepeatediy called it extortion, “Because when the bank held Me. Scudder’s passpon--Fin sory. caused his prssport to held, that just didn't cause peesonal paia foe Me. Seuddes,” ho said. “What it did was give tho opportunity for the bank fo control the technology. o control ch situation, because now InfoSpan couldnt compte in the LAE hocxuss of the fans that this typ of thing would happen. And if sso gave him the apportunity to try und extort money wid cantrol of Ure technology from nfaSpun.* How do you countor that? Ruzmmler wis not available fr am interview, but Schewter said preirial research showed peaple expect that if yor cla business overseas, youll comply with the Tavs of the foreign couniry. And in UAT, this is haw they. headle fraud. “Judge Selma has instructed you that filing a crivninal complaint in Dubai for fraud is a common practice and that if you've hon chested. thaf's what you're supposed to do.” Ruznmler suid. What about Seudder’s emotional testimony? She undercut in without coming across as callous--a fine linc. “Nis, T have fo menticm fhe tears. And this is the aly thing Tm going to suy about it” Riemmler said. “Tle was detained for Less than 24 hours. nine years ago; aad then, he was in bis corporate apsstmea and had $300,000 10 Jive for, ike, sbout six moudis. I just pointe to say this: | will leave to you to cvanate the sincerity of those fears in light of all the other evidence that you have heard in this ese.” And thea she immediately talled shut hus he “basically, hud faked u document. It worked. After about a day of deliberacion. the juey found across the board for Emirates NBD Bank “It was binary cane--cither they Tied ar we lied” said Schecter. “The plainiifls strategy was al ar nothing. There were ni: wlT-ramp far the jury. The Latham tearm also inchuded cowsel Aadeew Fossum and associates Nini Mabebbi, Stephanie Grace. Jonathan Sandlor, Jacquelyn Levin, Elizabeth Grosiunan, Pushkal Mishra snd Lom Rickoman. na statement to The Lit Daily. Tub Qussin. chief group genera] counsel und company secretary of the Famirates NID, suid, "While there wes no husis for this case being tried in U.S. courts. irate NBT) Bunk is deeply gratitied by the jury's decision and appreciates the court's commitocnt to ensuring a fiir tral.” Contact Tenn Greene +4 SEY +n TitleriGjgroancienn. Seat from my Blackiory 10 smartphons, rom: Schecter, Daniel (CC) Sent: Sulurday, August 13, 2016 1:34 PM To: Pizzacro, Frank (LA); Dunlavy, Dean (OC); Mohebbi, Nima (LA); Rucranlee, Kachy (OC) Co KL&W BY PR (US: Wie. Jane (NY ; run, Nicole (NV): ars, Nisole (CT): Creenberg, fff ILA-NY), Banc, Steve {S1-BR); Moore, Wendy i0C]: Jonas, Alex (LA); Robins. Greg (LAY Subject: RE: Press: LA Times - Federal jury decides Middle East bank did not detroud Orange County hp; www oobi. convinews 201 6:aug 12 jurv-decides-against-sic-fim’ rom Mazo Soak (LN Thre Thus, Ang 11, 2010 Schecter, Danie (CC) SN... (LEW BD PR (US) malo] Wit, bmi : Plt, Neale (C11 «| =, Greenberg, Jeffecy (LA-NY) 5 ict. Stove { SE-B) cr. en (CX) p Taming len (HA) <4 =, Robins, Grog (LA) Subject: Press: LA limes - Federal jury decides Middle ast hank did not defraud Orange Counry eatreprencur BUSINESS Fesleral jury decides Middle Fost hank did not defraud Orange County entreprensurshupsé fa lav | QHT Farooq Bajwa Tarooq Bajwa Rug 1.2015 steal technology from an Irvine firm that sued it for half a billion dollars in damages after their partnership collapsed. the partnership because InfuSpan conldn’t produce & working product and misled it into thinking it was an astablished company. not one with litte no track record. Afar delibenling for day. the jury unanimously decided that InfoSpan did nol prove ifs cass of fraud and InfoSpan had asked for $540 million in damages. An attorney for LafoSpea declined to comment on the pussibility oan uppeal. The verdict capped a two-week rial that involved ducling accusations of fraud levied by high-profile attorneys. on both sides, including the former White House counsel to Presiden Obama. Atta conter of the high-stakes battic was San Juan Capistrano resident and satreprencur Farooq Bajvsa and a mobil payment system thal he si would ullov migrant workers in the Middle Fast to send remittances buck home hugh tex messages Baja contended thac InfaSpan, with support feo outside investors, spent $87 million developing the busincss and technology. Io launch the system, known os SpanCash, Bajwa partnored in 2007 wich Emirotos Bau, which is controlled by th United Arab Emirates” sovercign wealth fund W seemed Ure ideal colluboration for the Pakistani immigrant, wh eumied millions uperativng umothe Trine company that mumulictured computer compangnis in the 1980s and 1990s Ihe Gulf States eely heavily on migrants to work conseruction and other low-wage jobs, offorng a ready-made market for SpanCash. InfoSpan aimed fo allow miarants to trasfor moucy back howe far more cheaply than Weston Uniam er hawalu, truditional Middle Fasiem brokar-Le-roker mane framsfer system A study from McKinsey & Go., ited in ciuri recisnls, projected smal revenue of $3.5 billion hy the deals fifth year, with IntiSpan receiving moce then $2.8 billion in fecs. But the relationship betwsea lafuSpoa and Emirates Bank soured and the bank cancelled the deal in 2009. A fou days lator, Emiratos filed a criminal complaior in Dubai against Bajwa and a parm alicging that thoy dafraudod the mk and inisrproseted InfoSm se an tablished business with a working echnology. Two years later, TnfoSpam sued in US. District Court in Santa Ana und alleged that its lechmalogy was working und thal it delivered its source core the bank on serves, Fmirates ended Ure deal, TntaSpun said, to launch ws on mobile payment system after stealing InfoSpan’s technology. Iu court, an attomcy for lufoSpan argued that kmirstes forpedocd the lufoSpan relationship because it abhorred ue much mone: it would have fo shire sith the Irvine firm “They waned SpanCush und they wanted the money.” aitermey William A. Tsaacson said in his closing scgunents Wednesday. Jsaacson a partacs with powerhouse law fron Boies Sebiller & Ploxac, chaired by high-profile lrigator “David Boies ~ argusd that the bank resorted fo “pure extoMiON” in an ACP 10 got ifs Way. Asa rosul of the bank's criminal complint, InfoSpan sllsgsd Bajwa’s paraor, Lay Scudder, vas defined au the Dubai Tutenuational Airport und taken ton cell where he wis locked i with 30 alhee men for 19 hours until he secured his release by ming aver his pussport. According to the Jawsuit, Bajwa tried to cssolye the situation but was told Scudder passport vould be released and ho could keave the couatry only if LafoSpan gave up owncrship and coutrol of SpanCash to the bak. Six months later, the bunk withdrew the fund accusations and Scudder got his passport back. hut SpanCash's reputation was tamished and it collapsed, Baja previously told The Times. The bank disputed that it acquicod [afuSpan's sowrce codk or used ic at any uns. ‘Former Whitc House counsel and an attorney for the hank, Kathryn Ructmlor, said that Ecniceres never would have acquired sours codon a joint-nartershin del like the ons reached with Infospan. Sho said such technology would instead be held by u third-party escrow company fur the length of the partnership. Tn her closing arguments, the purtnee with global firm | atom & Watkin tld the jury thet Bajwa and IntoSpan sold the bank a “bill of goods.” arguing that despues promises to Emirates, the technology never worked aud InfoSpan wasn’t as big a company a it claimed. The hank cancelled the deal and fled wn eriminal complaint, nal ax.a firm of exliiian hul simply w regain the ak’ money ier if was misled and doubts grew sho the character of TnfaSpan’s emplpyees, Ruemmler told the jury. “They conehudad, detinitivoly, chat they had been defraud,” she said. Lubua Qassitn, group genctal couns for Emiratos Bank, seid in & statcencut aftr the verdict chat “Emirates Bank is gralificel by foday's decision and the opportunity ta receive a fir trial in U.S. courts.” Thejowu said the trial has ken a toll un him anal he doesn't kn his et steps. “I don just beat up,” he said Phil Uiesllons contributed 1 this a Copyright 2 2016, Los Angelos limes<htio:i‘wwyr latimes coy Trank Pizzuma Tublic Relations Senioe Manager LATHAM & WATKINS LLP 355 Scull Grund Aseuie Las Angeles Ci 90071-1560 his email may contain material that is confidential, privileged andor attorney work product for the sols use of he intended recipicns, my roview. elinnes or distribution hy others or forwarding witha! expross preemmissian is strictly prohibitel. 17 you sme nal the intended recipient, please contact the sender und delete ull copes. Latham & Warkias LLP please uote The information canliined in this communication is confidential, may be ulonses-client privileged, nay cansiituce inside information, aad Is inteaded only for the usc of the addressee. It is the propery of IRE Unauthorized use. divelosure or copying of this communication ar any past theceol is sicily prohibited and may be ualatul. 1 you have received this communication in error, please notify us immediately by totum e-mail or by o-mail to jeevacations email com. and destroy this communication and all copies therzol, ncludig ull ultschnents. copyright all rights reserved oan: bien On Fri, Dee %, 2016 at | 1:46 AM, Ens, Amancio I=. oc: We continue fo see further upside in financials. Arrerican investor wre very bullish the banks [long only AND hedge funds AND macro funds), bul then conclude “1 buying has been concentrated in XLI (every client sector we have has been a better buyer of XU ). 1] Regulation: Excitement, with the base case that it’s not getting worse. 3) Sentiment on growth: Also bullish outperforming the S&F) after Reagan's tax reform bill passed the Senate; and 2) in 2003, the last time we saw personal upside to 2018 EPS from ~25 405% and stocks still cheap vs. discretionary. © Buy a5 month 105% call with a short 110% call that knock in if XLF trades above 115% during the life of the trade re m— * Gross max payoff if knock in is triggered: 2 8x (5.05%/1.75%) Regards, Amanda Fag Director | Global Equities Merrill Lynch, Pierce. Fenner & Smith Incorporated. One Bryant Pack Sth Foor | New York. NY 10036 1 To: Yefliey E.'; Rich Kahn Subject: Financials: buy XLF call spreads another 20 25% upside given the many levers to the Trump Trade: less regulation, higher interest rates, higher vol, view Lhe larger cap banks as having multi pronged upside given the aforementioned points. That said, given the velocity and magnitude of the recent move and uncertainty around the ir-pact and timing of a Gross rx payoll if knock-in is nol Iriggered: 5.7% 114,9%/2.6%) = you have upside up Lo 124.9% Post Election Flow Skews - Buyers of Health Care (via ETFs} and Financials {mainly ETFs) + US Buyback Flows * Cons Disc, Technology wad Financials are the largest 3 sectors for US buybacks (over 70% of execution). We Global Positioning, Nigel Tupper. 11/14. Large loug-ualy fuuls ure wore underweight Finnacials thun ay other sector and are UW this sector in all regions. Future of Financials conference hosted 30 public and private companies at our Future of Financials conference. We are. I Une period sinc: Une US presidental sletion, Une thro: Lop performing SBF sectors and industry groups have ul ben finance-related Banks, Financials, Diversiie Financials) “Wadon Gang Moment: oan: Rett ssa vs. $49 500 - us Source: Kensho Technologies he oe Shes, Michoed Hartnell, 11/18, Violent rotation: record equity £11 inflow, record financials inflows, biggest Bond oueiow in 3.5 rs, record EM debt outflow. Regards, Aranda Amanda Cas Director | Global Lquities Bank of America Marrill Lynch Merrill Tyme, Pierce, Fenner & Smith Incarpornisl ne Bryant Puck 5th Toor | Kew York, KY 10036 Phone: ES 1obi SE This message. and any ateachments, is for the intended recipicnt(s) only, may contain information that is privilged, comiantinl andor proprietary and subse! to important terms and conditions avlabls ul pine hanks Tamer comfenmildiscliimier, 17 yout are mt the iene recipient, please delete this message Please noe The inform conteined in this conumunicution is cantidearial, may be atocoey-client peivilcged. may constitute inside information. snd is intended anly for the use of the addressee. It is the propery of TRE Tnauhorized use, dds or copying of this communication or any pat theeeaf is striely prohibited and may be ualawtul, If yon have received this communication in swar, pleas nevisy us immediately by retum c-mail or hy e-mail 10 jeevacationi gmail.com. nod destroy this communication und al copes thereol, eluding ull uttachments. copyright -4l rights reserved £ _—E~ Busmess Wire wackssrusR so Rockefeller Partners with Gregory J. Fleming to Create Independent Financial Services Firm Firm to Focus on Weaith Management, Asset Management and Strategic Advisory Viking Global investors to Back New Firm October 04, 2017 06:30 AM Eastem Daylight Time EW ¥OR4 BUSINESS WIRE Rockefeller hana Ser es, Ino “RFS 1 he parent comps of Rockefeller 5.C3 and Srsgory J Flaming have aon form Rocker Gaia Mar 33srmont Roc feof or“ imi 1 indopondont irsrcia services 4m cused on neath mata ment st management and stategi advan. he trl coco bud Upon tha 35-y0at stony of xcs £750 = ex h 37 insasant manager: asecsiated wih ho Rocko's ar arity rough the adarion c-breaser casas des and re, ch capil (Greg Fleming wi corre be Chief Exec. ie Office of Reckefelen sor cssing. Ke Fering, a longtime Tnanca Sonicos soci, was mos: cont: he 2rssident a’ ors Staiey Wear and Asset Management and 5-cr to a, the Presizent of Hemi Lyne dng G aca Investors LI '¥ dng’) il ssck tre fr hough sn nsestmen: by ce of investront uss. Franca te ves not discosss “The tos at Rocksfallr inanc.a Sorvoos has epar: yoars building he Highos:qualty avostms : managemar fm or famlles and istutfons ” seid Jy d Rezkeleller J, Caiman of RFS “wie 53K onal t Gea leadership snd Yidngs Supporto sxpand tr Rockaaler 2 afc 375 bing “2 BrEEUcts rd sonics 1 out clients Tris zoméinaton i alo: Rocketeer © 2..on 1 deinguished legacy of serving ‘ar iss, nea 3 he Risketeler ara, ue we 2 “orzons, shciments and insations. Under 4 lem 3s sds, 11 (1m plas fo supand asset mars3omant cus on global 32s ies and 5% investc3, 3d t te waath manage: capabilites, and cui a fos Adsisory, and Sate = Avieary * look ‘rand essing Societe a ntfs xt ©1551r, backes by the Rocketeer family and my new partra’s at asset marsgsment, snd stategio advisory! Rozkeleller il be ond by a Ying inestment nd a tet repressing the brosder Rockefel er ami, snd re frre manent The samen gs nl ciples mak subs ST a in Rocke vst ple years. 1 il ide the apts necessars for Racketeer 0 execu s stags. enabing he frm broasn Tre board of ti nw fn il nclude Vi =emi=3. Dav = Racketeer, Jr. Peter. Ooi. Reuben Jeter 1 973 Brion Kaun of Ving. Addionalindopond: ioctors vill oo addr i= duo sours, The srsackon is sue lo ce ain cus closing corsans and fs sxpecled ko cose 15 rsd ne: of ne: sear Artes Partrers acted 52 he 1197c1al advise UTS, and Ae sir & Gals gher L_2 was he aga advsor RIS Paul nese. Rifdnd, Wharton & Garson LLP was he 69a advsor 0 Viking. About Rockefeller Financial Services As 0f une 30, 2017. Roce sr & Co. has approxiniatey $76.2 tion n assets nder ady seme: fo +3 vidual and fares, family ffces, 0 prof anganizat ns, fo sndations. dese is. 3+ gata itlfuions. This numce: nc des 161 assets under managarsn of azc-cximarely $10. billon plus approximately 55 3 bi cn in adie asses Aves assats arcrecture prograres oats” assignments, cons dated reparing. and account 13 and aK et preparato1 sevices About Viking iki Global Investors LF is slob ves:man: im 0.1983 in “465 its offices = Greemwieh, how York S51 Frarcinco, ong Kang and Lando The fim mer szes asoroximslely 525 billon in eas al avd uses bndoms ial lysis to selctinvestmanis. 31marily public and ¢1 vate equi secu es, fom a de (ange of dust 25 3353 y ¥iki's 5 einer ns an ves ren advise unde 13 Ines ent Adis Act 1 1940 Contacts Media: Teneo Strategy Stephan Cohen, 212-886-9332 stephen cohan@teneostrategy com or Vested Binna Kim, 917-765-8720 binna@fullyvested.com rv i Gott eee a Fw 38 Femi Boars Viking Global to Back Rockefeller Wealth Firm Led by Fleming J — [EE —————— ER —— tdi i Gh tn “Strategic Advice’ Hiranonr ik Silo Baz Rachelle esl Firm 5d by Fring - Beater hd pis 8 is, i do i i go Ast ats ths La. Users i ih nd nad by VER) a sy ai, i Tig id hts md wa, sshd aust pani ts bce oie Sly mien se ens, od on os ke a pe Css, Pleo hi: ies 55 sn, i Fu fs fil bon 0) Recher, rer ht SIG in oe nie sd et nna srs, nd do EA $5.3 td 0 ken nis Vn a ll vs 0 ta a nance os ml] se uh iin a Ti ay ts Bao” Pt a To pd hs Cot Ss ss a, mel bby, nt 265 ES Et ly IO AL id Boh Ci Gal, whit we be Adnan, sud 83 Un a ans, wk so on Uist Dis ls rs Th Richer Ti ws sda by Ard Fares, ste a ord vey Gua Sos cs: on tera Clits Coletti bos fen WK Tae & Cela LLP pride sis, mums stab. Pas, Wi, Kili, Ws Gren LLP kl seit Vins Glbsl. TR wt fl pad ies ol arb Sd gales. Pr AEC RES le HA ORS A Beh AK SE NCSA Py roe ig Stott els HF by Poin Bs Hiranonr ik Silo Baz Rachelle esl Firm 5d by Fring - Beater Br a EG Ess cA 756 GORA Baek ack ACTH Sed 7 “a Hiranonr Rokreler& Go © ha vi Ave WHO WE ARE unk FAN SQozeballer fi Ca is 2 dietinative Arana sersices ev thats prvansty held and inde sendont [Tr — ™ paren Roker & Co - Whats dre DRIVEN FOCUSED COMMITTEL tha rrslacna soundness, assessing ivasrman: aavidicgirsig thi so Lions crea: va cumen, ard persaral appartunites through a globa for ne sxc isticazed reeds of 1152018 101302017 8613017016 Aout Rockefiz br 2% Ca: They Yous Leter Rovkeeler & Co teem Tris SUA Taz he iano Rosters Go + ni ve Fnckafaller & Co. sprite ovrad and focused As glohol cite wtb on gasgranhenly on tas civersa inestren: anc Avncia neens of Lnconstrainad aapranch to axser Panagamert our sephisizated clantsle. Frow eur Saginings wa crow how mbortan: ts to ca-ceive se sorkd a the Rezeafeler foruy cFice, we we today a 1 is Lotuliy ii seeking io beet from vz sseelin “ul msereze, ncopereeil ene merggeren. snd 07 opporanties ww Geen Ou ase welt advisory firm, with a vison to hols cur reragement tes spesks 13 snguages, an lars ackioue thei asl indication of the globa perszactiee we apply ta aur bus ress 1882 TODAY z ockefi ber & Co. hus aszrenmntely $169 bilon in esscls der adsernent fo y inchidudls and faves, aml oficos, navproht agarations, foundations, endorien.s, are gel sales if Sapam 30, 2017. Tis muro nds noe sez under mansgeran: of spzrosimerzy STi bil or plas sppresinatey $35 bir © adore assets, Adusad assets 63st non raged avers tha races ices, uch. 45 comtng for open [EE 0 CEO MESSAGE ur TEAM wars Rosser Co + wh Ave REUGENJEFFERYII JMMYC.CHANG,CFA YVETTEM.GARCIA DAVID F. HARRIS, CFA Hianaging Jrector, Managing Divecror MaraginaDiector, Maraging Director, Shes cert & Chie Chie? Irsessment Gerersl Counsel & Coif vessmant Secouive Office Strait Chicory OTe Ofcar STUART HENDRY TIMOTHY J. EUZABETHE. KARA VALENTINE fisnaging Director, MCCARTHY MUNSON Savor Vics Pesicenr, Chie? Cperaing Henaging Hector, Meragog Ditton, Director of urketing Office Chint Compliance resdarrof Officer & Coune Reccafel er Tut Curran, Ns & The Hazeatel or aust Company (eleoare) [EE su wars Rosser Go - What ve RATMOND, DAVID WESTBROOK WAREHAM Mizraging Di-actor, tisvaging Jrostor, Cha Finwal —eud of Weuth Offeer Ade sary WHO WE ARE WitAT WE b Subscrioe for updates COPYRIGHT & 2017 ROCKEFELLER £.CO. TERMS OF USE PRIVACY STATEMENT — ~ — Stent ove INSIGHTS & NEWS NEWS AY [ARPLN NGS iB ROCZFELLZR &.CO PARTCIPATES IN ROCKEFELLER ACO HOSTS GLEST OPERATION SATKPACK 2016 SIXT ANNLAI NEXUS GORA YOU fsbo arvranty asa biases, sckeder o Unspanp amd SURAT ROCL=FFLL=2 RESEARCH SERIES: [HF MEWDIHBR CCK PRESENTS AL IH: DR VER_ESS ECONGARY ATLANTASOCIETY OF FINANCE & Fiwlubinlar & Cc bu, ov 200i Fes vile 0 vo Forel afell Tlgmn 2 Socvee INVESTMENT PROFESSIONALS (ASF iano Recteklers Ca ews LIAVIL FARIS [ANZ LD | AD E30 SORT RAL CELE AL STARS PAL AFA ATINSTTUTIONAL NVFSTOR FORUM, CONFFRENGF [————— on Hiranonr Redcklert Ca = News, ro Seseiera Ge rcs INSIGHTS & NEWS INSIGHTS WATS NL fun assess ow nner J satis 3207 SL0EEL FRSESICH] J FACS S—— Je ————— wo Hiranonr Roseceler ae rg Brean rckes saving He su Hiranonr Roseseler ae rg Branches saving He wt iano Recker a. Irene Genpry Irs coring Capital Markets Hears 1.2175 19 0 ET Company Overview of Rockefeller & Co., Inc. snapenot people Compmowmer Keyes forRoeieierscome Rockoollr & Go. Inc. a piatoly owned WE Reuben dettery ll, 3, investment manager. It provides 1s services t High \aragng Drevin Frese, S20. ans br of nl woilh individuals. hi Tani, amily oficos and | EPS elated ene, nc organized as domesic ar ofishorc (hon-U.S) companics, mifcd patnorshis. yy, David Westbrook limited liabity companies or other types of legal Chu Taal Oo ars Mirage Cit anion: USS. ogislorod investmont corporis: Truss and other fduciary accounts , Foundatons. Mr. Stuart Hendry endosnents. charitable and othct nunproft Chi Opesting ces sc nag SHecic institutions; Taxable and tax-exempt acoourts, and Sovorsign Nalionfs). The fim manages separals Mr David Peter Harris FA client-focused equity and fixed income portfolios. The Stic amegn. To 0D Hee and Him invsts n the public cgay markets actos the globe. invests in the fied income m... Ms. Yvette Harie Garcia J.D. Cnt Alias Coe, Sucre Hang a Detilea Description Sica, ard Seve Ger Compares vf Feel Vest 2017. Phone: 10 Rockton Placa oer 21248500 New York, NY 10020 in Unied States Founded in 1882 Rosketelerd. Co. Ino Key Developments Rockefollar & Co Names David Rockefallor, Jr. as Chairman aes Rockefeller & Co annaunced tat director Davi Rocksfeler. Jr. has. been appcinted chairman ofthe basrd of ditoctors. bi. Rockolellur, a lourding marer of the board of directors, suctoods Calin G. Carpi, who has served a5 chairman since 2003. ir Campbell wil remsin @ member of the board of directors. As chaman, bi. Rockefeller wil lead he board of oetors is oversight ofthe rns business, and wil wrk closely vith Rockefeller & Co. CEO and president, Reuben Jeffery Il. in supporsng the firs delivery of best in css woallh acvisory and usselranagorment sorices Lo igh nol woilh individuals, lamlics ant institutions. Smite Companies Bymavery | Recontpvite Companies Tangactons Company flame Region we Ey avery Luc Untea ss Rea Pana LL Unted sices Cohen IT orners LC Untzd Se J ———————] ww Hiranonr Rachelle & Ca. Ire: Fiate Gerapary eorrfin - Beomserg Company Name. Region “23am com, Unted sree 1202222 Ores, Inc Unezd sien Request Profile Update Br BAEC Eh HE SEO SEE Spl S51 su CAREERS ERE wars Sozetier Ge = Comet OPPORTUNITIES Ls wf Reaksfil er & Co. 15a d tinct raza sences fon thet is privace vad ut indspendert. We take great side nthe ile, cepts and vier of ur profissione Cay * ~ NEW YORK, NY (4 OS ITIONS) CLIENT AccouNTANT SUMMER INTERN-ASSET MANAGEMENT SUMMER INTERN. MANAGER SELECTION SUMMER INTERN-WEALTH ADVISORY = WILMINGTON, DE (1 POSITION) VPI SENIOR TRUST ACCOUNTANT Dorit see the job yeu ane hook ng for? Yeu sen sobre e resume for “uiure eansideretion by icing hee. [E— an Hiranonr Roceeier Ge + Comact COPYRIGHT & 2017 ROCKEFELLER 8 CO. TERMS OF USE PRIVACY STATEMENT & ROCKEFELLER & CO. ROCKEFELLER NSIGIHTS ACTIVE STEWARDSHIP IN FINANCIAL SERVICES Eman Song, CFA ROCKCC.COM “THE CONCEPT OF ‘ACTIVE STEWARDSHIP’ WAS FIRST INTRODUCED IN THE UNITED KINGDOM IN 2010 WHEN THE COUNTRY’S FINANCIAL REPORTING COUNCIL INTRODUCED THE UK STEWARDSHIP CODE.” #8 ROCKEFELLER 4.50. Active Stewardship r— Nine years ago, in mid-March, Bear Stearns, which in 2007 traded at over $125 per share, was sold to J.P. Morgan for $10 per share in a transaction that many mark as the beginning of, what we now know as, the Global Financial Crisis of 2008. While it is said that the passage of time heals all wounds, the disastrous contagion across the global financial landscape, the collapse of numerous large financial institutions and the loss of public trust in the financial services sector remains on the minds of many. Whether it was opaque counterparty exposure, excessive leverage, insufficient risk management, or a lack of corporate transparency, we now know that these factors in combination led to the near collapse of the entire global financial system. While the financial markets have moved well beyond that terrible day in March of 2008, the public trust of a very large sector of the global economy is still severely marred due to continued bad behavior, lack of corporate transparency, accountability and proper risk management, as well as risky business practices. # ROCKEFELLER & CO Rothe Gomrcrote dik Taecrueasardescaed ta ssa noite mar of "nglard Sark Cary cai: lacks of effet ee cane alder Ii sraed 0 adop & saris iF We Fai ordi sbi ebay eden aden lo egg wilh compe bey itenrath led bers Uz many sen © Pranggenen: en seeking bs morse buses cheurmertats dative Lp essential coporte gvenarce orscizes aac disclosures. [hese these stardes” Fravoarescy, sees sob ac dk manga, stores ers Foca on tesking Fasparsiol by SrA aCCaUrAD Fy, Sarporate strategy, dependence major rafeas francs farsa seacoast and began wale cwslon ashley At gran snencesn regan hos us iis Whey onrst To perc me Laiot swnlomrings, wopaw b bly Veta Uri so rae the glob irvesament corny cparita tack 52h 15 wb cri 0: Active Stewardship is Born hs venept of eet ve Tw acepiun ° stcwarcabip £533 insaes b5 idevity dotartic] snemrcsbi was Hot incduced odes many ritions ag ern bur ars eke anc inte Lec Kngiznie mare highights ane seb af cochagh nmataty ion ck a 200 ann tha snare rospmnebl Tins fo sharerclders, macagement cany ard ths, ntieyed tie LCStuwadins ens var se closely cimpte charge ard wa carer Coc? Aczording To tw code, moniter their compen es anc conc. Ye bu ieve tut such stevesbia meses ThE esses 10a thai 5300g doa angrpemarts can aie a lrg ara mipactad no p-cazively opine separa hok sue sx1g apse. bab on hu nose Ragan ar oman an ear As facanes, eine sha prea ly 2 somo lve gorarringe, ridding ekue one clerts ind ether staebs ders. Beyord the puzentia ong rare an “ernivast er greath and Taday, acl ve x pancdth ta esaley beach of sedinie rational wyilong svi aw gears BSG) aude, oll tior: iss Furnas wid vowsnd ons vais the, ark pr Les or Cee we sucig ihe efforts te re Id ef $IF brlien fellomed siz aesting with swat Lity =uati ublic arkess ate tha ard lnrchad the bese LS rhonda duc as, ne “rane ca, 1a og snseathe Smaaveibi Cade ot Socistellsr Ca reek 0 sss wore mart apaert He orgage will aosede of diosa Tesncial soricas sentir Embracing Change: Financial Services Sector Sore oulof betrsana for Wal Steel save indir rosa | ay dri as a srg se tach 2008 ae 2 new sive vg Ly applets ow seni bo ok Val mars ol args barks lu lazer endite nen, Hoarcia 2 gr cart steps to charge ts res methorns in 200 by revies faruizhs camgn ax vara tha best corp aoite grea ce za dele, ing oharousiars sar dries ard ance tas ne ee af thare. Bucers pact sane tue pws sede ard mplemarting 3 AGTIVESTEWARDSIP Il FINANCIAL SERVICES | ROCKEFELLER & C0. vi / “AS THE GOVERNOR OF / THE RB NK AFC ENCILAND / THE BANK OF ENGLAND AND AFTERMATH LAID BARE THAT MANY OF OUR MARKETS DIDN'T LIVE UP TO ) THESE STANDARDS’ il / OF TRANSPARENCY, , | RESPONSIBILITY AND / enphyes la nnge nn rou vibes amen be acacol cok mane Dviea” Ge lages bans aan i sport and bos weensigh. AM WE tat Lancs nade she oat vsivle public y eekneslodg ng rspcni- Oren’ tae sgt orks sign fi- + barges, hoy ces viseeur- bliey fer Lrathica rac ces ang carthy improved pak dacosares mittass ot he boord level nd. racogurrg past matakas They ky adoring new dokzies nd implenented compa wide isk shad tar boc we dart by Cor Wig Ls igregus iy press swale me se wo = veing bark ng” in thei sige eatior are tess eras anil sasity in the ULE, oh enlists grin insane managerial west. srdescnomic opporturit® Ar position or Una Kise Crvicer Ore Eze puklic y comm trae the sere oF tise stron, ws tie rapatrgmohabarc anc tka 1 seskng respanshle buses gonl 2 oe cient orisrted, oth with srsUtngraincenTie drt grain ard fon IVE a Focauetan ry on aseha dens QEAMSI INE GEATEAIAT AIRS nos name da spererl ia ard vegas dlke. SUL AGE ST LPR sary iokeoking #5 ROCKEFELLER & CO Take ac emacs campares | lanersr wala omn agains rough loa basen, ether te ruatworthy and o "sent Tans sdwstec (wr aawss model alirelon bo pase bind prestios lend dusinesses. Bens have leng run, & eductizn of earrings sacuenzes oF oac oshvio-lorg crzeard fiskzoarrs dusiorsin vesarcanfideaca ir do dard Fa aes of fe Clohs Fo 3 ¢ resull, Sandint Laks ae wsiol Cosi, includ ug Bese ML its sss sdinisteazion ir rire enemle, Fig eep ar pat werd L verging fiom lig 1s ds 56 eu § dhs hae represen significant otetiol cama los sera, wake of legislators ed ropulory bute usside for 59g tern investors in and ore; hr dering. hs card leac =o sdetioral costs “OUR MODERN ECONOMY REQUIRES A STABLE, TRUSTWORTHY, AND EFFICIENT FINANCIAL SERVICES INDUSTRY TO FUNCTION AND GROW. ACTIVE STEWARDSHIP CAN SERVE A ROLE IN MAINTAINING A STRONG FINANCIAL SYSTEM." ROCKEFELLER #0 Cover hp ne sewers] aac, « Compensation and incentive s1avesrds acd encase Cakaral 2% 5ur arts, we have oy % commanecstay prgagac sib anand of eineras + Sustainable finance and enh Fs loi fous “+ Financial inclusion os in arses of gone ring « Implementing strategy on populations corpliance, zo reac el + Improving transparency over As engaged irvewiers, wm ballaa HRSpOSAe bsines pki business standards, values svn len mace sigan arngraes, Suu bibover wan pean. 0 management systems and Tela gr pe fo tok bal mce on.” net vn wemadebip ane ROCKEFELLER & CO. HISTORY OF CO-FILING SHAREHOLDER RESOLUTIONS IN THE FINANCIAL SERVICES SECTOR AFTER 2008: 2007 isl Fargo, Rogor on Business Standards 2013 Walls Fargo, Payday Lending 2017 LP Morgan Chase, Proxy Voting 2012 Morgen Stanley, Transparency in the 2015 Bank of America, Separation of Chair & Repurchase Markets ceo 2012 Bank of Americs, Internal Controls Related 2014 LLP Wigan Chics, Report on Business saMerigogs toon Standards 200 Sts Stet, Saparste hair & CEO 2014 Bank of Aeics, Roport on Business 2071 Morgan Stanley, Restare Confidence in the Standards Financial System 2014 Viol Fargo, Report on Business Standards 8) ROCKEFELLER & CO. INSIGHTS@ROCKC OD COW COMPANY, NA COMPANY (DELAWARE) %J ROCKEFELLER & CO. sm Aging Bull Where we see investment opportunities after eight years of rising markets NTH ol og NW ies it 730 wl IB / N Bi Cover Story of the sins since 2014 have been driven by multiple expansion rather than carnings growth. In this issue of Global Foresight, wo highlight potential We examine emerging markets with Jimmy Chang focusing on Chins, and aE article by Dr Mariels Vargova The Charging Bull Tae Hear of 3 bul ke ply foes ys, Gres Ugo bs bc cx ug Bo aa mkt posks— dig sbruply. Commer hess son on Lowes Buby 192050 1959, We belo th CAPE RD i co os Sci Kon ss Ching Bl a sry srt hos nid ru i DUT le, post Ll Sug CS. lol Bass Wl Stew TL nol wey bores di pi Bsr subd uta actus, Horeeee, val he sack’ proc Commision by he City of New York mr ay or of i pes th cad of tho Rosia Tie tos oc ths dot ca, iosior mesa bask, Rader, the hove and sc hlf.u ee donot bli wea aa alt of concn of act Stu wa inh wed ume Devs dy back on USELy BUDS thee 1.3 bac ote ubdacd Sonam covers pine sen To fhe New York Such Exchange, 63 ve secsucy cxpSecaced fa the US races GDP guovrek Tre hence was Fehon sero Amat di iin who cre. 194 N52 a5egiag about 20%, ts a he coonouny as ot ed Chg Ai desmonsoee ho bef he regs of WAR th Gees ths 0 duck ust pons ths CAPE. 1 1S. ocomary afer the nck tare th 0 199, rs S10 BY COA uci ths 19008, US £0 GDP porto Me 5 Stodion ducted ie stocs ns coove by the 55d 42% a oa LOK-L989 gic bt £35 i. cock NPD ands hor capecrettn me rantcred Tivos norte Coto yen Sue the CAPE oto those pais cso en of hi bls novo, sce 0 enous] genet nn BE 0 bose GCL ecg Gcomcunis oeti end hs, ning arionn striioes pair tower co. 106 DELON VS 00 USP 3 Sang ths cr “ding is opposed boon the erect se ealobic tae OR A aiconaest ane i, “gin nl was Fo es one Afers Couple of sks of publ press, Ching Bt recived ne sale a os nutes apm the rreetion of roads and Wacko, ace bas boc. tale fo ourins ghotos [2] NEW, YORK POSTS RT (or Fr age ard vs echo dv ce rth erg, A oe es Ti tans] vrs opprrtenien. os ee hts dered re. /] ier ward heres annrapedy pil ded | NLY. Stock Exchange grinches pment om the continent, We have hee re a rar ot Chrish Ht poull strac.ive emerging risrket (EM) aor arides bat ane mind can ir Caistmas-git Bu mie fic, Frarhly t emia, el racket hd sigs 4 2 27 Eo i oe disses cor sdroricand bh. eet A are Wiehe meta lrg err alelel coma grove lid WBE, oo i X ) Lom Thm The Challenge of High Valuations 8 Tip ; 15 1938, profissuss Rubert Shiller snd. Tob Carnpbell arr era LIPPRRET (EIN hich vers rings tv Wives perdi th LAST CHANGE 70 Wik A GIDL CAPE ain babes ily hl we bral U3. se i EM Grawth? 14005 1 Higabghts don fom she 10 ares emerging ir CAPE cation se: foes outside the US. wath cgi ase Ket hich acct for 39.0% of the MSC Faverging Mer- Kits ves ver ts hot i dove rast, While we E15 InAs The grwth epee of tis gree appear sr Ire besa sn: conse: i: eects of Gita Fre. 70H pid. Te median rea GDP grows for he reve tom son LS. ospartisuion we belies thee sped. BEC OUT 5 orate 28 235%, fs Topaletin growe tance of CATE ston hon onspacing he vey dec dives TPH to be es than LI. The ern “Smerging market” Sto copanics 1 he 1S, wilh on tae rbot, Wil 0% coined 3 the 1580 oe frankly, mos of those on alton fom 3000 et hooks bute on ay pla, hice IS have liad merged” The commie with he mest wie cin aco CATE wa: cain ol wh, 1PGETY conaric gonah tcl wes seg hos anayricg small markt, Nas xen spl, Busia as ih 030g, growing Sopeltions namely, loi, Indore he owed CAPE rc i the wkd, bus ks oat ave fs 92 97 Male. Toure, hese comics heee smal. <q. vey somsozated i conmmodiy Wusiuascs whose camiags "MY rots thar, chen combined, do son us equal Sek we gly eked Korein se ALL 1: KEY DATA FOR THE TEN LANGEST EMERGING MATKETS. ows mm Am es am om en me am ow SY ww wm ax mw ws 2c es ome am ET I I TSS ws an am am om am ma ws wr ma wea ane mew mx ome we mm ee ove ae woes nosis WH WooMG GanoNs Ar hed eos Chin 52 market thes bs nko arsed valid actin NEE Populations . sbi 1 grt prpoct.Hewenr, Cris as lady A 110 hulle Soh Kone 31d Chia esd oe. iv 61 oda neo racer frm coroetion thot atl mr. 347A POP. Cini ha tr smo pavers Eee rn Sa ain oma J Che ar air ail. ile os the pul ir Lhe worl se mts nse dros posse fo. coed he cece atoms Orne ell sey ceo ee ee a Wc NPE Jeroen ages en. he U5. with ined Te et emia abl enya 44601 73 yeas (hel of | Americas are 4 oe lie. ra RN oe wooed though se uf the sold younge: developed markets. Aging ihe Ls ded by compara io med of are Stn Sores or ssi he. assent EL Sb ST bere valuation ard pls for goers. As the sd est 16 SL cecil, Wemarkabls people 1 tL. en met le Cf we ele tal eis le hy red a mora, ecomy and sc or poten rvements. oy meg eh robe TL TE ST Tn Wma in mre del he ries ron croc SST ors re ame medio of af or bs 0 Milt Vorpors. oxi diary fs ears ler an he U5. CHARI | CHINA POPULATION DISTRIBUTION 2015 bod u - ———————— 2 ——r ee Cm - J ——— 2 es . ee — —— s i ————— o EE —" “Wale we consider domograplics as en irportaat long-term. 0 CARI 2 with progressed younger population beacksts ict fo sting os diets in hs Thed Qaree 2015 going tour BIG: nding sel nese boctores ew of Gin Fons ght omstin or he Ah Ka S30 fo Ingle Role Grn pertarmirg wel over the list few years, cespits bring the Young Ideas soon andthiud oldest countries inthe world with the media bpan has saen a long, steady esanaric recovery hebind the osuiation age af £7 years {once bas the world’s aldest aries fiondy policies af Prime. Miner She, Ihe LS. bas graphics factor into economic en mare by its culure of iar vation eamatically in your 30s and 60s in he large: ran, has led its Taarker’ returns. Ry cam. fom teinyour orn ORIIGUENICS aClOr Il) pen. ams bas en aged amr mony CuOnOING Gronl gs corsumpliony 1 HELE PoE 0, Fonds wih ghar tes cn CRAIGS TAGE (1 YOUL BOS of th La Sime year. 1 odin wil eveatoll weigh on the ii) 05 IOI AET6 Lis (1 youn aber contr tho challenges workeee, 30s ard 43s, ea wel of 15 aging popmltiors, Chir Ma ven spe compl othe Ls. xd smqcbly C2! te wits oye worsens over the next er pears wher the murrber of retirees Sd ts oe ges ik el bs mate iy exceed he number ol re iraritioles the Tavs forces. S50 39 yout old Vimemammne] Wasm, whe not end son the South Koo 5 the oldest cnciging market sath & dion 362 shania pave the seay for ecomnmis vines that we helieve in FL Ent ioc du Tat. DBS TT ri” ig mast che ft mers foe A AY Sa Ll Cart Ln hres dened nc on logos, EM wnwestors should uadewsnund the seslizy that the ii SR Gb ii ki . est Hn pears ceonoank zrowth case outside of South Ask aad Southeast ie in lee Jus i 3 yl Rid isp 4 od ro adie aia be aostly Liuted to poductivicy gas. India has tho best 4 ih hy Wate Hi Fritts bs be ie, lv — CHAK) 2 INDIA POPULATION DISTRIBUTION 2015 a ) ” u er —— wi er pie rem, — - re —— — wa EE ——) ——l TL ———— ee —— igh rp. So th cron bas dred good raporT i Get Counparis the Sint mates bine, Wes py Geran Chazeclor Angela Mickel hort ws spectob ze. f= EANG ors av, typicly havs rot zed ou robs lite a Scprezabos The poiical ck fn oxviaacel rings lobal economy to gence hei daring ean growth Lc cow cased in ol, Bo eoursgad tht 1 fr. Moo ono sen ao SSP S00 es, one non ly Le Five Sta Move ve sy fot sot gion beast rom 3 tongs scone. lstions, whic cork bode well fo hse at satona] lc aT ———— buicig ny Many bull marets have interacing hick cies 310 bons they tenunsasdllisncn wih te Dersosratic Unser Porky tgs} ets avd end. the luvs ball mario com amguably bu vince sees vos wep fost arnthar shentimvard ives gerger dow. TASI30 barsh 9, 2009 fem the C163 oF Cinianks, Wikrars Tce on rec, ve are sce, Hs onl st am CTIA 53 hing 4 hes: corer since aly 20. Mh Vl prs i giao oil rc tn merle monn Tr nbd hat eri a gn he wos wos mn, read the March 2019 deadline. Hy his time reat sesr, we © C1 for She heleagnerad hanicing sexta. The SKU Si bi Con akedioms tat dn snd igh ear be ang sry All EE TRA > he 5 ia exringa and te awe selling for shot 15.7 times. The 11S. Aging Business Models pst The “FANG” stobam Face, Aas Nolin, sd Gon Aa oko ppt anv, we se pola Fortunes are dorupeicwrten wetness eid inpresion bn Burape hse Rai hesliomls ol oes re eves sod les ee Fog elon ross Spgess wn ZH: Ws bl aoe Ue see tr hoe GS, at Manlt bo tl Mille umerics se video ofthe eudezshie i. the Houne of Representatives cars sik sorte etal, eb on pode Spee sed Wicmosa oth wel i sve te ple Bf suse obs ased Fos Uh rerio BANG tbs, hs income uous of L285 ol SEP ale ult sar 017. S00 Tick, A oe soe oF rs bl marke, wn Macc, 200, dni am 8. cmorging maksts of ors ata lations, bat cs ee compares lad ark, luc of $326 bilo. Todas. aor Ltn Sea panscen bs gil pono he gnomes hc tt vo br 7 lr, Thc hes m5 ps cent oop tng eve a Sp A Eo BAA RA A A ATI NADL no Coser an mrt drs. The challenge oil be scone oestrone cot nd = Yesterday Once More; Tomorrow Never Knows Chira's housing boom once again lueled global growin, bul how long wil il asi? embossed rely irk ee th oie 1 Di Not Bat Against the House mathemati, Vere is nus exas dy a right answer wach a AC az0uad the ane thet Amecica lebiased i Biceawmaial. —— Chimento soso: Cini sro ooend es or got a 1 Nant and Conse of ie Wel Revolution. Dan: Sisoping thes: accu to perc and Natons and Is gencealy reereed tose Toe Woah of Nosigns, Soaked on sufouans that powered swaghiy 10% ceal GDP tse en, wy pox san or the at fous doa ud iid ms Tr mad ch APCs 10 SOMA COLI 150 mn ot ln, pcp uta ove. Toca the Chimie er end Scomouy be Ifthe wd os pasos wercantikist and physiocratic sconoic theories tat dogul- PHY aed ar road cbr Sos he SALLE camry, Isringl, Chins ie had le tnd th Adee Ste Metcontih theory hold saat covateie: growvealcs byunazi- fee marker copialin. While Ctesunprosdertos economic nizing domestic production and exports, ad wis the bess os awcension was inde fore oy wrlsashing the energy and “he SEAR SE A SO ath of aatoas vas dered fromthe vebaoofagacultoatard hat alway heen shaped hy cho avert ments sessy hard. EE Toitamton Aen To Hema Tot sete 1 ; : Fr Are Sao gert io he Woah of Neos mired Unit o masern cpialiom 1 may pr ands bad a eames om one erandimg bother. ams C9850 rrwings mens policy in buiking vp Tk fo 797 Tomas ecw ser ys pes EGE rset. Inds ns hove of lok exports is Tut om mame anid somemerce. In Iemiary 1977. in celeira "ttrarkahy grown from shu 15: in 1530 tn secend 13% hy of Aurich icomenr he eden Fever pal 2th gest in te word Sow lr he Chin vee Richer d published the paper Hie Kefevance of Adam Swill. Produces mare sombrera thar Mexicn. Wowie da. te Tks beomee ire elles nth nah bs Gls Fes Cisne asd uly vidas] sell meres ne welfare of the greater society. oral wo seul ta Chins gouty skyrocketed, set prices i ran i tt on oghom ost sme earned Shia lll REARS PR fly chu bible in commodiies sed emerging wacked stouhs. By ly 2011. China ld ool the ccm sod tckle he ket. Chive olsun shld the ers spends ond The trast proba ued wat lo be mors woreplcusad oro lado usd rls shi, Toe mol os suchas he in Chinese plicymakss my have expected. Unlbe the Liggt bouwin subble evs 12 Chins erase wh rm sts ndteunlur- drive poh vod rer whist pov ul sured res 5 ese vere he spun S016 Kon runt woah] be cumolled by ads the shpeine ul China was valli he wl phrssrats sovmunis (beury Coteus profs, osetia svn Evol would Jt eich posta tha the ell of 8 sation ie i.e lard le i le Had” oF ered vonmiers exit ore dere. ilar Tor wor, commpion-drven wede Wd Toe vers Chis hos sid sep preperty prc esis le mrs con 1 mat fois atl APKTISEAY EEE 1 a A wt crc gob] epee nprediabiity, ile arcbIn . eaioed 5 us i song Kon ae Long Kon okt Tog ee rnin. fn esol Wi fr oro of th war, Cae te wm os ens se ees to a oe Ton Uc a sng ie Uris aerbinty cThne Conapie sonata nen bbs ort Begs lit ron Lng coal lft niles Sania tic ow cost ons in 2000 5 sue ot, ith 11nd hooey rt round 905 ard many SEyEorkting dpmsic pepety Pcs hase also danred tamilios holding multiple apartments as invosmacats, Chinss mary Chinos soveswrs views of foreign propertios they are honing markt ana oi npacton ees. onsnpion bargin tiv 0 rice in Ding. Sangh nd Sherzher, a onstvion, a eel he general con: AS ow in, 10 eondr Chines irvetoc has: 54 op angry prices CA 1, he Dap Roving see acres i 2016 0md 2011 cas ufo ines sun he lobe 44 gn of oes. porn egubtorstn cont dhe hosing tac, which wanted Warten Doffrs Derkahies Dichavny TomsSorvicos has ie rie decline a 12 Horever, the Sowing conn soon eat oom 7 with Cais vil con o brig Amicon eho hen ea horas pees rset, redial, ssdentisl proper tings Cn, Bowing prices ohare be espns. with dosbie-digt increas ir Hn is, MEREIG MRSC 0 ie Ae Tobe ran nes oh An Under-Appreciated Reflation Story tiscite clear fst area manera driven hed mentally Soy MES EW Rp S oki 11, srehanador ha he did mot eve cidenenin the Tan step towsiascsoss fl ste and BTR og GO dae pref aot rir Capital 0 highly Ivcesged stare-omacd <omPARLSE, foes resi fhe ova errors: he va Freight inne, policvabuscagiscrsd a stockametslysthe socomd Eric oe arepia and al om olame, 1 2010. he OF 2044. As the wally goed mowentuia, the heed Hockiod | suas invndused the | 5 Kecizng Indes. whic cakes the bur upper, not owed aad pumped us Buc SOKDUSNC seriphied averse of hae thas meric’ anal grow:h nes tt atone bce up id, Tas ws Allred Ie ros Chm mtr on cmuiabis offical Gevubetio. a Aagoss 201510 svt he > > id pmo suing Us li Chins seped GI sn ATE 2 Tt in Contac wich showing ecinrmic grovath, deckming Frese {yen deseleralion in 2018 und «son seb in 2016, exhinge reerces. sing cop 1 ght, nc 4 colguimg nec CHAN 1. VEAT.OVERVEAR CHANGE IN CHINA NEW PROPERTY PRICES 2 os on Ll nar mee 209 ae EM Anz ZW 24 Nah ane 28 CRA41 J THE 1 RFQIANG HIDEX UFRSUS EHINESE REL 60 GROWTH sn " - To on os an ucts 41 sor th tony to LuKsqnz 1 Lewe CLats song cts, thnks othe stiches Lakes maps pty wel 0 he con Fone Chics popes bailout aa te Unpiecedcatd propcty rcs dices in peices, confining the thesis that propery prices bave anach wsjor cities, aay have been tac wost smpactéul yet vader Laps on he Chi como Appisciated <amiyat tha Raced the spachionized gobo: Aloe ination 35 rsa erestingberason: COBO £50757 45 14S saa of 2046. Ths good nes Vly he Kem mde bce erst chm rm he 1 ht Chie uch ie ks 0 emia bal tos ths epi GIP go. Om cud seve ot Corda SEARS of 017,35 stabil passat shead ofthe COP groom rveasired on yest over year has rathe than IUEEAL Dower Teazsition this autumn. Homers, the am anmaslived vequential changed may have heen greater tran VBSSTNIY SUT 70 iss 8 3c Joak beyond 2017. ine repre 5. the rd guar of S07. Ts cou be tional Toe aveectine st te vas grout savy. Sliaclony BO 2016 may have Seen lower than tre reported 6.7%. - . hangs ins vprte ue hese I HAT 1. port Sched oon sass hs otis sp 6 tng nmr er 15 veo 5, dl Lc, Sd 1 150m amt od boar ob Hr ws obo Earp Sct dari the St acter of 2005. Tobe hi prt of repens pesoren ptbeymabon souls ood oud os Chines bilo post Sous Gorm nd ar 000 105. commen of Seeing ees roar Sem ore so comand coum, mae ll fc pec 0 Sao. pontoon meio: Ns Foner oh he ser To nhc atu anh ArmA enn oe ee—— conte ud dela 17. to tn hrmgh som ord om 14071: LI KEGIANG IDE VERSUS YEAT-OVERYEAR PRICE CHANGE IN CHINESE PROPERTIES sx on wwe wr ew we oma an wo an me om ome ow ith Chinese President i clin for a hegre «fur Tomorrow Never Knows rede vari rings ik, elton hae ted 106K il me hee Chins sro choad eld up oof ging ibibo Salon Senkise ese, Sees MRE Woe Tn. inten Ve meet rato to oe rr ee. Gen rin, Cine anki ego ah 1 Sater, snd the gee Tecls of C ih rimg mses ihe richie “Whitwind Gas” Tar Ws 70 POTSEESE bom akon Seb nape 1 eet ie massgement leh realy bsved ris uf HeChES Un CL Suen quite hie bt E18. | ing pics charger Ee Chr Le Jer A Vib viedo cad dig iodo erty ais mangement produc rir orc HOSP 14 td Ghia pl hn ey ons a ath as Te a ine ake Chul ction ML the hosing marke, tnd thorefore would zeflate sais fo a ens CHANT & CAR QVER YEAR ANGE IN GINESE IMPORTS BILLIONS OF USD) son 4s on 0s on id I I LL hs.. LRT a | 3 I EEE Caos “aon 200 wz sons 2am ne wr ws Tae cause ave du 4 Chis Mrsba ASO 005, pd of stil pe cas Toles vod, aio vl senpocte ond vic, Tas SUC ou ths SOT pr ih an vs one wns Bi it Dnsking ates te do big pin sboted boa BAS, ssvckcusbl lo tron sean. 1 ay, Chis act <oepocse bod susie dropped co 4 > , Si i b Ahh sci wellty ited gsm Je, Est Hy SNE mechan glase mcers: iwseos, hecanare he cos On hs bssing Fr stuns ies bove ole 0 0. “nee vee ve oe eet dive meres ithihe i of keeping sg ITC fue 31730 po eh on nary 19° on sbraary 3017.1 Tt. Fw lon ver. ested 1 he scone Testiten’ uf songhi A. 65s mis of 6nd arnt pero ners Wo SL ccm esha fo ES Sa re al + A RR sos froma dlr aks, rams Fratton Kahin salon 215, Chis so conte bots i apd lo S100 icy shore os Fores epport i uly Chas back sd Sncilimuiors Grebo rr, eons ete Wl oy To we vars oo Leeple 87.70, compe othe peo: Ere ldOTZU000 10 une Lk more ule pase oa of large arbor (825.155. Fund lered oversea probed om pues sha, oe mt Fe es Fy be moreso, Yatious mew etic Jova have sha beet. paced on Buain eelingeschim. ss well av grees are ened sod shor Hapmes Ho copllighlvors Chia ell ye onsenbiat. vere Eller onl er. Leveling the Playing Held Irveszment opacrtunities in the changing Soth Sores andkeaps LA A A RE AL Wi Am Cl Sl A heen aeaciaed ith anging governance ius. The BS Tie pes ans eecogaizadle chacbols as aoa in C1141 1 Wf sumparsble econurmies. Stock Price Index (KOSPL} sad 475% of ics seveawes, Seansang, Ta Won, i GH Shahn uA, Ops 1% aE Tec as AMI ev som sch to ces 580 lio xu SK. che chico cs Kons soe compaiice. Ho was pasdonse by tousacs Peesidest Fuk Goud | yuring Park Glenn 115% 2015 presidertial section campaign Hy ithe suman of 2015 0d 500.10 nd sl uck KPH dfs cre, Mi. Sark aT es evtiesl fps presides tails leadsciip fol of is ons congloniets, POCO! huh ise the peer to gando individ and sght 1 actions sued 35 hie paador. of cpotisan is ge PAMKIY on the goweraments mie i granting parcioms. 1 te deciior. wo w= Ps P a reer = annie ] oo ~ fo a aon \ A SAN . yice: { ZoiTie lie b \ - PLE EE Tg iS peers. Ir. addition. MSCI Koves® relative valuation is 5150. jig arean stick market languished sx a resal. wf President ER A ————— Bacar rota sh sons desperately seve ho samples polio oR Toner shat rons rampant within Karen were Sale 5508 rosie. Mun fae Ti. who was onc tre Chief of Stall tn heand. Presiden. Rob Mou Hyus (199 2008), assisted President Roh EE ET bee lhat a president: he Bae Ths presiden apposed lug Hume wo wepchivn Gog the Prisichil Monn Jao In (05 peng spears het peste and nok exclusively for £ Ir " Korea Universicy’s Businsss pieints increases nvesior sxpeclzlions Keser Snir’ Busine Srotont toon etn bus [01 COUN (GOTT ATL I 15 Saki ag etapa mech sees reatons 4 lin Die ewe mao for eorporete reforms and itis. tical for he nation 0 continu <ouporste zeta ss the tovador of cialutbesionmeonwse (cit (15 ll 07 ol GG The Feopic Salat os SS een Rakiponsy Dometiny PB5D family ties thet eaten o ily tis thet maiiain a & cre organization pussuLES sreaghchold oa the Keroen sang Cokd on ho Keron #awbolder tou. Tus PDSD py ‘ oe tonand te oe os Aone appointed cs econo puns ismsyi capes Bt ations ot proven ged it eee a at pring Lb hd AHA TA soveiannce, mad eevitalziog + faced Scoapr Rta presses SE ERA OE ET AR A WA Wty Io} A NO rented seni poled tv tome Cong de Sen SER Ewes df A Or Rw ss od eho A — Spa oo hin ogni hatred be SOR re ego crurshling selafunsbip with Chin by reevaluation (9% Tc Kon stock sche bs bec «sta perforce fn 205 deployment af re wysters. & (vlendly call with Vreddert Xap, ye ROSH ap acenusistely 21%, gear-to-dite in SUSD Fring ler sec radial ron HoT Ls, ud asprin obo abt so GATT RrGHONAL LATIONS Css oe [0 ees » ey Li i” - = A A Sarr pn Da J] “AEN Fon on, dd v EC Et all PL Pl JRL Vv. wi hi WT J - Sg nT > HEU SH COMMEA ECT " Pv SENS WCU RATS ee =o I 1 a: 14) | of a " I Th, | ———— = hs . Cy yi " I LE J ee —————— P— Hong Korg ane Cs Dp ther song potoasans, Ipass liy str cul des PB th of Lox wih Ge ati fe 1 an peane ot To og sions wd the Tok ond ee proces Wega PB ios isk. SCL Koiott picio-book SBD ceo of iS ua 0.3 spite $10 illic of posts wiiestevod Lois ecto IVE (1 mous sow) eo of as cua fun 01: swe dats. Fahy, Korcowboalo aad AN borne SCAN GE dK pti i cua dng 13 PB xk of 033, ch comics pir mins pos ox Sad nF Um. I comodo hee Kars indus: goss an sacs suse ly offer 09 Orlin ofthe Kons bas Bae Laptovd a scat ermeling relive vests when entre aga ver YO 85 suo by pooling ROE La che ios secant bcos georaphies. The Knrean Astemabiles and Components Yo3 Koucaa buss gaccaied ROE ot 7.7%, oucpectovsabig Feder ron arty teades 2 BE rain of Vs ih THRE 757 sud Tis 692 omnes Tsendhiy vo nds Pi beso robe Vom Vote ngntenn lsuton vet sated los il cngatng imatvesshisarigil sq mersiretscmer. the vet roast ov oe forevtios of ei, Kora, {tah Korons OFWs trade at Psat ar 3.51 Sn chet ui hoe the Prentice cover fob inte stenp amr hrc Be iat the Vimess. lve gh easel ecard room en Bet ites od Snort rlnars fonts eens ot alvetatog fo Hoe Ered goat Serr ierataed whos ot sore tack te Fog a Irs tbltines cage mom hoe aed erga HK Vea oo. we live ha arin ont te shsthal 1 enhanc Frorace ote fervince, mini crs eldings, rear hosed Uliitien in smother seckos share the valatior: apa iy is stark. Serato A ahaa Toni ig Sores barged chev produce: urrenty aces a 25 ell recived by global investors snd monty reanding tn Fai of Bx despite ree stella yee of ror oceatiog, EPebol valuations. or. frther lok f ora. pcr ance angi wad pradens copptal discipline. By comparison, he 7 S00k Kores, Plessa see the following ariel by Pr. Mariel: Vga I'he Promise of Governance Reform—South Korea is guration esc vm ha Ws ely dtd res meses hs tgs bee sted the lg. Te evo brosdm fine owed legac Sods Sovomee abate. i Hire om Femi rinse ewe Hip etomiatende. Crs of 157 159%. the cary sodersent muri ee A Ee limbic RR coment het ate gam Ns erage sew ta geri of td rs ia lp me de Brac Keaton ha rpeachmenand Sereno dmmoraelt es orn 3 1999 lab 20 reich Sh ST Semanding 53 ims mbes fro Survonts ava ge Fated soa Ge th sot 33 Tom rr Kreis iy or lena onal. haemo te Kore aha od KER Peo The psi snl Kos lo bd othe ta ile 1 bres tie directs nd or ne lf ee ais prchle cozy ¢ sercat an the souatiy: La Fooruy, lar Y. Loe, Prindsperdent. in the hand independetse receivmens, Te tions und wing Sendo of Samsung cogiomente ere farther srerygherd i the sipulation tht there be. canpise, was attested on sccusations of bribery tw foiaes THOTY of dependant hmaed directo for large comparies. Presiden: Park aid hice mace ech i cxuange for sccuiaga PWS 85 ar 53° wich leadieg iniernaional beut praciices iv Contiontsia mcigee of Suen Construction aed Trades SPOTS Fvernanse. the Kovwin Gommersial Gade sin Couporssion and Chil Industsos, While he imag of 4 Paltes that abide or independ. divers ms. not 2 Bali Leo sent shoves ocros the usiawss world bi Tebed 0 rrangernent. hile activ x Rduciaries® Iie acest wus owt eaprecedeannd. To the past, his Stee Lec Kua resonated with theirypetis koward grever hosed indeger dence. Hic, cunt cls ans of Semsus, mus onsicaod owe of Title the role of corte insiders and create new worcaption wid sudoned. Sumilacly, ia 2007, Hyundais Seperdent auditing siructures wihin Knrean corgarations. Pudi. Ado 201, 5% Chiao Cos To wae lt oe id ony dai, seid ot opto of a ele: hot ior at Ae Em i Vota sr oth Kove coek si Tok clos ss wiht sai sles. chsppeomlistors ells prs a I A Se toicicased sharchobdor Gacostean. ethics contravaraiesinvalving Korean chachels sweet aver the i ee a olusion of pire mad busacs a Rows bighgtes she PF FUE Ln EE EE Poot practices of couporste owns aa busiaess Thich, cect Leet hile the hoards of dirtors of Tyme lagging i govsranace behind leaders ia the axgion. Korea 0 0 Lor ore ep i the do shart fo A TT Ph Rt AY AT thurs and rvspeanncy bn corpora gumnance matter. All these inszaness pint to a serious lapse in the. : r nrc of cist corpora ornare ues ands ick somites wiser. 2) allosing sharcioldeis of pacert usualy Toe cll usin Goer indie ormpanies si dineturs of boii Times, 3 een of he sound of Korean conlonnetes adhe sof outside Wil nesholds for ilies represses Lossuis, 1) strstr nares. agen, sn wl o£ etd bg ian ctr Recent research or. Kovean-listed companies shows strong 4d vumalative vuling stati hese dependant direc aad mamaganea of Orsofthe eran biiousgals inelsespropossdsmandrests Korean esngiomoriter. While 57% af hoa a1 in theory to Keres Moncpoly Registion nd Fur Trade Ac imducing inependen, aly 7% mc when ors esis sail ies The constraints on chachel businesses £0 baring al. Sx Composition ot Korean saseds al poses sons, +s the cierlar sere nets cf chacho thi these see peentige of ditectors with HACE 07 FDAESACON {yg orb avernance reform in far were Fr public Backgrornds brs decreed from 45.35 i 2004 254518 uid by chachel sharehalders tremalees, In 2015, a. 301 This hil he nmbet offer bi Sl und Marni ered et shes rr sharply sneceazed from 2 75 in 2004 10 4.9% in 2011 iunted rangement shou. tre comanversial land deal rd foverexingly. in Koco: boaccoons, the inckision of profssars. proved a new siwvernance cormeidse i siren en sensight nd eras ndepopdet dors ur becorbe mmen T30 un accoetabili: Insn erprecedented fashion, their Dead or stronger “hacshalder sation indsgendenn aersight 5 a romp the company and monsroring of “Viith the 300ption of & SEwawsnip COUB, eps spats magrren i speci . Treen Tor Note OUT expectations are that snarencloers in Crp Gorernanes chachole 2s they Korean equ lies, and especialy in Chaeaols, Games amiing concentrate che of Toa independent managerial powst into will uss their voice more actively 10 poll mie the board's caiman. 2 _ " nahucshbder adr ener afthetonsing PICITIOE DOSILIVE GOVEIMENGE Change anc induce. Hmiy Tethys long-term sharenolder value creation wll smvunced i control aver a - new “Corpurate conglanceae thravh an for. lu eran the marageuneas conncil aod appointment of WATAGIOT OF purer busivess management arc in promte shanerokler shersholders socng ors aceorTANY aS WTA Compras sdreap to Enhance mg tam Shares tenancy ¥alue Creation.” comm: ing Un improve gernance hy increasing ts haanlsir deper dence, nell re del ard mm read experince ofits direc, Ath cone af one's guvsrmnes hallanges bes» armel problem at the chachol: the complex sysiers of crass Changing Korea's Business Culture harcholdings. On average, the funing Gsmily of KORCAR Tg pated posers eforinn Suse is oppurtails ot commas sh Fl Bet TTA, yy lodge ota ort bain. Seco ole shill Voted sbidiarins mem mors then M6 the se tuto pobstios fo: aharholdrs. Uo eves faneding fomily ix a chavchalder in the other chishnl oy uppuctauity w oak tre culties ul sessing in Use biciarie, and the sohvidiaies repeats hy owing hers conten " ors aston and pater comet heswron any 0 CDI ist teas Code, cnomrogin big tos harebviders and exiereal shrchaMers. 1 mary, fess UCC PEEFO0 pes and et manager actively engage with concerns have heen fsctored inte what has heen called for ower JIVESHeS comperics and fomanitor hi managertent decisions. eels han genie sea aad se semi an sive oy Seiten loi ow sds or fingilend. With the sdoprion of = Stewardship Code, ovr cr procs of niority bares Tabs Gd OTE exmacations ste thot shove roloers 1 Kage specs, on fora spend ane pi such: 1) elormian Gre Ronan (ot LGC EE em sharchaider Conmmrnd Code by mandling se ete dest or dl gprs mon, & ROCKCO.COM insights@rockco.com Now York. Wasingion, 0G Santon, 1a Sipe Slat 7 on Honda 1 10770 i mon 0005 Ronen fac 12 braeh foe at RAN Rockatolle Tus Company, NA. Tha Rosatllar rrr Tat Company (Delaware iF TSE apn Sr Sot 31 Sean Sonn Singin, be 1060 finial eS) ROCKEFELLER ASSET MANAGEMENT Market Revi A “Vixing” Puzzle 1 I Ces Markers unis back of salatilily; Sontag ean Be fearful when others are greedy fs sew) ror hs ioriealls bor 1 sock mts place = thecrash of 1639, 1987 Black Monday, samo se mm oa we he Facial crisis of 2008, ee. This Gelober, lower, vac rare om mus Ue were rly rats aud 0 ticks — the biggest oue day Hust zee® wo wows ee meament for the SKP 5c Index craig the month wasa WED seem am mes 81% gain, ni the higeest dean day had a mere 047% TH OE NE rap. That said, there was quite bil of irbulenos amon, <5 mm aa am individual stocks. The Lnfoeation Tochuology sellin | XE: we Ws ae buge wont vith the so ealled FANG stocks (Fac och. [rey Amaze. Netflix, Google) eadimg the way up. whilesome = = ES ESSE EEE m oi ecomomy belies nd the uch beleaguered hick oro re MEE and imrtar relalers Lock a beating. The rising hope of 170 er > ity > ie US tan evfores and the continued strcugth of Ue glotal 777 RIA 4 veonosmic expansion lifted U.S. Treasury yiells as well as siti i £ coummarity prices fron oil to copper. The 1.5. reflation | espectation also boosted the. greenback. FGropean communes ™ PT. <onercign bond yicids and the cum declined aher BCR gy pets a an am as resin Draghd anounced a eduction in Woy SSL gp acy Tor bg purases startlg in 2018, but prowised a Tonger gent ie wa wm duration of QE. China completed ts cpiuquensinl 000 . ol ett ph SR Lami ig i Cress, which should usher in a new era wilh WORE oe ven i : r focus othe quality uf grow lone Une anit. President oon "oo Xi now awaits President Trump's Stare visit to Beijing on: EE — Noswmber 4% Investors wil kel he formed on issues Gos te meoooem em ranging fram made 10 Noth Koren, thongh major ou a ween am neakthvoughs appear mikels. Lastly, here is Si One. rs civ ry 4 see wm aes an resolve shper issue hal ay cou back 0d 1 igen forty un sa am mm auarker — will a new bipartisas deal be reached in Heo agg ae, = w wm am fond the U.S. government beyond December 82, swhenthe 0 os Wo um WE erent conrinaing racolntian expires? ea The Original Big Short Unfortunately. the concept of diversification prabably The Amsiendam Sock change, founded by the Tuleh never crossed Jesse ming. Tesomehon managed o oss East inca Company i 1602, recoguind us the workds ll is money anc was bankrupt by 1934. The bunkevny oko onk exchange, I clare a secondary muckerto. result in an automat suspension af his membership rac stocks an gave risa arcing clus Arn tha mid. on the Chirag Board of Trade, Tn 134, the lgendary 17 century where speculators would. congregate. trader, suring fom depression, shot himeel in the Messangers would rush 1o and om the exchange ta cloak room of Manhattan's Sermy-Netherlund oe, ndane pricing ta enstoniers. Rise ofthe Machines Tn 1867 the mention of hestark. | ‘Lc combination of clevated | sos things have chang from ker machine, ale nan a the stor comnlacency anda | os Sper das when human Licker tape, obviated the need for A were doing the Iading. Today, sosugers Sk lnsachoudats | tightening Fed makes the | wilh the adveat of tochaology, rat. | marlet vulnerable to a pulllick. | morte "7% = frmeatd bn pint oul abbreviated company strategies. 11 is estimated thal nares (Licker symbols) followed by the price and volume: Tundauental discretionary investors now account for oly data. Thon Edison later upgraded te syste to reach 10% of the trading volume, Big inflow into wajor ETFs a printing speed of oue cliuracter per second. Ticker tape. prowpted biving acrass the board regardless of company eliminated the need for messengers and allowed peopleta specific issues and valations. Rig data and machine Laden “realtime” rom long distance. Teaming an he eo Ws words orf eos Fetured a ausul fund rn Uy eve bovaty somethings. Theis 101900, 14 your ol Jew Liston Livermore started ast andes saneget was the Tow u of millions working 5. uetation hoard bin the Beton office of of dolar, et they sceraged 1 billion in transnctioms. or Taine Webber. His job was ta update the hoor with 10,000 16 40,000 trades each day. Sino there are only information cong off the ticker ape. Tle became 6,400 soon in da, sf would sencales rade nlervsted iu We belivivr of steels prices and began. cw 2,16 to 8.4 sevonds if it worked around We dock, seconling price movements that enabled him 10 apt Much of the deciion making and trad excakion, of patterns prin to sizeable advances wd declines. A fellow cone, ns beentaken aver by ftwarealgoritn, These office bes ater talked him into specnling am a hock on whiz kik employed satisienl arhiterge trading srstegies margin ata bucket shop. Too days hte, Jesse sd the in socks aud curreacis. and <losod ul all Lrading position wilh a $3.42 profil. Le svon quil his job aml positions at the cud of cach day. started trading for a living. “The allure of sophisticated computer models trowieing Jesse made hi first $1,000 (aronnd 827,600 in today's their human eompetitors has confined to attract inflaw dollars) at the age of £5. Le was later banned by mosk lo quant funds, IL is estimated thal quantilalive hedge boule bps it Boston as nd toned sn of the Tudo aang sur tha $4 tellin about one ied shal operators, By the age of 20, be lad aceurnlatd. of he $3 rilhon Hodge fund index, While here are $10,000. Them cami th hig gray the ani of 107 ~ indent brillant quant. managers. whe have deivered ding hich Jose shorted fhe marker and made $1 song rere long period af fime, th shear cre of millon (525 millon in today’s dollar). Me moult 0p his. the industry means her are ety mone pretenders than foot av Fo ip 0 the reputation se “The Geet Boar of ecules, Goes that say fonds <uaply salar Wall Street” by shortmg, the market i 1920 for an strategies (5, rene following), a eversal inten cold astounding $0 milhon profi (5143 Bllon fn 17, crea dip market MORAN, Nt 10 mention the making Him one ofthe hast men nthe world. threat of me aime wreaking have on the market A“Vixing” Pursle allocation would even exceed 100% when the market's Fauity solatlt has bosn unusually low far mucho 2017. realized solatfity is below the Largeted volatility. On the The Volasility Inde (VIX), which measures the implied other hand. 2s volatibty ticks up, the exit allocation oar of SK 500 luckes options and has been viewed wonid be scaled hack. a5 a harometer af equity marker slafilty. has drifted 10 all-time lows. Over a <pan af more than 7.000 sessions Whike [hese strategies have enfoyet strong retums during going back Lo the start of 1690, the VIX Indevs average this SUrvieh of progavssively Tower cquity volatility, they and median losing values have come ov 101. ated 17.6, may be planting the seeds of a market coreeion. Market tespremvely. I vas 4 Tare aocortence for the VIX fo makers and dealers on the other side of the growing short oollapss. helo 10 — there were ais neh occasions ont VIX rades som nese 10 employ varias S&P sacs option 0 6:802 trading sessions prior 10 2017, or 0.13% of the strategies o hedge heir kang VIX positions. There is the lines. Year-to-date 6 2017, howe, ere were akeady concert ata decline in Une S&1° 500 Unde vould Uigger sessions with Ue VIX closing below 10, aljostiuculs to Unse Liolging positions Wal. world exacertite the mar et decline. Similarty. should volatiity Anather vay to lak at fh ack of wait i fo tally the. sudden spike wth aforementioned solafility oontrol number of trading sessions when Ue SSP goo Indes had strategies would be culling 6quity expasires a daily lige of more Ursa 4% i ilher direction. There concurceatl, which could anuplily Ue market decline mee only 8 sucks seasons so fae is 2017, compel 16 48 stuart the dovaard selling pressure Laat Une 50 and 72 seh occasions in 2016 ud 2015, respectnely. calls portfolio insurance products generated during he crash of 1987. We wonder if any investors and reglators Laces ironic that the market should be tis steady with uly appreviale how Unese strategies, in conor will arguably Uw most wereurial aud uscowntional vasious raid fixe Urades gencrated by mackine-learuiug president in modern bistory at the hd atop he free based abyorithuus. ould itupoct warlet movement wad world. Petiutps investors hue grown ub to all the liquidity should there be an exogenous shock. Only time choos and controversies. 11 is as if Washington's willtell dysfunction and a divided America wore just fodder for ae ivperscutilaing wedin, and warkuts were beliniog Fees, Greed as i all will Le oe when the Kepubheans pas the tax There is an adage that one should be fearful when others reform to prive the pump for the 2018 midterm are greedy and geeedy hen orhers are fearful. Judging by elections. Time will tel this period of eerie cali 3s the depvassed levels of the VIX Indes, the enthmsiastc prescient or isguided. speculation over bileoin as well 45 ollet varias of enpuocterencics, wd sures al indicated strong Unintended Consequences imvestrient sentiment, it is dear that greed bias bees on The decline in market volatility has made shorting against the riae. Can this euphoria continue fara while longer? Of the VIX fufwes and varias VTX FTPs (exchange-rraded conse. Hawever, in anr apinion, the combination af products) quite populac and profile in roceol years. dlevated investor complceaey and a Ughioning Fed The nel short position on YX fotuees lus progressiely wabes the warlat voluerable to a pullback. though the climbed to nev highs over the last couple of years. fing of it is hand 1 predict. The sforementioned sues Anather phenomenoit was the rise af “yoltilfy control” ith varions trading strategies could further ad fuel fo investment seatesies, spposadly frvared by many hedge fire in the event of 4 market decline. Tat sid. with the funds and insurance companies. These stralegies in macro and earnings backdrop remaining positive, we essere adjust a portfolis allocation betwen equity asd would view potential selloff as & buying opportunity cash to sunintait a targeted. level of volasility af the rather than the stat of a promacted market donnie, portlin level. In an environment of declining volatility: Tore a5cets wold be allocated to aqities — fhe eqite XJ ROCKEFELLER ASSET MANAGEMENT © - € For More Information on Rockefeller & Co ROCKCO.COM insights@rockeo.co —— Washington, bc P— richie A 200 17h Sot WY £2 i vt ont Sto Troe ror, 10670 Weston, 0G bail Treseneioe pry peo Soze3000 i Rate Tot Compan, NA The Rocatler To Rookatet Pe That Company Osa) SFr fry Now ork. Y 10020 Suto 107 earnsioo Wiington, OE 19301 aczansswe iano kn se Lok of cickler 8 Ge Baran Rock of Ages arulnasth acisor Reckefsler Sa as hb oth 1 nancial aris Sr he Sat of CEQ. Not ony 45 suns ied £1 veo mows ali ©. Rockefellers ‘ily fle, oskefe le 8. ous vec in {G52 sega ling ie qa 2 clic 1960 nd 2 GAYA 375 li of its sents ncn Fu. Toe oes gc ew oe ug re fra beer In Sop ACR, 25 rn en, 215 aged, Sock id viv. Jee 3. Voom, ds well ein con eke i Osh, oer ic ord rect ort thi dns sil, Hock yea for th Rocketeer Fars Toa. hve act C0% of he asaya’ eg igh, gst emote seaesor bn hse sr fo rage se dongercus ssn ars ance servos im bein. 4 263 151 EA 31 TU, WORU EGE TANSISS 15, CHANNG3NGSS BE el Rona’ asi nd! adic nd sibvstalon sly 1 S25 SA on nthe ee gear re 5 Crt ra 21a fe X08 Te ee ST, 15 ig hain sv pt decade * Spr he tte-co fo pancd shen sega in, ess 3 amatatly song Fanti 3d buses ay eueer ery l Roc ’s 0 ree past $981." § oa STINT 0 TE Na 4a ree Jerson Lars me. neki ost of he pecpi ho re sl ire lossy Fe 73 101 ly on UG. rors ION os Eh Vi Seat earl” of Coy Gran, 2:3 me Godin Sav aes ha in 2507 pen 1a ork x George S05 react fs To SOME, NSF. 47 Aas, af Bek ating 25 pressen’s pot 1) speci whist for Lave Warstan eve oper Ir dine 200%. Soe Give Fis Barking cose on fs rch of 37% ost Postiar acorom share Rocka b Co ead go stabi ts becca shea dur the § resent sre ii. he Fines sak as ben ince press shed rane suas. Lo Baker Hughes 10 Sulla GE, : > - Company... Thats Ron ihe Only ea 2 a1 Cop. {He Sure Jory USE lr sal of cits Some ‘Generales ake 1 Lord cor Ratechi' RIT Capra) Paes. The lsd ant ind 1610 ven ee Tor 70 aneon anc of <olhch da: ans as 19 -— il got (82 lon) unter mamsgeom. Too cess eepees psoas the crd 2+ Qudeosanm: Brudeomn’ Gol 4A Lut of oF waih. % » uch he: heals Sow come akabl marty Ap: 26. In Se ese ie fr coo TI AT AS gL Sa ice of ves cxoeserd fan es ave mara revresde dons 3+ Nvidia Rising; Dazales Street epee ot rod ales hs marmgad 1 Kees Ue Fede d Wa ens bar co AO U1 OG SST 7840 1 rao J ite Look Soccer Ge rane Mo 0 Tn — 4. pp Scalar eden, er Us fi] Seosszom ramen - pri a 5. Stopping Dey Madess: Why ivestoss [EL lh consi sin Aron Oo hh 4 NEE or Recon Co. Sern 57 san sentir EE Cn Lafont Market Vos I EE sags ar nv, bt ne ord a BUSI TINT Dramate ue POMBID-r304 pOSuCt for weakhy ver? — Hse aD Basvos asus Js rp ——, Br oo a ween anar Shares tal sie ae ed note, Das st Searaals, CEC Buin lala sr. Stout. sarelagte nutngknse whiher " Vath regs ard aa af a Wma, eb 3 SEG” SU faa Ger BRS Acer To on sie ot sl ear or, 1 hc 3 Gea Fraaded by Set, Sotetre aty pronsndu cor “ aman shh on cos ve i 570 or TTS 8 SR meee ar seed oe evr vos ae oR RAT ses 0 DA 170 re ra of Skeeter 8.0 ust ha blu of-e Saket o's Sarit rime rn |e 0. nl Rosle Fb oe ne rh dh Er i Teor reed to dered #7 oe re coor, Cu wate 1 pleted manta th Sco fr mange st oto in ss ds pal a fm 1 for 195 ln ase 9K fre EO ork Rockett tpt ene oh 520 ean ints rors ws 2 ora 31000 rd en 3m rahi va SED $100 ill pal ly cols 2 20 al Soren mero Fm pert Av hap Rokadtos seston totus Root 4 eet We aa rs a he ining pret of a cre Wa diaries oT bss avn $1 la i re Fh Th 0 aod we Jer Te e——— [RS —— Tne EL mm, 2. Fo 1 Buy a Use Jet At n Bargin Price rv J p— 3. The Family Portrwit 4. Tax Bonuses Earned From Renting Out Second Homes. 5 How to Tine Mamita Cords Mrket Tr [oe | ronvommma. | prem. [—. [inn Ton ToT an J— SS. = From: Jlisevecation®rrai com sent 55720191250 ad To: Nicholas Aivi: I ups: times. com 201 9413/06 unfit trump-inauguration-stophavic-winslon- wwolkofhimiZactiom=clich&modale=Topt2 Ionics pgtype=Hamepge please note Ihe information contained in this communication is confileniial, may he uiorsey-client privileged, muy comsailute inside information, sud is intended anly Tor the mse of the addressee. It is the propery of Je Unauthorized uss. disclosure or copying of his communication or amy part thareal bs strietly prohibited und may be unlastul. Tyou have received tis communication in ereur, please nity us immediately by corurm c-mail or by c-mail to jecvacation: mail com. and destroy this communication and sll copies thereof, including ull uhischmenls. capyright all rights reserved IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BFACH COUNTY, FLORIDA CASTNO.: S02009CADOSOIRXXXMIAG TEFTREY EPSTEIN, Plaintiff, ws SCOTT ROTHSTEIN, individually, BRADLEY J. IDWARDS, individly, and LM, individually, Defeudauts. NOTICE OF FILING COMES NOW the Defendant/CounterClairunt, BRADLEY TDWARDS, hy and thaough bis undersigned counsel, and berehy les the uliached transcript of the elephone intesview of Virginia Robes to supplemeat the proffer made in support of Counter. Claimant's Motion For Lesvo to Amend to Assert Punitive Dimes. THEROBY CERTIFY that « true and correct copy of the forcgoing bas been famished by 1.8. Mai to all Counsel on the attached list on this __£ 7. day of May 2011. Tuck Semok 7 Florida Bar No.: 169440 Searcy Denney Searota Frnt & Shipley, PA. 2139 Palm Beuch Lakes Boulevard West alin Beach, Florida 33409 Phonc: (561) 636-6300 Fac(561) 383-0451 Autarney Tor PelendaniiCounterCluimint Edwords Edwards adv. Tpuicin Case Na: SI0MICAMIRNXXXXMBAG Notice of Filing Supplement COUNSEL LIST Jacke A. Goldberger, Esquire Martin Weinberg, Fquire jgoldberger@agwpa com: Martin Weinberg, I"C. smahoney(@agwpa.com 20 Park Plaza, Suite 100 Atterbury. Goldberger & Weiss, A. Suffolk, MA 02116 250 Australian Avenue South, Suite 1400 Antomeys for Jeffrey Epstein West Pulm Reach, FI. 33401 Phone: (561)-659-8300 Fax: (561-635-8691 Attorneys for Jefiiey Epstein Taio, Tall, Weissing, Edwards, Fistos & Lehroum, PT. 425N, Andrews Avene, Suite 2 For. Lauderdale, FI. 33301 hone: (954)-524-2620 Fax: (954) 524-2422 Attormoys for Joffrey Epstein Joseph I. Ackerman, Ir. Esquirc Ja@lowler-whitc.com Tawler While Burnet, P.A. 901 Phillips Paial West 7778 Flagler Drive West Palm Beach, TL 3401-6170 Phone; (S1)-502-9044 Fux: (361-202-9976 Atoms for Jeffrey Fpstein Mare §. Naik ‘mare@nuriklass com Law Offices of Mase 5. Nurik One E Browaud Biv, Sulte 700 Fort Lauderdale, FL 33301 Phun: (954)-745-5849 Tax: (954)-745-3556 Attorneys far Scolc Rathséein 2 Edwards adv. Eps Case No: S02000CAO4O800XXXXMBAG Notico of Filing Supploment 3 PRIVILEGED PURSUANT TO I'S 766.205(4) and/or WORK PRODUCT TELECON PARTICIPANTS: JACK SCAROLA BRAD EDWARDS 'VIRGINTA ROBERTS RE: Edwards adv. Epstela 291874 DATE: April 07,2011 18: Virginio, Jack Soarols and Brad Bawestds BE: Hi Virginin, ve Hi Jack! ili Brad! How you guys doing? JS: We're doing fine, thauk you. I'm somy for all of hs trouble and hefurs we ga any furdher, let me tefl you, if | have your permission, 1 have started a tape rocorder und 1 want 10 be able to tape this convarsation fiom the very begining. Is that alright with you? vi Sure, that's fine, Jack. No problem: 8: Ok, ood, thank you. I appreciate that, Let mo start off by introducing mysclf. 1 know that Brad has spoken to you about me but { am Brad's lawyer, and 1 assume that you can confirm that you and | have never had any communication before. Ts thal right? vi Lhat's corroct. JS: AWight, T hueve, however, golien same information from Brad about conversations that you have had with him, and that will enable me, hopefully, to male this a little bit moro efficient and aie up minimum amount of your time while stil petting the informetion that we think is going to be hotpful to us and to any jury that might ultimately have fo car those facts. So, let me begin by usking vou firs! (a tefl us what your fall name is. Vv: He Louise Roberts. That's my oaiden name. My married name is Virginia Loniso Edits ad Epmein Telephone terse wih Virgin Roberts Pes20f23 75: Could you spell your last name for us? That is your mamicd last name: ve I$: Atright, thank you, and where are you living right wow? ¥: Tlive in Australia, JS: And how long have You resided in Austollia. Vi Phisismy 20" year, 18: That is where you are right now, comet? We've reached you in Australia for this phone conversation? Vv: “That is courcet, yes. JS: And what lime in it in Australia right new? Vi Lthink it's abour 9:00 now. JS: Ok. That's 9am, correct? Vi Than vome JS: Alright, Virginia, the reason for this conversation is because itis aur widerstanding that vou know a man by the name Jeffiey Epstein, and | want to begin by asking you please t cll ws about the cireumstaecs of your first mecting Ms. Epstein. Vi Ok 1 was introduced lo Mr. Tpsiein hy Ghisleine Maxwell. Twas working at Donald “Lramp’s spa ia Mar-a-Lago and I was peompled by Ghislaine to come wo Jellrey’s mansion in Palm Beach that afiemoon after work to make some extra mone wid to learn about massage. Sho met me at hs spa, aud 1 vas reading a book about anatomy; 50 1 was already interested in massage therapy us JC was and nol having sny of the cduostion or you know snything behind me, 1 thought this wus a great upportanity Go sork for ber and 20. So, { viem 10 Jeffrey's mansion abou 3 or f in the allernoon. My dal drove me tere. My dad worked at Mar-a-Lago with me, and he met Ghiskaine aiid she seemed tke: 4 nico. proper English lady, sad she knows. 1 mean, you know, ono time thea _once ‘before Toft to frevel overseas, Se just ssomed really nice and like sho would like £5 help me out. Soy dad left, snd Thad no problem gelting home thai night, enc of her drivers would take me hack afler my trial. So she led me upstairs, und inlo JelBey’s bedroom, and past hat s Jeffrey's massage roam, which fas wot is tsam rar and shower od a massage table, and there is actually an extra room that has, that nobody lov about it it's kinda like a scerct oom and it's got a whole bunch of decorative pictures of prmigruphic leraiure and sex toys aod Tem _ 7 shat happenod in there, Lad adv. Bpein Tengbue evan wil Vigra Kobets Pages of 23 JS: When you say thatthe xoom wes hidden, Virginia, Low vars the room concealed? Vi Itwasn't like a door that you would nomnally go into, like some kind of special vpening, ‘you open that and then a litle door, so it looks like ivs a lide closet wo-ta-speak, hut when you walk in fhere, i's obviously a lot bigger than just a closet. IL wasnt 00 big, but it was bigger, you know, Ti wasn't a gigmtic som, it was just like a small room, which you know, it probably cauld Gt sme shoes in there, it iad racks of shocs, boxes, same sweatshirts neatly folded, and the ceiling by the Boor was covered in pornographic picturcs of the girls that he bad met 18: When you say... Vi So anyways, that was geting there, und | was intaduced to JeMlrey, he was Tying nuked ou top of the massage table, and obviously for ane, Um a 15 sear old girl and seeing him on the fable was weird bu, also leaming about anatomy and message, | thought this would be purl ol iL. So abiously. Thought it was part of The massage program, so | said ok, this is Fine. And, he then insiruied me on hos b touch the hudy, Joffroy's body. how to massage him, und for the first haur, it Was actually a real massage, maybe nal a hour, rsybe like 40 minutes oc somethiag, but of something fike that _and that’s when he ‘wmed aver on the other side and to expose himself fully. So then Ghislaine told me hat she swunted me to undress and ben to toke off my shirt and skirt, my Wwhito uniform rom Mar-A-Lago, sho also took of her shirt and got wdressed, aud so { was there with just my undies an, wd she was completely bare, amd nde some kind of litle fake sont ‘the undersvear that | was wearing, because it swasm’t ty normal sexy girl underwesr and just like. | don’t know, had red hearts on it or something like that; ust your normal, you know, real cute underwear. Anyways. so dur alf of this I'm kind of ike what's going on, how do Tact, what do © say, { was so afiaid of, not afta or feauful for my lis buc _unsare of haw ull (his skied and wanting to obinin 4 profession_ I was so aftaid thinking about upsetting and disappointing them, 1 don’t know, it’s a weird situation by far aud | was expected to _Lick his nipples, instructed on how 10 do 50 by 1Ti_ and give im oral. sex while bc wanfod to fondle me, and then at the end, 1 was told by Giislaine to gol on top and straddle Jofiey sexually, and when wo vxe donc, we went and bad a shower in the rium and Jelfrey KI me to wash him up and dow. yon know with a bar of soap and take sure he wus all cleaned up. And then he tak me dounshirs sd ok me to ow of the guards and told John to being ine home. John was the butler ut the time. 38: Lol me jurermupt you for just a moment there if I could, Virginia. You mentioned as sou ware recounting those dell tut you were 15 yoers old af the time. What is your date of birth? Vio Augustd® 1983 18: And can you lel us plosse, as bos! you're able to estiute it, what the date was when Urls first encounter occurred? Faun ad Epscia Telephone servi wi Virgin Kubert Pag dof 23 Vi I've gotit waitten down, 16s lke - Tm nol good sith rath — hold on — 1 though 1 wrote it down but T didn't. T'm not tn sure, | (ink it was 1998 off the top of my head and around June of 1998, T would say as I was turning 16 at the end of the summer. 18: Alright, You talked bout the room where Jeffiey hud the pomaggaphic photographs. Did vou sctally sce thst room om the occasion of your rst visit there? Vi No 1 got to see Dia room a few visits after but § was fust trying to doscribe that oom fo You guys so you knew exactly what room | vies talking sbant. 3S: Another question for you, and I don’l meun a be prying into sour personal life, aod if | yous um questions ut all thal you're uncomfortable answering, then you fust tell me that and we'll move an, because | appreciate your cooperation aad the fist | hing I vant m do Is impose wpon that cooperation, but can you tell us plese just generally what kind of sexual cxpericaice you had had prior to this eonlioniatian sith Jeffrey? Vi Verh, sure. A chose fil friend hes sexually abused me, and I was on the strsts at 13 yeurs old. | was picked up by 2 67 year old man named Kan Eppinger who did cxacly hat Jeffrey did with me abuse and violto my youthfulncss _ & Twas with him fur 6 months. So, bic was gone and then 1 had (his boyfriend who vias ike my sehaol lriend from young deys but we just kepl in contac with each otber and we were on and off constantly, and that was Tony Figsroua_, und thers was also another younger guy was near my aye, Michael, T can’l reanember his lsc name, but yeah, there, 1 mean, there wast ike a tring of men or anything, but there was Ron, like 1 told you, and be was tho first guy expecting me to do so-called disgusting nffirs, Joffrey actually knew Ran, hich was quite weird when I told Jefffey fhe story about Ron, und Jeffrey ad actually ct hiro, and yeah Auysway, just smother story, and yeah, here were a couple of men, ul thal gives you um idee. 18: Now when you described the photographs in the room as pomogrphic. (cll me just 4 litle bit about the photograpls, if you wonld please? Find, how many af them were there? Vi Atlewy 100, and like | said. they covered the room from the ceiling, uot the ceiling but rom the top of the edge of the wail o the bottom of the floor. I want to say at lost u hundred. even morc, there could have been more in the boxes Some af tem wers 44_ Photographs. lk the large size. some af make] samen pong, sa hiusw, positions, Rex positions. Others were, you knaw, some girls had bikinis on, and it wast so pamogsuphic, hus iL ws all wimen, and it was all in a sexual oanure. 18: Were there photographs swhere more than ous person appeazed? Vi Ob yeah, plenty of hem. There ware Tots vf asked photogruph, 1 mean T wis just tréing 0 give yoru visual range. There was anything from 5x6s to 48s 10 8x45. Some of them das lv. sisi “Telphano interview with Vira Roberts Vasu Sof 21 ‘had frames, some of them were our of frames, but they were all, like T said, they were all omen, they ware all soxual in nature, JS: Was it your fmpression thal there were a bundred photos of a hundred different people or were thers multiple photos of the same woman of girl? ¥: there was defuitely a lot of differcal gis. 1 mewn it wasn'l easy a sit there and say, you wert finding 5 girls out of same: Phalos, i, Were thece 2 hundred different ones? There could have heen pictures of’ some girls, | really conldn’t pet close necessarily to actly recognize faces or anything like that. But if you, you know, the rungs of them were all diffecent, majority of them vere differen, yoah. JS: Did there over come a onl in lime when vou becarae aware that a photopcaph of you Thad heen udded to the collection? Vi Yes, there was. Ghislale took several nude plotogrepbs of me for Jeffrey. So, yeah, there were pictures of me wnd fhare were pictures, he wasn't shy, that wasn’t the only ‘pli in Bis house hl be kept he photos. [le tiked photos alf over bis house. If you Taaked in his den ar en his desk ar in on the ball table, agian Lall fable in his bovse. there were at east a hundred. photos of giss in frames. Not all of then wore asked, lof of the ones that were all around his house wero nol nsked girls posing pornwgrephicalls, Some wea pictures of celebrities apd politciums he hak knawsn_or things lke tha or bad pants on or whatever, but yoah, thore was a lov of mixed photugraphs in the outside anes. IS; Were there eny photographs of girls or sous women that you knew or that you subsequently came to know that you saw in the house? Vi Yeah, yoab, there was, There was pictures of Nudin Bjoumik______, pictures Soni Keke, pictures Emmy, pices of me, pictur of the rexilars, bl & 1o¢ of the girls, sometimes TefTrey could have like 7 girls a day, aud be would ouly sce thos girls mez if be got bared. 1 don’t know. “Lhese weren't my days. | hod he's goilen + Jou Sloppier since 1 Left. So, L don kuow anyways, but when 1 knew bi, there was jus, it sectmed. there was such an influx of gils coming in und aut, so did T recognize a Lot of them? Maybe, maybe not, but then they were ull definitely beautiful, they were ali xovging in ge, same af them young, sore of them older in their 2073, 1 mean it was just They wens all beatiful. J5: Yowve told us about the first visit, Was there suy discussion on the aceusion of that first visit about your returning? Vi Vos, they were very plewsed with me and after the encounter was finished, the sexual encounier, he went and wid me | did veil and I fave a lot of potcatial fo become a massage therapist and if 'd like 1 could return tomorrow, you know, and do the sume thing and get paid $200/kx. so Jeffrey insisted that | come after warh, and ver the fest forv days, 1 gus the relationship gro info more, and within a couple of weeks, not even wards dv. Epsicin “Tolophone intevins with Virginia Roberts Page bol 23 1 couple af weeks, muyhe a week, 1 had quit Mar-2-Lago and [ was working for Joffrey {ull time. IS: OF lets talk sbout your job at Mir-a-Lago, if we could. Yau said that your Dad was working there, Whi. was is position ul Mar-a-Luga? Vi Tle vis a maintenance supervisor | think is what it vas called? Ho like managed the tens courts aud air condiriouers and things ike that, 18: Whats your Duds full nome? b:3 Sky William Raberts. J8: Andis he still living bere in South Flarida now? vi No, he’s noi, he's in California. 18: Ok Is your Dad awae of what is curmcutly goivg on with regard th your having made ‘public statements about your relationship with Jeffrey? Vi Yew he in eli cue oF iL 1 told my family even before all this stuff came our, because hey were the fiest ones contacted by the journalists from Mail on Sunday. know that they the Mail on Sanday printed that | had gon our aud tod to, T mean F think on of the ‘photos sald that | was angry that save Jofitcy aud the Prince walking together and tha is “iy | came out and went public wilh everylhing. Not true. | mean, 1 am angry ubout how they are sil] vp fo heir old ways gether und (hat treg”re Stil Banging out but 1 didn’t contac the Mail on Sanday and [ dida’t bring it ot. | figured that everyone was. wong t bring i out anyway and 1 better bring it out the right way, He's known everything fiom the stat, and my family is very supportive with overyéhing goin an. 8: I'm kind of going to jump sound a Tile hil und. agologize for wat, bus since the subject Ts worme up, 141) me first uf ull why you are providing this cooperation to us, and | am certuinly very appreciative of it, but | want you to tellus why it is you've chosen 0 spend time with us on the telephone and provide this information that you're now providing, Vi Pmout to help the bigger pichire, you know, T think all of us can make a big diffecence in a lol of other people’s lives and T think that this has gone on long enough and it's a biz slap in my fae Ua he can gel away vic hurting me so bad let aloge so mou other girls and laugh about it. | guess | talked to you guys out because 1 want to sco the right thing happen, not just to him, but 1 want poopic in the world lo understand this js not the wy of life, You know, i's 10t acceptable to 0 out procure young girls und make them think that, this is the way you should be fiving and thut's wll. Yeah, [ guess my reason for doing il is Io help the bigger pure, you know, Tin a big befiever in karma and | believe ha goo things vill come back 0 You, 50 1 guess that's why I'm doing this. Bawasta acy. Epson Telephone nsevivw wih Vigiia Rohens Pugs Tol2t 38: Just forthe recur, neither Brad, tor |, nor anyone representing that they have anthing to do with os has ade any promises to you. [5 that corcect? Vi “Thats comet. Ll ell you, sines this is our first conversion, thal nobody has ude me fool Tike I'vo boon bribed ar boxagbt or hud 1 say smything. I've wkd you anything that Know from my own self, nol some hings somedy told me. If anything, Brad's been extru careful not 10 tell me anyching and let me do afl the talking, so iv’s quite opposite L think. IS: Alright, Let's get back then fo tho wory of your relationship with Jeflres, and we've talked ubout your (iv encounter with its and howe it evolved from that ato our fui ime emplaymen with Jeffrey, bu what were you doing at Mar-a-Lago before you quit Mara-Lago! Vi Iwas just a locker room ltendunt and sometimes [did habysitiog for the dich and fimo. So, 1 wisn’ any hing big. | worked in Ue pa area. ‘That's why L was studing ato, because | as really realy interested in becoming a massago erapist and at the locker room, I dida’t do much. 1 mean I was waking tes for a living, I would, you now, make sure the toilet paper had a litle triangle in it ler overybody went Lo the file, or wipe down the waler (rom the basin, Yau kno, it was a very easy peasy job. 8: Did you ges tha job thrvueh your Dad? Vi Ves, my Dad pot me the job. IS: Ok, tad you vicre only 15 years 13d rf the time, were they avare of how ald you were ul Mir-a-T ago? Vi Of course, deflaitely. We fad to go through extousive, you kuow, we cveu had to got drug tested aud id test and so on and so forth. 1 mem, Mantas (7) is very siice on employment, yeah, everybody knew. TS: Ok. Was there ever wy conversion with Ghislaine about how old you were before you were taker to Jeftieys mansion? Vi No. She didn't nsk me hows old T was from tho srt, bul when 1 did gel 10 Jefliey's ‘mansion, it was iscresscd how old T ws. IS Wilh whom? Vv: Dung the entire hour of what I call the Legitimate massage J was giving him, il wis ca and mowsc games getting information from me Go find out who 1 wn, zm 1 a willing ‘participumi in Mee kind of Tings, and how would react if hey were shout w ake the ext sep. Bul they gol information olT of me, they got ny age. they got my, a litle bit of ‘my history so they kis vias, yo know, not very stable at home, and they kw that, Edvard dv. Epevin elephone nes iow wilh Vii Heit Pugs tof2l you know, 1 was sctually intorested in meking my Jil eter by studying > what they ere offering me wos a chance tn became o legitimate masseuse bul it was geting trained They viould have peaple shaw me how to work the body and be called a massage therapist and get me bool on it, and you kuow, koop we interested, and cvery tine, you know, [was with Jeffrey, licrally was about toassages, J dom'l mean just going in and have scx with him. 1 mean massage, beens it would ulways sta aut with ‘masmge and then it would Jd into sometimes ofher things. 8: Alrghit, ance this evolved into full time cunploanent. what did full fine cuploymenr mea? Vi Thal was entirely having to travel with Jeffrey in every city. When he was in Pulm Thea, | stayed al my apartment, and he would call me © bis house once or tice a day sometimes, and that’s, you know, do things with him. Sornctimcs vis’ go out shopping, somctimes vic'd go out aud watch a movie. You knavw. simple things Hk tbat, £0 to an capo or & fiir. whitover it was, Bui when we were in alher cities, T was a my spartment_, Ulived with bir full me. What | mean by full ime is even in the middle of he night, Tcould set u ing on my phone 12x to me and tell me to como In bis room, you kano, so it was lieaally ful time. IS: When you say Ul when you sere in Palm Theach yau were fing in your upartmenl, wre you living an your own or were you living with members af your funily ar thal time? ¥: No, after | quit Mara-Lago, Jeffeey offered to get me an aparcnt in Palin Beach somewhere, Royal Palm Beach, and it was a nos apartment. He farmished it for me, it ens absolutely besutiful, bul yeh, that’s the only time 1 would spend fime way from Fim relly. 35: this apartment was on Royal Palm Beach Boulevard or ont inthe Villsge of Royal Pai Beach? ¥: Tso hanostly dan’ remember. Ve heen trying lo mck sy brain because the TRE was aking the sume thing ind were trying Ww find it, but yeah, Tn Not sur. 1 didu’t get to spend as much time in it, | was only there about an entice weak out of every month probably, bu the majority of the time § was with Yoffiey anyways. It was somewhere in Royal Palm Beach. T don't know about Royal Palm Beach drive. Tdan't even remomber the Royal Palms Buch drive sinymoro so Tm i doo sure. JS: OK, tet me see it can drave the distinction for you and maybe that wilt help sou 10 betp us? Road Palin Beach is a village thats... Vi No, no, uo, I got Royal Palm Beach, just didn't know fhe Royal Pulm Roach Drive, like shu street it's ofT of. Were you talking aout a sireel? Fidwanls adv. Fpstein Telsphone interview wid Virginia Roberts Pagnol25 I: Yes, L was talking about a stroct. Royal Palm Drive is on Ibe ishind of Palm Reach, and is a stot that is lined with Jorge royal pam frogs, ane I'm wemdering iF his was an ‘apartmacut on the islund or wan this an wpartment uk west of own... Vi No, it wise netually in Rayal Palm Beach, not on the island. 18 Aight WV: Towauld be driven, it sis closer to my family than it was closer to him. L wanted to be clase enough 10 everyhods’ else so that when | was i town. 1 could just go sce thee quickly. JS: Ok. So we're not talking shout Royal Palin Boulevard. We're tatking about the tova of Royal Palm west of town. Jefliey got you an apectment out there. i; “Ihat's correct. IS: When he was in Palm Peach, you were generally oot staying at the mansion, you vere staying at the apurtment that he 20k (ar Sou out vest of town. Vi has correct. 5 Ok EL T men then there was Limes, | don’t wanna say that every time | sayed at my apaitment. “There wis times we'd fly back from some city maybe too late at night to really want to £0 back home, 50 you kuo, it's like 12:00 «t aight or 1:00 in the morning, 1 was just Staying in the yellow room. o somthing ike that; ane of the guest rooms in Pulm Deach. But majority of he ime, E vwould definitely wast fo get back my 04h apartencidt. IS: Alright. What were the general hows of your ful tune eraployment when ...7 Vi Lhe was not sot hours. It wasn’t like logging. and you kiow, billing the shill hutton, nothing like that. The way T wuld get uid wauld be, ab, if T was in Palin Beach, 1 ould et S200 sn hour Uy massage Tellrey of some of his fiends and then go Lome. So iLwuld be ike that. TIT wes traveling with him, it would be per massage, so 1 would be geting paid per day. So | wouldi’t be geting paid on an howdy rate. He wouldn't say ok, today you're going to work for mc from 7:00 in the momivg mil 8:00 ul nighi. Ji ‘never liko that, Twos on call ll the time. JS: When you were here in Palm Beach, were You actually getting paid only for the time spent massaging Jefliey or were you getting paid from your aurival at is house until you eft the bouse? Vi From the tims the massage starled. Edorards adv. Epstein: Telephone inlerview wilk Virginio Roberts Pe 100125 1S: From the fimo the missago started, Ok vv Sometimes we'd go there and T would wail for a while or tlk with Ghislaine and Jeffrey about something or we'd mest somewhere and wk shout somthing, A lob of times, I'd ‘meet him upstairs in his room where he was ready for me. But then there was a lot bl mos whero if didn't start right away, so ho coukdit really pay me from he time | gat there sameimes unless it wis just paid from the tine [ massaged bin fi the timo the massage was over. JS: Alright, Did your doties for Jeffiey ever inchde anything other than providing him masmges and sex in connection with the massages? Did he ever give you any ofher responsibilities 1a perform? Vi Lvias asked 10 do the same things hat | did to JelTrey wa few of is fellow cofleaguss as well, Those were my duics. He fooked at it this way is that 1 wast going to be u Professional massage theampist und maybe { nccded some clicatele, so b had me perform erotic musges on a fo people. 1S: Did that starr hewe in alm Beach County? Vi Iedid. Tho firstono did. IS: 0%, und how Tong sltcr you first met Jeffrey did he first ask you to provide services for one of his riceds? Vi About 9 mouths, Thnk it was. 1 wasnt a full year, it wasn’t 6 months, bul beeen 6 anihs and year, which is why Y'm saying 9 months. 48: And when sou provided services 1o u friend of Toffrey's, who paid you for those services? Vi Jofficy would. I would get paid the next time | saw Jefftey, so if I way invited 1o the. Breakers Hofal fo give a massage, L would give a massage. [would go home, and the next duy when T saw TelTrey, he would pay me for what L did. So, it was paid always by him, Twas sel up by him, xo he slays knew shal fo pay me, © id got tips aud things like the, if you call it that, you know, like u hundred doll tip or something from & few of them, you know, yeah, IS Wasthere, Vi There was aiwags pasment frum Jeffrey. JS: Was thre cvor any discussion with Jefirey about what was expected to happen when sau provided massage services to one of Jeffrey's friends? Edvarts adv. Epson oleghune irri with Visi Robeets Page 110125 Vi Inn roundabout way, ses. In so many vias, Jellvey really really had to train me, und tl wos why Ghislain seid tat she and Joffiey oujoyed ae 50 much vas because thes never really ad to sperk much me to tell me what thoy wanted 1c to do. You kaow, | wast waiting or you know, ther directions. Joffrey would tel) me go give an erotic massage to friends.” He wouldn't ive mae mich detail about i, but he would say t treat them like ou treat me. I8: Did he refer it as ao cof massage or are hose your words? Vi Erotic massage is my words. ‘That’ exactly what il wis, but he would tel me fo rot them how he wanted it, 50 I'd do shat he wanted without having 10 uy fo me words more. ¥ moan, T canyliod vith what he wanted because it was somessbat of a, & dun’t Xow, 1 don't keoww how fo say i, if was just very mindbogaling how 1 fet him have so much control or power aver me basically. The msssuges would be routine to what Jeffrey and with my so called new clientele, ad with tei own wards wookd ask me 10 ‘provide them with sexual pleasure afer the massage. JS: Did you ever repart buck Io Telly shout what happened when you provided massages to his friends? Vi OF caurse, of couse, and I knew chat his friends were reporting back 10 im a well ‘beau Shere ware times where he would instigate convarsation by saying you know, sa ani #0 had a great time. you did wonderful, you know so and so gave me a call and told IT How it wen. IS: Did Jofey ever elicl details (om you? “Tell me what hagpened, describ in detail what went on? Vi No, hut be would have » Tasgh, hie had a Legh with me a fo times about some of their diffrent manaerisims, T guess you wauld say, like some of them, one guy hed a foot fetish and that vias really weird aud T mentioned it lo Jelrey, und we weld hove a liugh over it. He didn't want fo know details. He wast asking me “50 tel} me shal did you guys da cxactly.” No, hic just basically gave me a slap on the back and said, you kiow, gd job. And ve hud some kind uf conversation abou it, 1 can't recall any conversation off the top Foy bead. really don, kw ous, 1's been that long. Bat yeah, we did talk about iv briefly. J8: Com you give me an estizaate as 10 the mumber of fiends for whom Jefirey provided und aid Tor your services? Vi There was abaut, you know, | don't know, 8 guys posinly 8: Aud sic you able to name those people for me? Edvards ads. Fpsicin elplume inleview wilh Viegas Rober Page 12023 Vi No, not af this stags. | just, Some of these peaple ate really influential in puwer, und don't wan to start another shitstors with a few of therm. I'LL tell yom that there was some. erotic massages given fo, I'm just afraid to say it to you. Is: Ok, Vieginia Vi Ts)iko geez, Xdon'tkuow if T want fo, Xm really scared of where this is gonna go. 1S: Aight | understand thal, und us T told you from the beginning, if 1 ask you a question that You are uncomfortable answering, sou just tell me that, amd Twill move on, and { understand that at least right novi, You are ancomfortabe answering, und | ann cerluinly going to respect that, Vio Thank gous much, Tack. 38: No, that's quite alright. 1 am very appreciate of the cooperation you are providing, and [ don't sean! you at any time to feel that we are taking unfii advantage of that cooperation, a give me the information thal you's comfortable giving me, and if we get 10 a point sehere you're unc lrtule, [will respect that amd we'll mave on fom there. Vi Ok Js: Twamt to talk a Tito bit about the traveling that you did with Jeffrey. About how lang. into sour relationship with him did that ust start? Vio luediately. 1 sarted traveling immediately. Nol intermationally unbl T think about, Gosh, | can’t seumeriber even, | think ic was a Year law that we siarted doing international avd, Misbe [ike 9 wontbs to a year agala. Not too sure to bs hoaest. J8: So that would have been approximately the summer of 1995? Somewhere around therc? Vi Yes. Somewhere around there. Somewhere around a year, samewhere wound there, T con't pinpoint it cxactly., But like | said, we smarted doing domestic traveling immediately, so my first destination with him was New York and Santa Fe and the Carribean, California, T sould lake (ips with bir occasionally. Sometimes we would go 10 SL Louis or New Orkeuns or Santa Crus. We were tmveling just aboot everywhere 1 think IS: How did you tomvel? Vi Well, we took Jelliey's private joi, and umless 1 was being sont somawhere by myself for wiht we were just taliking about before, then 1 woul travel on a what do you cell, 8 public jer, whatever itis... IS: commercial Sight? Flats a. stein Telrphone iterview vit Viegiaio Roberts Page (30123 Vi Yes. Justa normal flight, au e-ticket TS: Tike the rest of us cammon folk. Vi Burwhen | vias waveling with Jefikey, the majority at the te would be on the black et. J5: Naw. when you say thers would be times when you would travel by yourself because be was weding sou somewhere, tell me about thal, How did that come sbout? Vi So, one of iis colleagues would be at the Carribean or Sana Fe of even New York, or ‘wherever, and he would call me up on those days where [am not working with hin of in Palm Beach with him, and ho would ask me fo got on the next plane 10 so aad so and go meet 0 umd x0, und thal" when T sould take e-tickets. His secretary ur special ssant, whatever, weld organize iL fr me and give aie the details and | ould just walk up the line and they"d fet rae righ through. I8: Cum you give mo any ideas as 6 how pany limes it happened that Joffiey would seud ‘youll’ meet some friend ois al same location uli of Palm each? Vi llow many times it happened? I'm not 100 sure. Probably about 10-15 times. 3S: Ok. Aud on thoso occasions, how much tine would you spend with one of Jeffrey's Hicads when you were scat w a location that you would bev to tuavel to? Vi Only a couple of dass. Only 2 days, thats il JS: And bow were you paid for those tips? Vi Twould be paid in eash upon ny arrival buck with Jeffrey. So, whenever [ wes back with Jefe, he vould count up how tuny days I"ve bid, sametimes give me ven more tn what] deverve, at deserved, but what | eared and ive ioe lite extra I8: Was there a daily aie for thos rips or was that per massage also? Vi Per massage. With Jelliey, Twould be honest. Todds’ toll him T did 15 massages if 1 didn't. Tle knew he could 10st we. Te could always come buck the other person thal he seat me To give massages and usk thea as sel, 50 you know, it sas aways by per massage. 3S: Alright. When we've heen bafking about massages. el] we exactly what it is we're ling ahout when we speak boul massages V: Same thing I would do to Jeffrey. Again, it woud start out as a massage, which would start with them being naked. 2nd sno giving him a legitimate massage to begin with, so Elvan al. Spin Telopboss inerica with Vegi Aakers Pare 140023 Td start with his feet, go 1p to bis calves, up his legs, buttocks, buck, bis nck, bis head, his ams, yada yada. aud then it would bo time to flip over, and some a the men wand want rac o coutinue on rasssiging the front wide of them und they would instigate me begin having sox with them ar replay, whitever you want o call it JS: Sooutinely, these massages involved sexual activity. Is tha accurate? Vi Thats sccurate, JS: Ok. Let's talk about the vavel that you were involved in when you were on Joffiey’s private plane. Generally speaking, who were the passengers on the plane shen you traveled. Vi Well, Lamy was the pifol, und then here was a short, small solid pus, | don’t know bis mame, but he was a co-pilot, and hen be changed and there vias another guy brought in Tater on. Generally speaking, there was always Jefiley, sometimes Ghislaine, somelincs Euany, sometimes a whole bunch of othr girls, sometimes fimous peaple, sometimes somo politicians or yeah. ust shout anybexly could My on his plane. There was never any sel routine sho would come and who would go. It wes an influx of people on TefTreys uirplane. J8: | want t deal with theso things separately in order to respect same af the reservations that you have, 0 I'm going to ask you who the people vicre that you remember Nying with Jefey on bis plane when you were personally present vithaut regs 1 whether hor ys any scx etvaty thu overran the plune or nut. Sa Pm ot asking you fa Smplicaic ny of these (maus people in improper conduct, but just tell me what the ines of the people are that you remember that you consider to be fous people. Vi Ok, there was Naomi Cawspbol, Heidi Klum, there was Bill Clinkn. There wis Al (7) Gore, there was a whole bunch of muxleds, wauldn'L really honestly be able a ive their mame. Thare wus Mist Groning the produce of the siimpons cartoon, Jack CCoustean's granddaughter a ot of interior desigoers, architects, politicians. {am just trying to think of as ruany wanes as possible for you. OFF the top of my head, that's as good as 1 can get for ow. IS: Ok, right, tuts fine. And again, T am not implying by my questions, nor do 1 want your ansusens 10 be interpreted as your suggests hat any of those people that you have just ideauified were engaged in any improper sctiviies on any pazticulsr figl, but 1 wear 0 alk you now about what went on on occasion on the airplav. OK? Vi Ok. Ttwas a lot of the sae hing thet went dow om the ground. A [tof times, ic would be just be te and Jedifey, or me and Jellkey and Ghislatoe, or ne and Jefliey and some aller gir, sometimes Tiny, Sarah. and Nadia Bjournik. (bere would be sexal conduct, there would be foreplay, there was a bed in there, 50 wo could basically recuact cxnctly Biter adv. sin Telephon miarvies wid Virgin Raberts Pago 15.0721 what was happeiting in the house, It vould stat off with massaging or we would stat off with foreplay, sometimes it would lead to, you kuaw, orgies. IS: Were thems occnsions when you wore in Teflrey’s company, sehether on the ground ar in the air, wheres thers were wher gicls present whom yau knew t be wider uge 18? Vi Yes. There was a constant influx of girls coming in and going out, And we were all very ‘young, Ou occasion, hero was some older girls. and 1 don't mean older as in like in their 30s or unything, Tsnean like 28, 29, someting like tht, just very ely. The majority of he girls hut Jeflrey actully met or hud an his plane ar in bis house were under age. JS: Do you know low it is that Jeffroy establishod with auy of these underage ails? Vi Yes, Tdo. He would send me personally or with alee girls to clubs or shops, 1o_pick up anywhere, 1 mean we were constantly on the Took foc other girls that might satisfy Jeffrey, IS: What instructions sere you given about what to look for? Vi Young. pret, you know, a fun pemonality. They couldn't be black. If trey were any ober descent other than white, they had to be exatically beautiful, "That was just about it 8: Who gave you those eriteria? Vi They hath gave ms he insiuetions, snd 3 wie Just me, Telfrey asked most girls Io bring a friend and make extra money. They would se ws young girls So that way it probably Locked a tot miofe safer to a rl that we were procuring 1 Younger girls that were alteady doing #, bat was the way that Joffe had it IS: Were yau given any instruetion at all an how 1b spprouch theso girls? Vi Yes. Jlefirey and Ghislaine both Gught we to, depeading on the circumstances, depending on the girl you could offer them a job 25 a massage therapist or you could tell then you have « really sich friond with, you know, great contacts in the acting world or madefing yiurid wnd he loves pretty girls, you should come back and micet him, ake some money, you know, we had a whale hunch of ways to be she (a procure girs. JS: Canyou give me any idea as to the total number of naderage gids that you know engaged in scxual conduct with Jeffrey during the period of time you hd your relationship with him? Vi 1 would hive mo way of estimating that whatsoever. T mean, there could be hundred, there could be tore, honesty I'm not too sure how many girs, really. | wish T did know. moan like 1 said these viere 50 many over the cowse of 4 years with Jeffcey. Fis a, tpseia Telophone interview sh Viginia Hoborts Page 160733 8: Letme see if we can ry 1b namow i down i file bil. Fs there any dao in your mind that it wus note than 107 Vi Yes, there was definitely more than 10. JS: Ok, what T want you fo do is I give me the highest mumbee thal you sec comfortable in saying there ieee definiely mare tan X aunher of widerage girls al T know Jeffrey Epstein engaged in sex with while I bad a relationship with hi. How would you Il in thst blank? Definitely saoro than bow many? Vi Tsay definitely tore than a hurd. 8: Alright. Did feffiey ever help to pick out your clothes? Yi Oh yes. Tynan he wasn't ant to dross we ke porn stat or anything. Ho would sbways dress tne very elas, but we'd just go shapping ull the lime togelher. JS: Did he ever expross any style preferences in terms of how Le waited you to dies? Fesiden drcssing clossy, [1m, you know, auy other suggestion fo you about how be wanted you dressed? Vi Ue didn't, like © said, wasnt uging Go dress me in any poostitle way or mything like that. Ie was nice, classy outfits [ was wearing Be Gucci, Dice Gubhans, Chel, things like that. He was buying me ot of very, very nice clothing. 1t was provocasise. | meun Twas wearing miniskirt, and tight short shorts and irl shits that showed ny belly and ms cleavago ani everything, but they wero very expensive clothes, IS: Was there every any dress up role playing? Vi You. There was. Lots of ie. Joffrey loved the latex owfits Ghislane had for us girls, he had bondage quilts, be had wl} different kinds of outfits, but his favorite was the schoolgirl. J8: ell me about that. Vi Well, yoo know, Ghislaine would taks me fo dress me up to surprise J or Jeffiey would ask me ta gel dressed up, hat would include wearing a tiny litle skirt with nothing underneath, a white collared shir thal you would be wesing 0 school witl a 6 in i Hed win a bow , wy hair in pigails, skins on up i my knees, and § wid go in there and act like a kid and we'd do role playing sexing. J8: Did Teffioy over brag fo you sbout the age of auy of the ids with whom be had relationships? Edrés dv. Eps Ieeghone erie with Virginia Ushers Pag 170123 Vi Yes.ho did. He did all thoime. The worst one thet heand from bis ows south was tis rotly 2 year old girls he hud flown in for his binhday. It was a suprise birhday gift from ome of his Irends und they were from France. 1 did sco them, I did met them. Jefiey bragged afterwards after he met them that they wero 12 year olds and flown over from France because they're really poor over thr, and lheir parents resled the money ‘or whatever the cas: is and they were absalutely Fee atay and flew out. ‘Those weee he worst ones. He was constantly bragging about girls” ages or where he got them from ar their past und has terrible sir past was and good he is maldng it for them. 18: Where were the 12 year old girls flown to from France? Where did they came ta? Vi Pulm Pow. J8: And were the flown in on JefPs private plans oe did they get transported? Vi No. They were tnsported by somobady else 18: Ok. Was the aexual activi that went on on the airplane conducted in such. way so thet ang ofthe crew was aware of what was gol on? Vi They wero told to knock i they hi Lo come aul, if he crew had to come out. They were told, you knaw, bs tome out as litle us possible, so they Weien't out there hanging our watching sverylbing, no, hut it. doesnt take an idiot 1 put wo and two together 10 say ‘well there's « whale bunch of halt dressed teenagers on board with this old man who is canstanly being massaged by them and he wuts we to keep the door shut for whal reason! | mean, only thoy could put that other, but yeah, they knew. JS: Did Mr. Fpsiein ever alk to you shout people of povee and influence oving him fvors? Vi Tle would laugh about it, you know, | never ceatly kev: what fo tak scrious from Jofircy because he was such a fami chassoicr at ims. You never know if what be was saying was true or not. Yooh, fofs of people owed him favors From what he old me. 11s gol everybody in bis pocket, ind he would Tusgh ahaut he helps people for the sole purpose in the end they awe him something. That's why | believe he does so many favors iu the First ple. 15: When and how did you first bocome avr thal Mr, Fpstein sas in trouble sith the lun? Vi wes first informed by, T think someone from the FI called we fiest and stacied to ask me gestions, and | suited to answer the questions bur then fear took over, and 1 just said Took, 1 don’t know what's goiug on, I've got a young family that I don’t want w risk, you know, please don’t bother me about this again. and i was real shor. simple comarsation, ‘and within a week or 2, 1 had golfca a call from JelTvey's attorney, and then u week later, Jeffrey himself Edwards ady. Exar Veliphon baarviow wif Virginia Rohorts Page 18 0123 TS: Ok, well Tels back up before vie gel 1 those conversations and tell me approxiunately when il was hal you were contaeted by the person who you believe was with the FBL ¥i Ok. It's hard for ms to pinpoiar, if hed to pinpoint it, it woukd he in 2007 somelime. IS: Alright, And you sere living in Australia at thal ime, coreect? Vi Comect. 38: You wore contacted by clephonc? Vi That's comect, by ms cell phorie. 15: Ok and do you have any dca how your bam came up leading to thal contact. Vi Node. No iden whaboever. When I did wi, 1 was told that some girls had revealed my name, | guess, aad that’s how everybody, the FBI knew to contact me. 58 OK Vi ButTdon't know offhund ar sarry, just walked ind the wrong room. 5S 0k Vv: Somygoon IS: Yes & II mover tell ber you said thes. Virginis, hoo Tong was it after that phone call from the TBI person were you ontacted by Me. Epsteio’s lawyers Vi Like a week Itwas back to back wo cach other. 1 remember being so soured ufir talking. 10 the FBI thinking viu’s happening. whnl's going on. 10% heen like 6 yer, 7 years ai lat stage, how did they find me & whil da T hve Lo da with this?” So yeah, | do remembes that very well, and it was only about a week later | was called by his attorney. IS: Who was ft thac contacted you, do you remember? Vi [wantto say Bill Riloy, but ho might have been from the FRI. No, it was Till Riley. Bill Riley. Not sums if at's his correc rime, but that" what i coming 10 aud 8: Whatdo yon remenber about that conversation? Vi Lremermber a Mr. Goldberger as well, I semcanber, there might uve been vi them. 3S Alright Edwards ety. Epstein Telphons rview wil Virgin Koperis Puss 190122 Vi Tean'tremember which ous it was. | want to say Bill Riley is tho good one. IS: Alright, cither Till Riley or a Mr, Goldberger or bath of then comiscted you, imd what do zou ferenber about that? Vi Tdow't know if it was the samc guy who contacted me thar wesk lator who put me in auch with Jeffrey. T think he yous on the phone and he put speakerphone on with Joffrey. So he commeeted me with Jefrey. T dan’Lauow i iL was the sume gay or different, bt 1 detinitely know: that Bil Riley was the 1151 Qus Lo cont me. en prety sure ahout thal. IS: Ok. Tell mo sbout har conversation. Vi He asked me what | knew shout whi's going on with Teflrey smd spparenly, there was an investigation beg eld about sane of the girls who had come out and suid thil Jofficy had sexual contact with them under the age of a misor and that he wus discrediting fof of hese girls and making thom out 10 be drug addicts and prostiontes and shal bac you sa They wouldn't be Jooked upan ss warlhy in fhe courts cy2s 5010 speak. And ou Kw, he Wid me in the [ini five mimics that, sou know, if slay quict, hat “ll be looked after”. Aud thar was the exact way it was Suid. ( wasal1 ike you know, Lm gouna pay you zillion dollars or anything if You be quier, but if] stay gues, | would “locked after”, And | remcmix saying { don't want any part o do with this, You know, bis is not something 1 wal Lo bs a part of, T've got a young faonily. 1 wish tho best for everybody in his, you know, take car kind of thing. A sock later, was celled after the Tearing by ane of Jeffreys lawgers. T can't tell vou exaedly which one i was bul he bad Jeftiey on the othe fine and he connected Jeffrey and 1, and Jedlrey teed 10 make sme: simple conversation, “Low are you? How have things been?” Yon know whet 1 oiean, catching up. 5: Dao you knaw i the Yoneyer, did the Iswiyer stay on the line while Jeffrey was sposking to you? Vi Pm prof sue bo did. [has why f think Jeffrey was on speaker phone because it sounder a lot different, and 1 vwas never taken off the line to begin with or connected to mother fine, so T was pretly sure Jeffrey wis on speiker phone und tho tawyer was making the call. After the simple conversation, it led what sas yore on gain snd you kno, Jeffrey couldnt believe ie. You know, he thought he helped all these irks owe. He did't think ke was wong in any circumstance here at all. A lot of these gis viere drug addicts and just aficr drug woncy. You kuow, he was rcally putting dowa these women ar these girls | should say, not ving then the credit hey deserved, and then be exactly repeated whit the lawyer siid the week belbre i thal he would Took aller me if 1 stayed quiet, and if need any help, you Know, his las yers would represent me and hi would get legal help for me, whatever | need, he would do, and 1 10kd him exactly, 1 said, “JefTrey. £m the mother of two children a that stage. © away from everything there, | donc want lo bo a part of it. I'm not going to spel to anybody aud 1 don't want to speak @ amsbady, T don't wit to ho involved.” That wes the last fimo 1 hoard from him, And the Ewan adv. Fpsin Telephon ierview ith Virginio Robes Pago 0023 next thing I knew, [was sent iy vietiin's ledter, my notification of beiog u victim trough the US Attomoy’s Office and that’s when 1 knew it was well out there enough not to have Joffiey's lawyers come back on mo and discredit me in the seme way he had done to all the other ils. So, T called up Joseph Bird who was the recommenda lawyers on my paperwork that they had given tne snd stared going from hore, J5: So you contact Mr. Joseph Bergs’ office and then you were dealing with his office from ad point forward. Vi That's comect. JS: Tell me about the ending of sour relationship with Jeffrey. “Ihat i, at shat pais in time did your full fim canploymens and and how did that happen? Vi Ok So, it hado'c really ended. 1 walked way from itl. Jeffrey sent me to Thailand where | met my husband and escaped t Ausieulia, never L return hack 1 the stags. About 6 months prior w that. ho came up with 2 proposition that | thought was realy disgastingly sick. And it really showed me for the first time in d years L had been with him hat mahing was going to change nd Twas always just going 10 be used by him?) sohich | did not like. Fle offered me a mansion snd sme of bis money every month, forget what he called it, a monly income of what he made 1 hear one of is children. The proposition was that if anything ever happened between Jeffiey and 1, that | would Lave to sign my child over to him basically and thet the child would be his and Ghislainc’s, nad T vould be looking afic it 2s Jong as nothing happencd between Jefirey and T. So, Twas kind of freaked ont by all of tht, I pushed Jeffrey more to please get me some ome training, you know, und T wis geting ulier and Dot of us wich intrest to Jeitrey anywizys. 1 wis 19 now, and he Tikes a female 2 lot younger. So he ent ma to “Thailand, in Seprember 2002 . 1 was firsc supposed 1 meet a giel there and bring her back with ms. but | never mot up with her, { proceeded get a short couse ia That massage 0 that ws to shit 0c wp about. my training sa { went ther, and ove of my fricads from school invited rie to veich a fight, bike u muy thai ght, which is lke » form kickboxing. So | went ard watched it, und | saw this uy thal vas = really ond fighter. and a girs word, looked really hor, 50 | asked ny feiend who knew bin ta imsoduce me. Wo gol introduced nnd £:ll in love iuwnediately. 3 davs later Rob proposed and 7 days. Tater wens being mwricd ina buddist temple, 1 called Jeff and told him I'm sorry, I'm never coming hack. I've golten marriod, "ve fallen in ove, | thovght ke'd wish tho best for me but he was a of rude wid he just suid “have u good Te” ond hung up the phon, and that 2s the last time Pd talked 10 him ever umnil ll this warled again. JS: Ok. Virginia, is thore anything clec that you would like fo add to what you have fold us up Lo this paint in ime? Vi Id dike to know that this time wound somethings going lo be done about it and that Jeffrey and a lor of his colleagues, na matter how rich they ure, will lin tht thero is Edsmrds ds. Epstsm Inbghooe inavien vith Vieni Roars Pags2icl2s law and hat there is people thai will believe in it. So that’s it. Thank you guys for Tistening la me, hearing me out and helping we. (0s kind of hard to get through. 1m Thank you very much. Yes, I'm sure it bas boon very difficult snd | am very apprecintive of the courage von have shown in doing what you have dane, which really brings ine the last subject, and thet is what was il thal. motivated you @ go public with alt of this? Vi Sharon Richund contacted ne. 1 like hier, I do, 1 like Lier a lot. 1 know she's a jovmlisl, and journalists ase normally bloodsucking leche, but Tike: her for thal, bul she is un honest bloodsucking locch. She fold mo u Jol shoul whak was 56M going an, and she showed me a picture of TefTrey with a Kile girl who looks like she could have been 12 youn: old. T meen # was disgusting. | agreed to talk with hes, | never agreed to do nyliing, until she showed me some pictures, and at that stoge, boing * mother of 3 childeen and having a daughter who | would do anything for in proieet, T wauld put my eck on the line to make sur: she ncver hus 1 go through what Thad 1 go through, and Knowing all of this, md knowing (hal he's sill out Mere doing the same exact thing with 1 regrets, na remarse, na worry about what he's doing to those rls, and ali those girls fecling the same way tat | did, 5 1, you know, I'm doing it because T believe in wy beet of hearts it's the right thing to do.” I's what T woul want samehady 10 da for my daughter or wy siser of my fricnd, 1nd if ssddcns me lo know thal it’s 31 going on right ow. I's like the seisholl story. don knase if yoa'te heard the story about the little kid wha throws buck arlish, you know, the line brother tries to ask his sister, “why do you throw them in, they're ull gonna die anyways, the litle gir says “well, it's this one That T can help, and this one that | can help,” and that's what { fool like I'm doing. I'm making a small det iu this big world we live in. 18: 1 cortaiuly appreciate tha ooursge, and T hve heard that story, aid you're dbsolursly Tight, hk cre pena may no be able Go 1nzke a difference for everyone, but one person can mike u dillerence for someone, aud hopefully, you atc making 2 difference for someae, and we're gonna do the best we can to make sur you arc making a diffarencs for as many people a5 possible, Vi Thanks Jock, J5: Justa Few other follow up things | want to ask vou and again, if any of these questions ave questions that you're wacomfortable in responding 0. then don't hesitate @ 1e1) me that. Do you have any rocollcction of Joffrey psi’ upeci ically fling sou that “Bill Clinton owes me fiers? Vi Yes Tdo. Twas a taugh though. Le would laugh it off. Yon kuow, I remomber asking Jeffrey whav's Bill Clinton doing here kind of thing, and he lughed it off and seid well Lie owes me a favor. He never told mo what favers they were, 1 never knew. T didn’ Lao if he was serious. Twas just a joke. JS: Where was here? Edvard a. Epstein Talcphone inoriese with Viegiaa Roberts Page 2.0075 : Vi He told me a lng time ao that everyone owes him favors. They're all in each other's pockets. TS: When you say you asked him why is Bill Clinton here, where wa ero? Vi Ontheiskind. JS: When yon were preseut with Jeffrey Epstein and Bill Clinton on the island, who clse was acre? Vi Ghislaine, Emmy, and there was 2 young girls that | could ideatify. | never ceully knew them well angways. Jtwas just 2 girls from New York. 38 And were al of you siaying at Jeffrey's bovss: on the island including Bill Clinton? Vi Thats correct. Vie had about 4 or 5 diferent villas on his island separate fom the iain hose, aut we all stayed! in the villas. IS: Wor sexual orgies a rogular occurrence on the istand et Jeffrey's house? Vi Yes 18: If we were to take swom testimony from the people [ am going to name, and if dose people wero to tell the truth abont what they knew, do you believe that aay of the following people would havo relevant information about Joffrey’s taking advantage of underage girls? So TH just nan a mm, aid you tell me yes if they thi the truth, T think they'd have relevant information or no, [dont think they would, or 1 Gon’ knaw ‘whether they would or aot, OK? You understand” Vi Yes JS: OK. Les Wexner. Vi Lchink lie bas relevant information, but | don't think bel ell you the ruth. IS Ok Alm Demshowitz, Vi Yes Js: David Copperdield, Vi Don'tknow 8: Tommy Matola. abate. Lp Talons bit wilh Vigne Robs [intonty vi Donnas. Is: LPrinoc Andrew. ¥: Vex, he would know a lot of the tah. Again, [ don’t know how much he would be able help you with, but seeing he's in a Jol of rouble himself these days, 1 think he might, so 1thisk he may be valuable. Pm nuk lou sure of him. I%: Ok. Virginia, I think that’s all I have for you. Let me tell you what 1 would like to do. Ag T wld you in the boginning of this conversation. we've been recording it, and hopefully, we've gat u clear enough recording so thal we've taken down overything accurately and when it’s transcribed, il. will be clear and wecutate, but what | would like todo is transcribe it, send it 10 you, have you take & look at it, and if there's anything thal we gat wrong in fhe statement, you can waite back and you can make changes in the transcript so thi the bansceipt is accurate. Is that fair? vi No worries. That is fuir. No problem. 1S: Alright, great, I really do appreciate that and tell me what the best way is 10 send ihe ‘mseript lo you. Yi Fmail. TF you just want 10 send it by emafl or i you want to sand it by mail, cither or. FS Ok. Give me your email address if you vould please. vi RRGRRINE 15: Let me red ih back you: AER Vv: Yep that's it. BE: Thaek you Tennu, appreciate il, Vi Noproblem, Brad. JS: Thank you very very much. Bye Bye now. Vi Take care Jack. Nice vesting yom, Is: You teo. [EN ———— KIRKLAND 8. ELLIS LLP Jobn Rob, Esq. Principal Associate Deputy Atiorcy General Office af the Deputy Stiomey General United States Department of Justice 950 Pennsylvania Avenue, N.W., Roam 4115 ‘Washington, D.C. 20530 Dear Mr. Roth; T again wanl to thank you for this opportunity to explain why we believe that a federal prosecution of TeMrey Fpstein is unwarmaied. | appreciate your having informed us that you alieady have ow May 19 and May 27 communications to the Depuly Altorney General. as well ‘as our prior written submissions 10 CFOS and to the Southern District of Florida, In fight of the significant vohune of our prior submissions and to facifitate your review, we have drafied four supplemental submissions that will provide a roadmap for your investigation of this matter. Given the bulk of these documents and their appended supporting attachments, you will receive this packet by messenger tomorrow. A brio description of cach of the Tour submissions follows. First, T have included & succinct summary of the facts, law and policy issuen of hund. Thix document sets forth 4 bugic overview of the issues and summarizes our principal contentions us Lo why federal prosecution of (his matter is neilber uppropriate nor I'he three other submissioos inciude: a summary of the irregularities and misconduct thal ‘ocourred during the federal investigation; a letter from former CEOS attorney Stephanie ‘Thacker that responds to CEOS’s assessment of its limited review of Mz. Epstein's case; and a point-by- ‘paint rebuttal fo First Assistant United Stites Attomey Jeffrey Sloan's recent letter which we believe contains aclu] inaccurscios lypical of our comespondenoe rom the Uniked Stetes ' Attorney’s Office in Miami (the “USAO™). Alw, for your reference, the package you receive tomorrow will contain a binder including all documentation to which we refer in our submissions. Finally, we will be providing a detailed checklist of each submission or substantive communication to the USAO. Our intention is that you have copics of cach such document to enhance your review, If there arc any that you have not received from the USAO or CEOS, please advise und we will fedex them to you without delay. KIRKLAND 8. ELLIS LLP John Roth, Fg, Tuc 19, 2008 Puge 2 As you we likely aware, the Department's prior review of this maker was incomplete and, by its Own admission, not “de nova.” See Tab 38, May 1, 2008 Letter fromm A. Coslurbun. Without considering the Non Prosecution Agreement at lef this matter to be resolved in the State or any of the misconduct, CEOS reviewers, sked with reviewing some of their own previously expressed opinions. asscssed only whether the United Staley Alomey would “abuse [his] discretion” if he pursed this case. Wile we appreciate CLOS's willingnces to cxamize these limited issues, its cooclusion that a prosceution would not be an “abuse of discretion” rings particularly hollow in light of CEOS’s adrirbly undid concessions that we have raised ‘compelling’ abicetions ard that a prosecution un these cts would require “novel” applications of federal Taw, Indeed. oven a bricf review of CEOSs own mission statement reveals how nappasite a federal prosecution i to the cts in this case Importantly, we nate that the CIOS review sis conducted prior to the Suprere Courl's very scant decisions in Santos and Cuellar, which we believe—iliuminating as they do the Court's interpretive methodology when It comes fo federal cominal Lsw—powerfully demonstrute (be substumlive vulnerability of the USAQ's unprecedenizd employment of tluce fedecal laws. That Office's inlerpretation would never pass muster under the Supreme Court's recent pronouncements and should mo be countenancod. That is all the more true under the circumstances where the duly appoinied U.S. Atvmey upined that, in cffect, the “unitary” Exsewrive Branch was driving this prosecution. We nw kno (hat is not so. What I respectfully request, and wiiat [ hope you will provide, is & truly “de novo” review—ihat is, an indopendent asscssment of whether federal prosecution of Mr. Fpsicin is both neseswury und warranted in view of tho logal and evidentiary burdles that have been ideniifid, the existence of u State felony ples and seniemos that have been advocated by the State Atiamey for Palm Beath Caunty, and the many issues of prosecutorial misconduct and overzealousness . that have permeated thie investigation. | alsa request thet you provide us with the opportunity during your review to meet with you In person to answer any yuestions you may have and fo elucidate some of the issues iu our submission. We heliove that an independent reviews will confirm our song. belief that fderal proseentons would be tequired to stretch the plain meaning of euch clement of the enumerated statutes, and then to combine these distorted elereents in u tenuous chain, in order & convict Mr. Epscin. Indcod, Just this week (and after two years of federal involvement in this matter), Assistant United States Aftomey Villafina re-iniiared the federal grand jury investigation —in direct. contrvention of the parties’ Non Prosccution Agrcoment—and jssued vet another subpoena seeking evidence in (his case, See Tub 19, Subpoena to [IEEE Lo hc subpoena, AUSA Villafana directs [IN SSESN:> oppess on July 1, 2008 w give iestimony ‘and produce documents t FG) 07-103 West Palm Beach. The attachment o the subpoena seeks documents sich as photographs, emails, telephone billing information, and cantact information tat relat: to Mr, Epstein as wl as specific other people who received protection from federal ’ KIRKLAND & ELLIS LLP John Roth, Esq. Jun 19. 2008 Puged prosecution as 2 result af Mr. Tipstein’s having cnicred into the September 24, 2007 Now ‘Proscontion Agreement with the USAQ. ‘Notably, the Non Prosecution Agreement contains the following ugreed condition: Fler, upon exes of ths apscaicnt 30d 8 plea sgssement with tho Se Amys Ofice, he fuderal Grane Try inveiation wil be. aopended ad ll pening toda) Grand Jury swhposrias will be held in abeyance unless and wnti) the defendant violates any feem af thiy sgrcsncnt. The detsadant ouiso opess wild bi penicg Tlion to Geren: 00d o ‘go corbin gan jury subpoenis, See Tab 21, Scprember 24, 2007 Non Prosecution Agreement. It also guarantees that persons identified in the Grand Jury subpoena such I und Leslie Groff und others will not be prosceuted. The new Grand Jury subpoena clearly violates the Non- Prosecution Agreement. Although Mr. Epstein has exercised his rights to appeal 0 the Department of lustice withthe full consent and knowlodg of the USAO, he has not breached the Agreement. “The re-connmencing of the Grund Jury isin violation of the Agrocmeat. But father, the new investigation, which features a wide-ranging, fishing-cxpedition tye to scarch in New York does nothing to satisfy the very essenti elements ol federal shtutes that are licking despite the intensity of an over two-year investigation in the Palm Beach aren. AbsenL evidence of Internet luring. inducements while using the phone, travel for the purpose, fraud ar caeecion, the subject of the New York investigation is as lacking in the essential basis for converting a state case into a federal case as is the remainder of the Florida investigation. ‘The reaching out to New York to fill the void emanating fram the aflures of the Florida investigation compellingly demonstrates the misuse of federal resources in an overzealous, ver penalized, selodive und extraordinary aétempt to expand federal lav: to where it is bas never gone. This last-ditch atempt hy Ms. Villufana reinforces our belief that the USAQ docs not have facts that, without distortion, sould justify u prosecution of Mr. Fpsicin. In view of the prosecution’s often-verhalized desire lv punish Mr. Epstein, we believe that the prosecution summary suffers from critical inaccuracies and aggregaes the expected wstimony of witnesses so as to Teach a conclusion of guilt. Our contention is reinforced by the fut thal key proseuion witnesses have provided evidence and testimony that directly undermines the prosecution's misleading and insecarate summary of its case. Indeed, we now have received statements from three of the principal accuscr— INGE through = state criminal deposition). I (trough o federal FRI-USAG sworn und irgmseribed interview), and SE— ithrongh a defense generated swom transcribed interview). Tech of these witncsses categorically denics cach cssential clement that the prosecution will have to prove in order to convert this quintessential slae-law case into a federal matter. KIRKLAND &. ELLIS LLP John Ror, Esq. June 19,2008 Page d Jt hus is espesially troubling dat the USAO hus not provided us with the wanseript of pa federal interview, nor the substance of the interviews with Ms JEN or Ms. nox aay information generuted by interviews with any of the upprositasicly 40 alleged witnesses (hut tho prosecution claims if hus identified. Because the information provided by these women goes diroetly to the question of Vir. Epsicin’s guilt or innocence, it iv chic Brady information. We understand that the U.S. Altmey might not want to disclose impeachment information about their witnesses prior to a chasge or during pla negotiations. Hut we firmly helieve that when the Goverment possesses information that goes directly Io 3 target's facrual guill or innocencs, th wrget should be informed about such heartland exculputory evidence. Most importantly, aside from whether the Deparment belicves Brady obligaies disclosure to a target ola federal investigation prior tn the twrgel's formal accusation, no such limit siould apply to a Department review. Accordingly, we request that you go beneath the face af any summary provided to you by the USAO and instead review the actual witness transcripts aud F131 302, which are essctial for you to be able to make a truly independent issessment of the steengeh and windom of zny federal prosecution. After careful consideration of the record, and as much ex it pains mo to say this, simply do vot believe federal prosecutors would have been involved at al in this matter if not for Mr. Tpstcin's persoual wealth and publicly-reported lies to former President Bill Clintim, A simple interme seurch on Mr. Epstein reveals myriad articles and news stories about the fommcr President's personal relationship with Mr. Fpstein, including multi-page stories in New Tork ‘Magazine and Vanlly Fair, Mr, Epstcin, i fact, only came t the public’s aficntion a few years ago when be and the former Prosident traveled for a week to Alien (using Mr. Epstein's airplanc)—a tip that received u great deal of press coverage. [ cannot imagine that the LSAQ ever would have contemplated a prosecution in this case if Mr. Epstein lacked this type of notariety. Toat belief hus bocn reinforced by the significant prosocutorial impropriety and misconduct throughout the corse of this mater. While we describe the majority of these invogulaitios in another submission, two instances are particularly troubling. First, the USAO authorize the public disclosure of specific details of the open investigation ta the New York Times—including descripeions of the prosecution’s fheory of tho case and specific terms af a plea negotiation helween tho partics. Sccond, AUSA Villafar silempled to carich friends and close acquaintances by bringing them busincss in connection with this msltcr. Specifically, she attempted to appoint a close personal friend of her live-in boyfriend ta serve as an attomey- representative for the women involved in [his case. Tt also bears mentioning that actions taken by FAUSA Sloman present an uppesrunce of impropriety thal gives us cause for concern. Vir. Sloman's former lev partner is currendy pussuing u handful of $50-million lawsuits against Mr. Fpstein by some of fhe masscuses. KIRKLAND & ELLIS LLP John Roth, sq. Jac 19,2008 Page 5 Finally, as you knaw, Mr. Tipstein and tho USAQ cntered into an agreement that deferred prosecution to the State. In this regard, 1 simply note that the manner in Which Chis ugrcemmct wat negolinted contrasts sharply with Me. Sloan's current representation that “fhe SPIT. Indicated a willingness to defer to the State the length of incarceration... * See Tab 1, May 19, 2008 Letter from J. Slonnun, p. 2. This statement is simply not teas. Contrary lo Mr. Slomaw’s asscrtion. federal prosecutors refused Un accept what the State belioved to he uppropriue a to Mr. Epstein’s sentence and instead, insisted thal Mr. Epstein be required serve a two-year tem of imprisonment (which they later decreased to 18 month plus ane year of house arrest). Federal prosecutons huye not anly involved themselves in what s quintessentially a state matter, but thele actions have caused a critical uppenance of impropriety that raises doubt us to their motivation for investigating and prosecuting Me. Epstein in the first place. At bottom, we appreciate your willingness (@ review this matter with a fresh—and independent—sot of eyes. Lo facilitate your review. T once again request the opportunity 1 make mw: aral prescntation to supplement our written submissions, and wo will promptly respond 10 any ingairies you may have. Saugebincprsly, 1 WS Kenneth W. Sarr ee Deputy Attomes Genecal Mack Tilip CONFIDENTIAL SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL RE J. EPSTEIN KIRKLAND 8. ELLIS LLP 7 um Pipers sit [hifi eviairitd Fr ina or Fo: E— Tune 19,2008 Jol Roth, Fay. Principal Associate Deputy Attomey General Office of the Deputy Atlomey General United States Department of Justice 950 Pemaylvaia Aves, NW. Room 4115 Washington, D.C. 20530 Dear Mr. Roth: 1 again vient to thank you for this opportunity to explain why we believe that a federal prosceution of Jeffrey Epstein is unwarrantad. [ appreciate your having informed us that you already have our May 19 and May 27 communications to the Deputy Atlorney General, as well as our prior written submissions to CEOS and to the Southern District of Florida, In light of the significant volume of ovr prior submissions and tu facilitate your review, we have dualied four supplemental submissions that will provide a roadmsp for your investigation of this matter, Given the bulk of these documents and their appended supporting attachments, you will receive this packet by messcager tomorrow. A brief description of each of the four submissions Hows, First, | have included & succinct summary of the facts, law and policy issu at band. "hs document sel forth # basic overview of the issues end summaries our principal contentions as o why foceral prosscution of Gis matte i neither appropriate nor warmed. ‘The three other submissions include: a sumenary of the ireguiaritics aud misconduct that ‘occurred during the fedetal investigation; letter from former CEOS attomey Stephanie Thacker th responds to CEOS's assessment of its limited review of Mr. Epstein’s case; and a point-by- point rebuttal to First Assistant United States Atiomey Jeffrey Sloman's recent letter which we believe contains facto inaccuracies typical of our comespondonce from the United States : Atoruey's Office in Miami (tn “USAD). Alto, for your reference, the package you reecve : tomorrow will contain u binder including all documentation lo which we refer in our ‘submissions. Finally, we will bo providing a detailed checklist of cach submission or substantive communication 10 the USAQO. Our intention is that you have copics of cach such document to enhance your review. If there are any (hel you have not reccived from the USAO or CEOS, plese advise aad wo will fedex them to you without delay. haps Hongkong min Meh dewiok SsPwene WeagnbC KIRKLAND & ELLIS LLP John Roth, Esq. Juno 19. 2008 Page2. As you are likely aware, the Depantment’s prior review of this ruatier was incomplete aud, by its own admission, not “de novo.” See Tab 38, May 13, 2008 Letre from A. Qostorbaan. Without considering the Non Proseuution Agreement that loft this matter to he resolved in the State or any of the misconduct, CEOS reviewers, tasked vith ceviewing some of their own previously expressed opinions, axsessod only whether the Uniled States Attomey vould “ubuse. [his] discretion” if he pursucd this case. While we appreciate CEOS’s ‘willingness to examine hse limited issuce, i conclusion that a prosecution would not be an “abuse of discretion” rings particularly holtow in light of CEOS's admirably candid concessions that vio have raised “compelling” objections ad that proscetion on these facta would requis "aovel” applications of federal Jaw. Indeed, sven a brief review of CEOS's own wnission statement reveals hoi inapposite & federal prosceution is 1 the fucls in this caso. Lmpariantly, we note that the CEOS review was conducted prior to the Suprems Court's very recent decisions in Santos and Cuellar, which we belicve—illuminating ss they do the Court's interprotivo methodology when it comes fo federsl criminal lew powerfully demonstrate the substantive vulnerability of the USAO's unprecedemied employment of three federal laws. That Office's interpretation would never pass muster under the Supreme Court's recent prodauncemenis and should not be countenanscd. (hat is all the more true under tho circumstances where the duly appoinizd U.S. Attomey opined thu, in effect, the “uitary” TFxeculive Branch was driving this prosecution. We now know that is not so. What 1 respectfully request, und whit | hope you will provide, is a truly "de novo” review—shat is, an independent wxscasmer of shather federal provocation of Mr. Epsteia is both necossary and warranted in view of the legal and evidentinry hurdles that have been identified, tho exisience af u State felony plea and sentence that have boen advocated by the Sie Attormey for Palm Beach County, and the many jssucs of prosecutorial misconduct and overzealousness that have penneated the investigation. | also request that you provide us with the oppurlunity during your review to mect wilh you in person mau any quastons you may hace and to elucidate some of the issues in our submission, We believe that au independent review will confirm our strong beliel that federal prosecutors vould be required 1 stretch the plain meaning of each element, of to epunerated statutes, and then to combine these distorted cloments in a (enuous chain, in order to convict Mr. Epstein. Indeed, just this week (and after two years of fodoral involvement in this matter), * Assistant United States Attorney Villafun re-intiated the foderal grand jury investigation—in diteet contravention of the parca’ Nom Proscoution Agreement—and issucd yet aucther subpocns sckiag evidence fn this sas: See Tb 19, Subpoers io INL 1 he subpoena, AUSA Villafana dirccts INES: 2opex: on Tuly 1, 2008 to give testimony and produce documents to FGJ 07-103 West Palm Beach, The attachment to the subpuena seeks. documents such as photographs, exis, telephone billing information, nd contast information that relate to Mr. Epstein 4s well as specific other people who received protection from fedora] ” KIRKLAND & ELLIS LLP John Rath, Bsq. June 19, 2008 Pago 3 prosecution as a result of Mr. Epstein’ having entered into the September 24, 2007 Non Prosceurion Agreement with the ISAO. Notably, he Non Prosecution Agreernent eoniains the following agreed condition: Foren, upon execution ofthis nperent and pls assent withthe State Atooey's Offs, ihe federal Grand Jay brosigaton wil Le mooie, | ll proding fda Grand Tuy subpsenes il) be bed is Sbeyance loss and nl fhe defiodea violas any toa of chs agtitnan. The derodact Wowie sgics a wild his peadng moda to Barer and to ‘uh shin grand uy poco See Tab 21, September 24, 2007 Non Prosceui i tees that persons identified in the Grand Jury subpoena such gE and others will not be prosoeutod. The new Grand Jury subpoena clearly violates the Non- Prosecution. Agreement, Aithough Mr. Epstein has cxercised his rights to appeal to the Department of Justice with the full consent and knowledge of the TSAO, he has not breached the Agreement. The re-commencing ofthe Grand Jury is in violuion of tho Agreement. But further, the new investigation, which features a wide-ranging, fishing-expedition type to seasch in New Vork does nobis to sil the very essential elements of federal satus hat are lucking dospite the intensity of an over two-year investigation in the Palm Beach wen. Absent ovidonce of Inteenet ling, icducemenes hile using the phone, tuvel for the purpose, fraud or coercion, the subject of the New York investigation is us lacking in the essential basic for converting & state cue into u federal case as is the remainder of the Florida investigation. “The reaching out to New Yotk to fill the vold emanating frora the failures of the Frida investigation compellingly demonstrates the misuse of federal resources in an overzealous, over- personalized, selective and extraordinary attempt to expand federal Law to where it is has never go, This stich attezpt by Ms. Villaana enforces our belief hat the USAO docs not lave Facts that, without distortion, would justify a prosecution of Mr. Fpstcin. Tn view of the prosecution's often-verbalized desire to punish Mr. Epstein, we believe that the prosecution summery suffors from critical inaccuracies and agercgates the expected ‘wstimony of witnesses so as to reach a conclusion of guilt. Our contention is reinforced by the fact that key prosccution witnesses have provided evidence and testimony that directly undermines the prosecuions miskcading and inaccurate summary of ifs case. Indesd, we sow have received statements from three of the principal secures [RRR hh u sale erimioal Se (through a federal FBI-USAO swom and. wrnscribod interview), and (through a defense generated wom {ranscribed interview). ‘Fach of these witnesses categorically does each essential element tha: the prosecution vill have prove in order Lo convert this quintessential state-law case into a federal matter. KIRKLAND & ELLIS LLP Joha Roth, Esq. June 19, 2008 Pages is especially troubling that the USAO has mot provided us with the asuscript of Ms. federal interview, noe the substancs of the interviews with Ms, JENN or Mis. nor any information genssoed by interviews ith wny of the approximately 40 alleged ‘witnesses that the prosecution claims it has identified. Because the information provided by these women goes dineetly to the question uf Mr. Epstein’s guilt o insooers, its clasic Brady information. We understand that the 1), Atiomey might not went t disclose impeachicent information shout their Witiesses prior 10 & charge o during plea negotiations. But we Branly believe that when the Government possosses information that goes directly to trgels factual suit or innoosuice, the targel should be informed aboul such hearand exculpuory evidence. Most importantly, side fom sicther the Depuriment believes Brady obligaios disclosure to a target of a federal investigation prior to the twget's formal accusation, no such limit shold 2pply 10 a Deparoment review, Accordingly, wo toques? that you go hencath the fice ‘of any summary provided to you by the USAO and insteed reviews the actual wimoss transcripts ‘and FBI 302s, which are essential for you to bo able fo make a truly indepsudent assessment of the strength and wisdom of any federal prosceution. After careful considerarion of the cecord, and as much as it pains me 10 say Wis, T simply do not believe federal prosecutors would lave been involved at all in this mater if nol for Mr Epstein's personal wealth end publicly-reported tis to former Prosident Bill Clinton, A simple Iniemst. soarch on Mr. Epstein reveals myriad articies and news storics abou the furmer President's personal relationship with Mr. Bpstel, itcfuling multi-page stories in New York Magazine snd Vanity Fair. Mr. Epstein, in fact, only one fo the public's wiention a fov years ago when he ond the former President traveled for 2 week lo Africa (using Mr. Cpsiein’s airplane) tip that received 2 great deat of press coverage. | cannot imagine that the USAQ ever would hve contemplated a prosecution in this case if Mr. Epstein lacked this fype of notoriety. That helicf has been ecinforcsd by the sigaificant prosscurarial impropriety and misconduct troughout the course of this matter. While we describe the majority of these irmgularitis in another submission, two instmeey are particularly troubling, Fist, the USAQ awthorized the public disclosure of specific dotafs of the open investigation to the New ork Dimes-—including descriptions of the prosecution's theory of Lhe case and specific Lerma of a plea negotiation between the purtien. Sccand, AUSA Villafans stomptod to enrich friends and close acquaintances by bringing them business in connection with this matter. Specifically, she attempted zo appoint a close pecsonal fiend of her live-in boyfriend to serve as a ulomey- representative for (ho women lavolved in this case. It also bears wentioning that uctions taken by FAUSA Slomen present an appeerance of impropriety that gives us ceuse for concom. Me. Slomun's former law parcoer 3 cumaly pursuing = handful of $30-millon lawsuits agaivst Mr. Epstcin by some of the musscuscs. KIRKLAND & ELLIS LLP John Roth, Esq. Pages Finally, as you know, Mr. Epstein and the USAQ entered into an agreement tht deferred prosecution to the State. In this regard, I simply nole that the manner in which this agreement was negotiated contrasts sharply with Mr. Sloman's current representation that “{T[he SDFL Indicated a willingness to defer 10 the State the length of lacarceration , ,. ™ See Tab 1, May 15, 2008 Lotter from J. Sloman, p. 2. This statement is simply mot true. Contrary (© Mr. Sloms's ‘assertion, federal prosesutors reflised to accept what the State believed to be appropriate gs to Mr. Tpatein’s sentence and instead, insisied that Mr. Epstein be required scrve a nwo-year term af imprisonment (which they later docrcased 1 18 month phus ono year of hotwse arrest). Federal prosecutors huve not anly involved themselves in what is quintessentially a slate matéer, but theie ‘actions huve canscd a critical appearance of impropricty that raises doubt as to their motivation for investigating and prosecuting Mr. Epstein in the first place. At botlam, we apprcoiate your willingness fo review this matter with a fresh—and independent—sct of eyes. To facilitule your review, | once again request the opporhuaity fo uke an oral presentation to supplement our written submissions, and wo will promplly respond. to auy inquiries you may have. Tous) Kennel W. Siar ce: Deputy Attomey General Mark Pilip MAIN SUBMISSION ; KIRKLAND & ELLIS LLP SUBMISSION TO HE OFFICE Qk tik: DEPUTY ATTORNEY GENKRA INTHE MATER OF JEFFREY. EPSTEIN feftrey Fpstcin, a successful husincenan and noel philanthropist with uo prior criminsi eevard, has been investigated for polential violations of 18 1LS.. §§ 1591, 2422(b) and 2423(5). Since ths limited 1oview coudeted hy CEOS, two Supreme Court decisions —one authored by Tustice Scalia 42d fhe other by Justice Ttomas—kave rovitalined the bedrock principles that feral criesinal statutes ust be narmowly canstrued, (at they may not bs stretched to federalize onduct not ily covered by their pronibitions, and that hanover there are two plausible camsfrections ofa criniioal statute, the narmovier consteuction (hich safeguards beets) rather than the ‘muader consiretion (which exp tho federal psecutor’s arsenal) controls vader lhe veaezable mule of lonity. Mr Bpstein’s conduci—ineluding his miscomluct—lla within tho Lesrland of historic sto police and prosecuurial powers, Abst a significant faderl nes, meners volving prostiation kava alway been treated 38 ste-law criznca even when thoy involve minors. Mr. ‘Epstein’ conduct lacks ny of the hallmarks that would convent thin quintessential ste cme into a federal ong under auy of the statutes prosecutors are considering. Mr. ¥psiin lived in Palm Beach, aud Lis inecstate travel was marely 10 0 Some. Any. sexu) conduet tant occurred aflcr he amived was incidental (o the purposss for his tavel, Even ‘ CEOS admitted that applying § 2423(b) to 2 citizen traveling home wonld be “novel.” In fet, it h would b both unprecedented and in Gouflict with Supreme Cort cases that have withstood the test of time far over 60 years. Worcaver, br. Epstein did 201 use the iatemel (vither via omail or chatrooms) to camenunicato with any of the witnossss In this investigation. indead, he id aot use wy ather fasility of fntersiate commerce, including tae phoas, lo knowingly persuade, entice, or induce: amyome 10 isis Lis hone the “local” cus of al the incidents ander iuvestigation uch loss fo persuade, entice, ur induc & knOWR MICOf tu engage in prohibited sex acts, ay § 242261) requires, Nor did auyont on his behalf “persuade” ur “induce” or “catice” or “coerve” inyone ns these words ace ordinarily understood aad as the new Supreme Court decisions manda hey he applied: narowly, without mrciching ordiviacy sige to confor 0 a prosecutor's case specific nod for 2 broad (and in this caso unprecedenicd) spplication. In addition, a5 will be shawn low, § 2422(b) requires that the objec of the communication be a state lew offense thet “can be charged.” Yel becuuso the state of Florida's tatuto of imitations is one year for the fire prostitution offense und thros yours for other targeted offensos, and because ofl or virtually all of he offeuse cuncuct a: i35u6 in the federal investigation ocenized prior to June 20, 2003, those cls oun mo be chicgod by the State, wd dus oamnot meet this essential element of federal law. Fuually, Mr. Cpsioi neither coerced, ar ensleved, nor traflicked, nor derived say profit from his seul conduct, He was an undinary “Toh,” not a pimp. But § 1591 bu directed only aginst those who engage ia force ur fraud or coercion or who are i te business of commercial 1 - KIRKLAND & ELLIS LLP sexual trafficking. “The statute has never boon asplicd fou “John. and only a highly und impermissibly aciective proscoafion could stretch § 1591 fo reach conduct like thal al issue in tia ease. In short, without “novel” interprotive expansions—a description used hy CROS itscif—it comnof be shown thar Mr. Epstein violated any of the twee federal matures identified by prosecutors. As the Supreme Cowt’s reccnt decisions in Santas and Cuellar make cloar, fodcral law may not be stretched in that manner, and the cunt foderal investigation relics, as its foundation, vn imperoissivly elastic stretches of each stamte beyond ay roported precodeat, bevoud the essential elements of each statate; well outside the ordinary constmetion of each ‘sratute’s limitations; ad 0 a selective, extraordinary, and unwanted expansion of foderal ‘aw © cover conduct that has always boan exclusively within the care nf tare powers. Al is point in time, the need for Departmeato] oversight is cricical. We appreciate this upportunily lo submit our assessment of the key facts in this case and review of the pertinent [feders] statutes, und respectfully request that the Office of the Deputy Attorney General end [ederel involvement in this matter so that the State of Florida may resolve this case appropriately. Summary of the Facts Mr. Epstein hus muintained « howe in Pulm Beusch, Flurida for the past 20 years. While 7 there, he routinely conlucied busines, receive medical alcation, socialized with reads, cad % belped cere for his elderly mothes. Mr. Epstein also had various women visit his home 10 pect massages. He did cot persorally schedule the wassage appoistments or comicnie with the women over whe phone or the Inemet. Rather, Mr. Bpstcin’s personal assistants scheduled many types of appoiutiments, personal traicars, chiropractors, businoss mostings ws massages. Tie phone message pad raken from his hous and in the possession of the government voalinned that in many cases, the women themselves contactod Mr. Epstein’s assistants to inquire about is availsbilicy eather than vice versa. “The majority of the russes were just thet wad nothing ele. Ms. Epstein ufien would be om the telephone conducting business while he received Fis massage, At limes, (3: masseuses would be topless, and some sexual activity might ccur—primarily self-mastusbation. on the part of Mr. Epsicin. On olka uccasiona, no sexual uelivity vsuld oeour at all. There was no peitem ar practice regarding which masseuse would be scheduled or a particalar day-- if one would be scheduied sf all—or whether any sexual activity might occur. Indeed, Mr. Epstein almost never now which massense lis assistands had scheduled until she amived See Tab 3, JEON Records. Mr. Epstein specifically requested that each wasseusc be at Teast 18 years old, The vast majority of (he masseuses were in fact in their twenties, many accompanied to Mr. Epstein’s home by friends or even other family members. Furhermore, most of the women who have tested hat they were actually under 18 heve specifically edlaitted To systematically lying 0 Mr, bpstein abut their age. See Tab 4 WENN Tr. ut 38-39; Tab 5. JET. at 16; Tb 6, 2 ’ KIRKLAND & ELLIS LLP 6, 6,22, 45; Tab 7, I 13; Tob SO Tr. ot 5; Tb o, MT. ut 5; and “Tab 10, JE Ir. 0% 14-15 (excerpls from these transcripts ato included below). Furthermor, the women who visied Mr. Epstein’s home all visited vohmtarily and many willingly retumad seversl times, The State Attermey's Office (the “SAQ™) has vast experience prosecuting sex mimes and conducted an exhaustive, 1S-month investigation of Mr. Epstein. A Grand Jury has concluded thar Mr. Epstein was merely a local “Jot,” guilty of soliciting prostitution in violation of stats tae. Notably, Florida lw distin shes soliciting from procuring und compelling prostttion if minors are involved. Indeed, soliciting is = misdemeanor except for tbe commission of a third schvoquent offense, wraiag i inlo a felony. Tho SAO, therefore, sought ind chisined m indictment. charging Mr. Epstein with felony solicitation of prostitution. Mr. Epstein is prepared to plead guilty and sccept sentence for that offonsc—a sentence that, notsbly, is far more severe than that meted out to other “Tohns™ convictod of violating Tlovida’s solicitation laws for ‘cases in which sexual uctivity wes allogod. Trough CEOS points oat its admirable goal of “protecting children,” a moniker thar nga high cxnulios, the conduct allged hard involses wore over 16, wich ie the aga of consent in 38 states and supplies the effective fdorsl age of consent. The young women were hy a0 means the target of high-schoo! trolling; they werd individuals who. with friends, visited Mr. Tipuicin's hous--a home fll of [eds and staf. The civil complaints fled ayuirst Mr. Epsicin eiterate the fact hat the individuals who visited Mr. Epstcin would visit with their fiends. And { Mr. Epstein never spoke fo ur had any contact with these Wornen before they urmived at his 5 house. And again, tho Stato Landling this matter sppropristly. We raspectiully submil that that should be the bopinning nd the end of this matter. As. you kaawi, the Deparmient's Petite Policy precludes sucoossive fodaml prosecutions afler a State ha acted: “(4] stare judgment of conviction, plea agreement [here held in abeyance solely us a result of the federal investigation], or scquiltal on the merits shall be a bur 10 ny subsequent federal prosceution for the same act or acts” SAM, § 920317 (emphasis added). Consistent with ehat principle, and of purticulur relevence to this case, the Depataent itself just recently observed the following: [PRrostitution-related offenses have historically been prosecuted at the state or local Jevel. This allncation between state and Federal enforcement authority docs not imply tha thes crime ar Joss scious, but ther reflects important social wilocations of respamsibility between state and Federal governments... [T]be Department is not aware of acy reasons why sue und local authorities are not surenlly able to prrsve prostinutiou-relted crimes such that Federal jusisdiction See Tab 11, November 9, 2007 Letter from Justice Department Priccipel Deputy Assistant Attoraey General Brian Bencskowski fo the House Committee on the Juliciary, p. 8-9. ‘ KIRKLAND & ELLIS LLP Summary of the Law We hve reviewed every reported case under 18 U.S.C. §8 1591, 2622(b), and 2423(5), nd cannot find a single vse thal resulted in a conviction ou cla akin to th ones Lore, Ln some respec, itis not surprising thal no precedent supports federal prosceution of a mau who angeged in consensual conduct in bis home, flat amowats 10 sofictation under Sto low. Afcr all, promtariou, evan when the allsgations invoive minors, is fendamentally a Ste cancers, Tinted States v. Ewan, 476 F.3d 1176, nl (11th Cir. 2007) (noting thet fodoan: law “does not crimicalize al acts of prostitution (a vice traditionally aaveme by sate rogntion)”), cud ther i nn evidence that Polos Bruch County authorities ani Florida proscestors canuot effectively proscents and punish the conduct, See alse Aatchelder v. Gazalez, No. +07-cv-10330 SEM. AK, 2007 WI. 5022105 (X.D. Tha. Ot. 19, 2007). In fact, he opposile is rus—the atnc-cleoted uficials, cognizant of the loval mores of the Gommunity, hve 2 lauded history of just sock proseculiens. To any cvaat, and os set forth below, Bane of the federal states in this case remotely supper a proscontion on the facts of this cass Who each aud every element being strciched in a rovel way to ciiompass the behavior at issue. We begin with first principles. Courts in this country have “eadiioually exercised restrain in assessing the reach of federal criminal states, bth oul of deface fo the precaglives of Cangross, Dowling v. United States, 473 U.S, 207 i (1985), und out of concer tat ‘a ir warning should bo. given to the world in language that the B wommon workd will understand, of whe the fa irs to 00 if a certin line is passed. Arthur Andorson LLP. rived States, 544 TLS. 696, 703 (2005) tqating McBople v. United Seates, 263 U.8..25, 27 (1931) (citation omitted). “Iwo recent Supreme Court decisions dramatically nadezscore these principles and help to highlight why federal prosecution in (his case wold be iuproper a u matter of both Jaw and policy. See United States v. Santos, No. 06-1005 (tute 2, 2008); Cuellar v. United Shazes, No. 06-1456 (lune 2, 2008). Though they both adress the interpretation and application of the feleral money fauedoriug statute, 18 U.S.C. § 1956, the principles they set forth aro cqually applicable hors, In Sanias, the Court held that the stanrory term “proceeds” means “profits” rer than “recoipts,” ead thus ave he statute a significantly arrose interprellion than what the govenment hd urged. Tn his plurality opinion, Justice Scalia emphasized thar where a statutory som in a crtuinal satcte could SUpPOTS either & amo or broad application, the marr interpcation must be adopted hecause “(w]e interpret ambiguous criminal staffs in favor of defendants, not prosecelors.” Shp op. at 12. As His opinion explain, the ric of laity “ot only vindicates the undaments] principle tat 0 citizen should be held acconniadle for a violation of a statute whose GommANAS are waceduin, or subjected to punishment (sat is nuk clearly proscribed. 1 also places the weight of ineria mon the pay tat can best induce 4 F: KIRKEAND &, ELLIS LLP Congress o mea moro clearly and keeps courts fiom making erluinat faw in Congress's sta” Sip op. at 6. In Cutelar, ts Court examined the ink benveen the momey-lsundoring stante’s mans rea requirement and the wdedlying eloments of tho offense. Aller u caroful textual analysis of the salute and its structce, tke Court ruled that the defends convictian could be sustined only if he knew th: tae transportation of finds to Mexico wus. designed fo conceal their nature, tocation, sanzoo, ownership or conhol—not merely tha the defend Knew that the finds had heen hiddeu during their transportation to Mexico. Slip op. al M117. Both decisions relied on the ordinary meading of the stetutory terms Congress chose, And both ejocted atteupls 10 broaden ose wonls lo cover conduot not leary targeted hy Congress. Vakeon 1ogetier, these dsciions ojoct the notion that prosecutors can fake iagunge from u varmowly drawn federal stelute—specialfy one that ilsel federnlios the prosecution of conduct traditionally Witkin the beartland of State police puweni—and convert it eto a Liemse to reach aldiiona) conduc by ignoring, rewriting or expansively interprcting the law. Both cases additionally rejected the notion that statutes abould be broadly construc in ordor to fellate prosecutions or to 01 auyway diminish the hore on prosecutors to prave uch essontial element ofa federal charge in conformity with Congress's determinations as (0 what is whi the federal ctimirial uw and what is oot. The conflict botwoan the Sanus end Cueilay decisions and CBOS’s great of effeatively unlimited discretionary actharity to Se USAQ lo ske fodcrnl lav to / “ov” places where hey have never reached before could vot be stacker. Sa ‘Thase lessons have no less farce ia the vontext af Kxeouiv Brauch decision-making than they do in the vunlex! of fudicial interpretation. As you are aware, when federal proscentors ‘oxereias theit disczelion, they hear an independent constitutional obligation to faithfully interpret the law 25 weitien a to broaden iss scope beyont the mits endorsed by both Congress and the Presiden. There is no support for CEOS view that the courts or o jury should ultimately decide where a “wovel” construction of the low is cot. Instead, che Exculive Bruch ffslf ha non-delegable obligation no to exceed is wuthoritys the poviey of other brunches to check or remedy suclt wsnrpation doce not Iogitinize executive action thas oxcoeds its bounds. See Tab 12, November 2, 1994 Memorandum from Assistant Attorney General Waller Dellinger to the Hon, Abner J. Mikva, Counsel To The President, on Presidential Authority To Decline To Exons Unconstitutional Statutcs, available al bp: tfwww.nsdo.goviolcincnexcut him, In Gis case, the text, sucture, ued history of the relevant federal stetetes unambignousty indicate (hal these sztnios vere desigued Lo address problems of a national aad imrcruational 1 ts Seven, bi como wpm, ah acknowl dod th i ofan, fin the planlty apices dicusion of that wl. "aly peatusive. {isd Sess , Sond, No. 08.1008, lip op 05 (Te 3 2008) [ony —— 5 ; KIRKLAND 8. ELLIS LLP cope—uo the local condor tha is alleged hero—and cach of these stalutes voquites proof of tho dofedant’s actoal knowlodge that spl is not prosant in dis vase. Any aCmpe to steeich ho language of thane SaHUICS 70 cover this case would be misuse of the Taw and contrary fo expres logilative intent. In shor, the elements under cach federal siatuto—1T8 LLS.C. §§ 1591, 2422p) wd 2423(b)—are mat swsied be. 1 Muse sem 18 ULS.C. § 2422(h) requires the goverxaent to prove beyond a reasonable dont Gt he defendant eagaged in communications over un infersits facility ., the Intemat ar pou) with Four cancurent intents: (1) to knowlagly (2) persuade, induce, entice or coer, ar scape fo pecsunds, induce, entice, or coerce (3) a minor (4) to engage in prostitution or criminal sexual sclivity Jor which dhe persn can bo charged. Mr. Epsin’s conduct docs nat satisfy the elements of § 242206). Each eleman zust be individually stretched, and thee conflated fn a tenuous ¢xain to eacompass the alcgod conduct with any individual vioian. As the statue makes clear, he essence of this crime is tha communication ftsolf 5ot the resulting act. The Coun of Appeals for tie Eleventh Cirouit, in AMurrefl, undeuscorss the poiatz The defendant in Hailey contended that attempt ander § 2422(h) ‘requires the ‘spscific intel t camnit illegal Sexual wcts rather than just the intzat to persuade solicit the minor vietin: to commit sexu acts” fd. at 638. In response, tho { ‘court held [while it may bo ese fos there to bo # separation between the intent to -. persuade and the follos-ip inten 0 pexform the act aft perstasion, they aro twa eleauly separate and ditforant inteats and the Congress has wade. clear choice 1 criminalize pessuasion snd to arent 10 persuade, not the perfoemmce of the sowul acts Grwselvoa. Hence, a conviction ender the statute only requires a finding that the defendant had an intent (© persuade or to attempt fo persuade. ited States v. Mureell 368 130 1283, 1287 (kth Cir. 2004) (citing United Stores v. Bailey, 225 F.3d 637, 638-39 (6th Cir2000)). Thus, the targeted crim conuct must occur through the intarstate Lacikity, not thaasafcr, aud the sciender clemenr must be present ut the time of the call or Internet confuct. In this case, hewever, Mir. Epsteia did not use my intersiate fcilly to communionte any ilagat intention in thi case: 13 phoue culls were mado by his assistants in the courso of setting up many olher sppnimmonss, Neither u conspiracy chargs nor u charge of aiding and abetting can fulfil the piers rea 1cquisetnent hee. fodcd, neither Mr. Epstein nor his assistaats knew whetbee sexe! activity would ueseasaily rout floc: a scheduled massage. Abd cecléaly, na such ustivity was over discussed on the phonc by eicher Mr. Epstein ar His aesstuts. Tnlead, a1 th record in this case males clear, many appointments resulted in no illegal sexual activity, and ‘often, 35 sonfirmued by the musscuscs’ own testimony, several individusls wo were contacted by ‘phage visited Ms. Epstein's hase and did nor pecform a massage at all. When: sexual activity [] ‘ KIRKLAND & ELLIS LLP did oso, i was waialy sel pleasing mastwbotion and cot necessily illegal, but spontaneons smd resulted frou face-to-face canversaions during the massage. Thus, the fact that Mr. Fpstein fater may have persiaded amy particular masseuse 1 engaye in unlawful activity durlag the massage docs wot work retrosetively to Tae tho earlier scheduling phon call an offeuse nde §2422(b). Nox is (here any evidence that women who retumed to Mr. Fpstein’s home time aud Again ware somehow coerced or indaced aver a facility of inferstals commerce to 40 $0. The fist essentiel lament of § 2422(8) that “Tw Jhuover, using the ena ex any facility or meas of inerstule or forcign commerce” by ils plin language, requiss that Ge soruaication, which is the cssence of ho crime ar ils actus reus, tako place duriug fhe use of the facili of inlerstole commerce (in this case, alike (he vust majority of Internet chat room ating opeiafions, 4 telephone). The statuto fs not ebiguows. IL requires that fho orimiaal covciuct occur while the defendant is “using” (i. engaged in the communication), not thoreafer, Given ie utter lack of direc cvidaos against Mr. Ipslin, prosccators have sigaaled that they ‘tend to offer purely circumatanial case if (his mer procscds to trial—sssentially gulag tat “routine wd habit” evidena could sbsitute for actual prof that an utarstite facility was used to solicit sex from minors, Thus, despite the fuct that the calls hemos were not made by Mr. Epstein and did not contain tho ncocssary explicit communication @ knowingly induce minors to provide sexual favors for MORcy, proscctiiars are seeking to tum the phrase “arc. ‘ou mvailable™- the same phrase used with frionds, chiropractors, aad trainers—nto a ten-year Fi manducry prison sentence. Lu any case, tho pmsecution’s alleunated wmgment regarding { “routing and habit” will also not ft the facts of this case. The Wiluess {esGimony at issue makes clear that thers was 10 clear “routine or hahit™ with rospect to the fnleractions ul issue. And in those unprecticiable instances where sexual contact reste, it Was a product of what acura after the benign phone couuusication, not during the call iscll Tue prosecution's theory of iability—hat a call 1 person merely to sehodal visi 10 tc defendant's residence followed by « decision made ot the resident o engage in prokibiied sexual tivity is sulciem—camot survive ther 2 “pla Lngusye” Les or the le af Juity as they have beea auhoritatively construed fu the recent Suntas wl Cusllar cases. “The samits anor be read otherwise. As ths Cusllar decision makes clear, « proper interrelation of 4 federal. camiaal state is guided “hy the words of the vperaive statutory provision,” not by autsids objoctives. such as those fai itating sucoesstul prosecution. Sez Cuellar, supra, Sfp op. 37. As Justice Alito stated is bis concurring opin, the government must prove not jurt ic “offost” of the secretive transportation, but also that “pelitioncr knew thal xchicving one of these effects iss 0 design (i.e. purpose) of the transportation” of currency. Cuellar v. United Sates, prs 553 U.S. Slip op. At 1 (Alito, J. concurring). Similarly, it is not enough thas ou effect of a communicalion scheduling a visic botsvoen Mr. Epstein md a minor was that there might be subsequent Suco-to-face inducement. Tustead, the watute, as drafted, defines the crime as the communication al domands that far wore be proven than that tho use of an interstate vilty rowalicd in ator mocting yhere even ua inducement (43 opposed fo a solicitation was made. 7 3 KIRKLAND & ELLIS LLP ‘The prosecution ws 1ovor represented to coun that they have evidence that would prove that the inducement or caricament (0 engage in illegal sexual gets occurred over the phone (or Tenet). The proscaution’s referecces to “roulins and habit” evidence thal would substitute for the explicit communications usually found in the. tmuscripts from chal roms or sting operations is lemuas 2 host, In essence, the prosscation would bo alloging communications understood, but mol spoken, by two people, ume of whom was usually a secrelary or asiatan, Sopcating (he acrur reus aud the mens rea, however, and promising criminal labihly on persuasion thal might occur after the cummhunication, or on the Gxistence of a specifi inicat fo sugage in illege] sex with a minor that arise afer the communication wovld viola the bedrock prnciple of criminal av: that predicates lisbility a the cancurreace of the act and the criminal staie of nisl. Even if, angiendo, the communication and mens rea could be separated (3 premise which iv ul odds with he requiransnt of concurrence), Mi, Epstein denies that the Frerval proof demonstrates much a posteen or practice. Instead, the ovidnce compellingly proves has there wos no regularity of predictabilicy to the content of the communication ur in what occured at meetings that wore tolephanicelly scheduled (netoding those that are the subject of his invostigatios). A second events] clomcnt of 2422(b) requires that tho defendant “kowwingly” induce, persuade, entice or cacree a person believed to be awinor. *.. . [K fmowingly induces... requires the Court e define inducement so it is consistent with fs ordinary usage sad so the term is nor 50 browd that ic submis the separate slututory farms of “criices” and “persuades.” / Irdncemant has a common logal moaning that has been endorsed by the govermead when it { porates to marrow the affrmalive defense of entrapment. /nducement TIUSt be MORE in “ere cL solicitation” it must be mare than an off or the providing of an eppormuiy lu enguye in prohibited conduct. See, eg. United States v. Sanchez Berrios, 424 F.3d 65, 76-77 (1 Gir. 2003), United Staicy v. Brown, 43 124 018, 625 (117 Cic. 1995). The government caunot fairly, or consiston: with the rule of lenity, advocate @ broader deffaition of the rams som when it expands u citizen's exposure 1 oriminal iiability than whea i mits the ambit of an affiamative defense to crimina; conduct. IF the term ja ambiguous, absen clr Congressional inteat on the issue, the Court's dovision in Santas requis (hat the Natrower ruther them the broader deflition he used. The facts simply do not prove Mr. Tpstcin's culpabilicy for knowingly inducing or persuading minors. Firat, in tho case of masseusen who sgroed or oven songkt to return to sce Mr. Epsieln un succossive occasions, there is no evidence that thcto was any inducement, parsussion, eaticement or costeion over the phone. And, for messenses seeing Mz. Epstein for the first ime, there was geacrally no telephone cantact with Mr. Epstein and there was po loowledye that any third panty al Mr. Epsicin’s spsvific direction was inviting the fo Ar. Epsiein's horse over tae phone athe than in face-to-face leetings. The women who visited Mr. Epatein's hame were all ends of friends. Contrary to the fucks in this case, § 2022(b)'s Knowing judscarent element is essential 10 federal liability and. given 1s hefty minimum ‘mandatory punishaneat, it should not be interpreted as strict lability statute. 8 F KIRKLAND & ELLIS LLP There is insufficient cvidonce that Mr. Tpstein (argeled miners, as required. The svidcutiary pattem Coes not evan aswblish willful blindness since Mir. Epswin took sieps 1 nsw Lis visitors were aver 18—aud certainly took non lo void knowing. Bu, even if (he ‘goverment canfends that it possess ovideaos that could demonstrate that Mr. Epsteia kuew or should have Lown or suspected that 8 small muenber of the msseuses wero mndernge, that woul #6 net wake (és un uppropriatc case for federal, sober hun site prosccution. The federal stitutes were nol intended tn superseds state prosecutions involving ikalated instances of underage sex. Insleud, the forers) statutes were inlendel for large-scale Tiogs or or an individual viho was engaged, while vaing intestate Facilities such as the Intemet, wich the willl targesing of wis. The govemment's svidencs, oven when stretched ta the limit, will not show a pattecn of targeting undecuge pens for illegal scnual activity. A fedecal prosecution shoal not becorue contest between the prosesution aud defense over wheiher the defindant knw, suspected ar sould have known whether a particular person was ur wis mot over age. The Listory of cases brought under this slotte make ceyatal clear that knowldge of the defendant regarding the age of the women is cequired—ither by admission ur by incontrovertible transcripts of conversatiaps (i.e. stings aperations which require repeated acknowledgment of the defendaat’s aearencss of the victims’ age). Hven sacs with absolute ibility shoul mistake rogarting age rarsly prozocute cases where definitive proof Js lacking (Palas Beach County rarely docs and when it docs, it imposes house amost scatcrecs). This is a matter for the exercise of stole / prosecutorial discretion aad nul federal mandatory minioin SErutes hal were not intended to { cover such conduct. A third eosentol clement of § 2422(5) is she requireaneal that the govemmens prove that th defendant actualy believed that the person heing persuaded (coerced, et) was a minor &t the time of the ommudication. See e.g, Offousc (struction 80, Eleventh Circuit Patton Jury Izstnuctions-Crininal (2003) (“The defendant can bo ford guiky of that offere only 1. the defiant believed tat such individual was less than (18) years of age”); United States v. Mune, 368 F.30 1283, 1286 (11% Cir. 2004) (§ 202200) requires thot the defendant nervingly target minor). Luportantly, then, all the cloraeats must be proven with respect to a speciic . peop. Hoviever, we wre Lold thet the majarlty of proof is sw more than toll records, not recorded conversations or ntemet cha rnscripts, but toll revords ard pechaps a memory of whit wis said years ago on a partcnlar cali for a panicular tequest from # particular person acting at Mr, Epsieia’s direction. ‘Two final points boar sposial emphasis ere. The state, which according to Santos and Cuellar must bo narrowly construed, also quires that the fudveement be cugage in prostitution or sexual accivity “for which {the defendant] ean be charged.” 18 1i..C. § 2422(3). However, simp prostinution is sot defined (or made punishable) in the US. Co, and iste lave thus supplics the appropriate reference point, Undar Florida kaw, “prostittion” entails. the “giving or receiving of the body for scxual activity for Lice,” Fla. Stal. § 796.07(1)a), ané tho tem “sexual activity” is limiled ta “oral, anal, or vaginal penetrution by, or union with, the 9 { KIRKLAND & ELLIS LLP sexual organ of another; anal or vaginal penemtion of other by any other Gbject oc the bundling ox fondling of the sexual org of another for the purpose of mastwiation.” Fla. Sta. § T9601). Also, the Florida Supreme Cowt jury Instructions define prostiion as involvias “youl inforcousse.” As a ml, topless massages- even ones: for iro that include self: stinhation— fall outside the ambit of the satcrlaw deffuion of prostitution. Abscat proof bzyond a rezsouable doubt tha, al the critical time of the communication, Mr. Epstein bad a specific inn to persuade anoiier to Sngags in prostitution or “sexual activity,” as dufined by Florida law, be canal be sity of an offense under § 2423(b). As iowpurtant, the plain language of the phrase “for which ry person can be charged” nccessacily excludes eels 35 to which fhe state's statute of Fmitetions has rr. Under Florida Jaw, prostitution and prossbuion-Telatod offeuses are misdemeanars in fhe second degree for x fist violation” See Pla. Stat. § 796.07(4)(a). The limitations period for a misdemeanur in the socond degree is one year, and there i 10 ting provision based upon the victim's age. See Fla. Stat. § 775.150). Tren xs to allcgasions of third dee olanics, the state of limitations is threc yours. Thus, ny conduct allcged fo Lave occurred bofore mid-Jue 2003 cant be changed os @ mndter of state law and ths cannot be a predicate for a § 212200) offense. evea if the federal sue of limitations has not run on aay given § 2422(h) offense because of the iengthics statuto codified in 18 U.S.C. § 3282. Thus, no prosecution under § 242206) can be brought hasod pan inducemmeat of prostitution or soxval activity for which Flrids's stante of icnitation has ror, Furthermore, in Tlorida, the statute of Eanitations docs mot simply give ries fo ¢ a uffimuative defense, On ie contrary, slatuto of lutations “creates & substantive ight which 4 prevents prosceution aud conviction of an individnal afte the state bus run.” See State v. King, 282 So. 24.162 (Fla. 1973); Tucker v. State, 417 So. 24 1006 {Fia. 3d DCA. 1982) (citing cases). Given he one-year stetate of fimilations, any conduct thai might amount to prostitution or other chargeable sexual activity thal ceed bofore one year from Loday is not coud for hich any person a0 be charged with criminal offense. Also, given the these year statute of imitations for third degree clones, uny allegations of illegal sisle criminal conduct. that is clamificd as o third Cegree felony cannot ho chargod In the state and, concomitandy, caniot be the basis for a fedecal charge ander § 2422(0), 1 tho Gxicat that I oceurred—sa did almost al of the pivotal allegations (e.g. the [INC c52tion which was made in March of 2005) prior to wid-June of 2005. 2 IBUSCSIS * hw orfese is fel of hind dee ely for ton svbseqeent violation. Fla. SL § 796.0764 0 5 10 Fa KIRKLAND 8. ELLIS LLP 18 USC. §1591, a acx iraflicking statue, pravidas up 0 40 Years” imprisonment for anyone (1) who recruit or nhixins by aay mens u person In inforstate commerce (i) knowing hat (ke person i under 18 and (ii) keowing that the person will be caused to engage in a commercial sex xet. “The ros: Leiuous of crimes, described on tie CEQS website, full within is statute ind includ the buying and selling of children aud the forced servitude of third-world Imatigrants brought 0 tis country 10 be enslaved. Mr. Epstein’s bebisvior ia nowhers sar the Beasland of thin statute. “This stavate has alan boen proviously reseeved for prostitution rings evolvi violence, drugs and force. In sark comirass, her is uo jurisdictional hook that brings is. Epsivirs conduct within the ambit of (he state, and securing a prosecution on thea facts ould eequize: u court to act aside both reason und precedent fo coat a local ‘Tokn' with 2 sx slavery crime. IL can not bo said that Mr. Epstein engaged in trafficking and sluvery nor did ho Knowingly recruit ar abiain widcrage women with knowledge iat they would be caused to engage in a commercial acx act. THUS, prosecuting him veer this statute would expend the lave fae beyoud its scope. Tu the extent there are cases where prosccivors tink that Me. Tpstein should have known thir carlin women wats underage, there i no evidence hat Mr. Epstein “caused [them] to engage 3 commercial acx act” The (em “cavse” naturally implies (he application of same. £011 of force, coercion, or undue presses, bul there is no cvidcace that Mz. Epslein’s infeructions wih the women were smything but consensul. Again, many of he women phoned Mr. Epstcin’s assistant (hesmaelvos in ove to determine whether he waiod a coassage. Nor can the ; cause roquireaent be proved sitpply by the uct that Mr. Rpstein compensated the women. Aller £ 3E. the slalule elsewhere requires that the women “engage in commercial sex ac” which by dcfiition mess (hat they would have received something of valuo in exchiage fr sexual scrvices. Luteipreting Lhe atatat to authorize prosecution whenever a commercial sex act results stom solicitation thus would render tho fern “caused” superfluous, and wavld make every ‘Jol’ who incerets with a usdecuge proitute guilty of a federal erimo—sven where the iTusaction. i entirely local. Read in context, then, there is io doubl thu the statute targets pimps and sex teaffickers who kucwingly obtain underage girls and direct tem engage in prostistion. The isnot a shred of evideuce thet Mr. tein (or his assistanis) id any such thing, and be csunot be proscested unior his statute. The Cuiar und Santos decisions also foreclose a prosecution under § 1591. Just as the fedecal rooney laundering statute did not coe down lo a proseription against Transportation of criminal proves that aro hidden, the sex twallicking of children statute cannot be builed down and expanded to 4 federal proveription of commercial acyval activity with persons who lum out tobe below Ge agoof 1H, 3 puscsaes n p KIRKLAND & ELLIS LLP 18 U.S.C. § 242301), a statu cnactad to avevent sex tourism, provides up 0 30 years of impnisonment for anyone who tvels across stats lines (i) for the purpose of engaging in (i) illicit sexual conduct with a mainor. Neither of those elenieats is selisfod hore. Mr. Tpstein did not mave) to Palin Beach for the purpase of cngrglae in sexual uctivity with & finer, within the meaning of the statute. The evidence is indisputable that Palm Bech was were Mr. Kpatcin spon most of is discretionary me, ad that is travels to Palm Beach Svert were rips Tetumng oft to is home of twenty years—nor the cacapades of a se ouriat olf to same destination. inextricably iertwined with the required significaut or dominant pucpose of that tip ta be (© have “illicit sexcol conduct” Fpetcin’s mips to Tabn Beach were simply those af a businessperson saveliog homme for weakends or stopping 0¥er on bis way Lo or from Nexw York sud St. Thomas of to visit bis sick und dying mother fn the hospital for months on eud. Tle certainly did not 5avel 10 1s hom: in Florida for the domsinm purpose of augiging as ssl condsct with a parson sho he knew was under 18 when be did not pow, at the tine be decided 0 uve, from whom be 3s to receive a massa, ihe were tn reccive one ot all In Cuellar, th wnanizions Supreene Court linked the term “design” in the money- Laundering stants 10 the 61s “purpose” und “plan,” nd stressed that those ters all exited he defeadant to “Formate a plan foi; devise” “(lo create ar contrive for a particular puspuse oF effect’; fourry aut] [a] plan or scheate” o¢ “Uo coneeive and plan aut in the wind.” Sti. op. al 12 (citing dictionary definitions). The same link is present here, and i¢ simply caunoc be said that Mr. Epstein’s design, plan, or purposs ia wali (o Pulm Beach was to engage bn illicit sexual 4 conduct with minor; his design or plan or purpose vas simply Lo ret to his how, Any consruction of § 2423(6Y's “for the purpose of” language 1 include pups begun the dominant purpase of the (zavel would run fous of the rule of Lenity aud due process principles divcusacd carlicr, Any attempted prosecution of Mr. Epstein undar a mote expausive consiruction of the “for the puzpose of” Tanguage would sien violate the sspararion of powers douse. Congress, which seliciod the “fr the purpose of guage signaled uo clea iuteution to wake it “ederal crime whenose: an actor has engaged in flict sexu conduct folowing is crossing of state fines as ong as if migkt be sad Gal sexual uetvity at his destination was among the activities be pursued there. Congress well knows how lo writs a statu in this field which clmninaies » purpose roquitement. Se 13 U.S.C. § 2423(c)(“Any United States citizen or lien admilled for permanent residence who travels in foreign commerce, md engages in asy iis sexaal canduct with anothar person .”). § 24230) is not auch a statute. Federal cont decisions watering dovm the “for fhe prmpose of * requirement fly in the 305 0f the two Supreune Court decisions addressing that ieee, See Hansen » Jif 291 11S. 559 (1934), Mortensen v. United States, 322 U.S. 363 (1984). Suntan and Cuellar speak lourlly aud cleady againat prosecutors socing such elasticity in federn] critcinal tulutes, including those enacted o protect imparan federal interests. La wises involving the federalizasion of &civicy hat is within tho States historic police power, Cungreas mus! speaic with pacticuly clit, See, e.g, Will v. Michigaw Day's of Stic Police, 491 US. 58, 65 (1081). 12 P KIRKLAND & ELLIS LLP { Relevant Past Cases We hie noc been able (0 find a single feral proscoution base on facts fis hose bat have voluminous evirence of fedesal prosecutors routinely doolining fo bring charges in cates far I0cs egregious than this orc. To take just ane obvious sample, federal prosecators have self consciously refrained from volvement in the Fiecally dozens of sexucl cases of former priests, opting insieud (0 allow scasoned state prosecutors (hike the ones in this cass) fo puree tae accused former clergymen. That Is so despite (1) the Jago mmber of victims, (2) tho vast geugruphic diversity of the cases, and (3) the fuct tht scr of these cases invalve allognions tha the dsfendant forcibly molested, ubused, or taped literally dozens of children—inluding some us young, a five yuars okd ver a period of years, Nouethless, federsf proscntors Rave aot hesitaed 10 fe their state counterparts pursue hose cases free rom federal infertetsnce ‘oven though tho sentences aseted out vary greatly on aceoun of the fo thal “[eJriminal pecalies are specific b Incalites or jucisdictions™ The facts of ths case, which involve the sociation of cunsemaual tapless massages and some sexual contact, catiely ia the privacy of his home ud alist endrely hy women over the age of 8, pale in carparison fo the outright sexual shasc and degradation of preteen miners i any of the priest cases. Nor docs this case bea any of the hallmarks tha typify the cuses that fodera) prosectiors fave puso ander the federal talutes al suo hore. When asked, (he closest case suggested by the prosecuters was United Suies v. Boskm—and it hardy could diffe more from Mr. Epstoi’s case. In Zoek, the datondant was charged with conspiracy v distibu‘e cocaine and coca base lo minors, ia vialafion of 21 US.C. §§ 845, 8411), and 859(): being feion in ; possession of a firearm, in violation of 18 US.C. § 922(aK1); and scx taficking of children in { violion of 18 TS.C. §3 371 and 1591. Ciniied States v. finehm, Case No. 3:04CRO00S (D. ke Alosia 2004). Diochm's actians, unlike Mr. Epstein’s. also hud strong interstate nexus: Boehm puichased an distributed large quanites of erack cocaine end cocaine that traveled im inleratate: covumerve, aud he wed is how nc hotels (Which vere used by terete travelers) lo purchase drugs and distibute them to minors whilo ato arremgine fo these minors fo ave sex wilh him a0 ortezs. Intel, Bock mot only (1) purchased cocaine in large quantitios; (2) istebuied Ge drug £0 wins; (3) poseesazd iliogal ircanns (4) and avenged forthe minors 1 have sex with othr meaibers of the conspiracy in oxchange for digs; but (5) mittod to Kaowic the ages of the adividuals involved Here, by contrast. os previous stated, al of tho conduct look place in Me. Epsten's private hom in Palm Beach Chere was no for-profit entoepiise, 20 intersale oupaaeat; no use by Mr, Epstein of an instrumentality of interstate commorce; 20 violenoe; no force: 0 alcohol; na drugs; no gas; Aud no child pornography. Ts vaptnspiop soon rghenors 2004_02_27_Jokaley 2061 02 27 Teey domes 3 hem pris © In, Rom and 2s soles dist dogo pT 12 pesos beeen te 450 3 ad 21. Bohn io tad a prot en Her re tha cml show io was a ems fo tony Poult Bad ben Souviead of pin both tives year. gi) sad 8 fc sea oh sr. vy 7 of Sentencing szagp. 2). i 13 ; KIRKLAND & ELLIS LLP { To the extent there is a sinilar, bul mare cyrogions, local Florida case on the books, iia that of Burry Kubin, » former North Miumi cily atomzy acccsed of havin sei wilh underage ‘prostates and videntaping the sessions. Mr. Kutm ploaded guilty on May 18, 2007 in 2 Migmi- Dade County covrroom as art uf mm agreement with State prosecutors end he reseivetl five years probation and a withholding of adjudication with uo requirezomt to Tegler 35 3 1X ofterder—all without 1 shied of involvement hy federal prosecutors, who dechined tn proscento him, Indeed, given the wide use of the telephone in today’s Society, it gives u Tue pmaccuinT carte blanchc fo ura au local crime inlo a foal offense. Given the fellerul government's desir 10. abstain {fos proseculing that case, # is Hrd 1 undenend how the federal prosecutors responsible for this case think thas fhe So's westment of Mr. Epstein samen eaves futeral interests substantially unvindicstcd, There is simply na busis for the fidral Ironccutors’ Gisparatc restent of Mz. Tpsicin. Summary of the Evidence Fiaally, we wish 10 share new evidence -obiainel through discovery in oonncction with the civil lawsuits Sled in this maszor—vehich confirms hal further foderal involveanent in this martes vould be imuppropriate. “This testimony taken to date categorically confirms that (i) Mr. ‘Epsteu did mol tare micas; if) women under 18 uflen lied to Mr, Epstein bos thei ages: i) Mis. Epstein did nol (rave in foterstatc commerce for the purpose of engaging in illogal saxual activies (iv) Mr. Epstein did not uss the Litcaiet, telephone or any ather moan of afrstnte communication © coerce ur entice alleged viotis; (+) Mr. ipsicin did nat apply force or costcion to obtain sexta fevers; and (v1) all sexual activity that occurred vas unlamedd and g purely consensual. The women's own statements. made under ueth—demonsinue the shsoncs { of a legtiraate fadera) concer in his matter, and highlight the serious practical difficulties an - attempe! foderal prosecution would face. + Mx. Epstein did sul recruit or obtain those women in interstate commerce (necessary for a coaviceion wader § 1591). o I rc tat she id mot kaw Mi. Lpsicin snd bad absolulely no oontact with him be it through Interne, chat rooms, email, or phome—prior ta their amival at his home. See Tub 13 JN. (depusition), . 3. © I is sted that (ike many other women) sho fist wt Mr. Epeicin whon her fiend, ee invodnccd her to him, See Tab 14, JETS. Ap. 4-5. » bir. Epstcin was 191d the girls wero over 18, e Ly Ed admitted 1 Jying to Mr. Epstein shout her age. See Tab 13, (deposition), p. 37 (0. $a you told Jeff that you were 18 years old, comet? A. Ves). © IN a1] that he not only always made sure she hou a ke 1) with hes und lied to Mr. petoin by telling kim she was 15, but that she « 14 p KIRKLAND 8 ELLIS LLP \ also had conversations with other women in which those amen hoped that “loffey dide’t ind out [heir] age.” See Tah 6, Mille Tr, p. 45. o [IR so ste thal sc: “sould ell my gir ieads just | approached me. Make surc you tefl him you're 18. Well, thexe girls that brovugl, Tknow that they sere 15 01 19 or 20. An the rs thet | didn't Kor acd T doa know if they wero lying of not, I would say mike mire that sou tel iw you're 18. ez Tab 6, JTC p. 22. o IN <iq th Ed ber say that she was 19 if asked. See Tab 14, ET. 8.9.5. o IN: ti she “old him | was 19." See Tab 5, IE 1%. p. 16, «Ms. Epstein did not kaow hese women would be caused 1 ongags ia a sex uct (necessary for a conviction unde § 1591) end any sexual activity that rook place was unplanced o IER sted “soraetimes {Me. Byuicin] Hikes topless massages, but ou Sow have foo ue you drt wat 10 0. Fe Jt hes massages.” Sec Tob 6, NET. p. 7. o I cso sates “fslometimes [Mr. Epstein] just vinted his fest { ‘massaged, Sometimes he just winled 1 buck massage." See Tab G, J % Tr, p19, «Mr. Epstein did uot use tw erste fasiliy fo communicate an Tioga objective (o the alleged vies (aocessacy for u conviction under § 2422(5). = RN confirmed th Mr Bsc never sanaileds texted, or hlted Mma Internet cut raom with her. See. Tes 13, IRE epi, ».30. + Nit. Epstein di uot arget ainors (necessary for conviction under § 2422(k)) © IN stsod, “1 alwys made suee — Iba o ike ID, anyways, saying thal Twas 1. And (EEE (vo is IE Fiend who bravgh her 10 Mr. Fpsicin’s home) Just sad make sum you's 18 becuse fofticy dors wait ny wderage is” Soo Tab 6 BRA. Ps + Mr. Epstein did not use the phone or the Intenict tn induce proscribed sexual autivity (necoseary for a couviction under § 242201). o [IN stated that there vas never any discussion wyer the phono about her coming over fo Mr. Epsteia's frome to engesse in sexual retivity: “Tho only thing that ver occurred on any of thes phone cals with BEE I 0 another assistant] was, “Are you willing to come over, or, ! 15 . KIRKLAND & ELLIS LLP { “Would you like to come over and give a nussage.” See Tab 1A JE Te Ap ls o I confruncd that she vias informed that she was going % Mr. Tpalein's house to giv him 2 massage and nothing cles, and that ao ore “sail enydiing t [hr] on tac telephone [or over the Interict] shout sexual activily with Mr. Kpstein.” See Tob 13, ISSN (J cposition), p. 24- 25 o I <0 consumed that no une wssacistcd with Mr. Epetin ever ined to call her or contact ber through he Infonet to tey 1 persuade, inducs, ontico or cosrce hes to engage in any scual activity. See Tab 13, I cy ositio, p. 3. = Mz Cpstein did noc travel to Patra Beach for the purpose of engaging in aucun] uutvity with a ménor (ncccssees for a conviction under § 242305). © Mr. Epstein speat al lewst 100 days a year in Palm Beuch for fanly PUIPOses, buses purposes, end social puposes, and to maintsin a home. © While ia Palin Beach, Mr, Epstein routinely visils emily members and close friends. has seen Kis primary care physiciom for checlenps and [oscribed tess in the Pahn Feash aren, aud wail her deat in Apil of 200%, togularly saw iis mother wha was hospitalized and then ¢ camyalescd in south Florida. Te © From 2003 though 2005 there was no Tonth when Mr. Epstein did mot spend at least one weekend in Palm Esach, © The Palin Beach area is thc home baso for his ight uperations, for wairxenaace olbis aircraft end for periodic FAA inspections. ‘© Additionstly, Mr. Fpsicin’s pilots and enginezes ll resided in Florida + Mr. Bpatein's sanduot did not fvolve force, coercion or violence oad my sexual activity that took plaso was consensual. The witness fenscripts are replete with statements such as tho following: o IEEE sci tut she ws not pasuaded. induced, enficed or coemed by uayons to engage in any scxcal activi. See 1b 12, J Tr. @eposition), p. 31 o IE cec [Mr Eosein] never isd to fores me do arything” Sex Tah 14, 3 o Red, “1 suid, | told Jeffrey, 1 heard you like massages topless, “Aad be’ like, yeah, he said, bit you don't have ( tio anything that you I 16 KIRKLAND & ELLIS LLP don't feel comfortable with, And T suid okay, but | sillinely took i ofE" See Tb 6, IN. o IN 150 stored “[sfomne ils didn’t wast (0 go (opless and Jeffrey didn'Lmind.” See Tab 6) + Ms. Epstein did not engage ia uring. © Mir Epstein’s smessauge hooks show that several masseugcs would regularly all Mr. Epstein’s usistants, without any prompling by Mr, Epstis oc Lis assistants, asking to visit Mr. Epstein a his home. o I 1c “2 fot of girls beyged me fa bring them back {to Mr. Epstein’ house.” “There vies 06 alvuhol or drugs involved, 2 fact that ia mot in dispote. © Mr. Hpstein bs 00 rior eriminal history, a fact that is nat in dispute. + Thos women do not see themstves ag victims. oI dicatod wider oat thet tho KP] abamptod to persuade ber that she was in fiat 8 “victin” of feral orimes hou she herself repeatodly confirmed hat she 595 nok. Seo Tab 14 EN, p. 9-12 snd Tub 15, { [ER Jeiftey Epstein, 4 solf-made businesstaan wilh mo prior criminal history, should not bs prosecuted federully for conduct that amounts to, the solicitation of prostitution. A federal Iroscevlan based un thes facts would be an unprecedented exercis of federal purwer, & misses of federal rescurces, und a prosecution that sould carry with i tao appearance, if not the reality, of wnwerraned selectivity givon the icongiuity belween the facts 15 develop in his matter and tha factaal paradigms for all othor reported federal prosecutions under each of the three stantes being considered It would require the purmit of 8 novel legal theory never beers smctioned by fedecal luw—and that indeed is inconsistent with cach of the slalules prossentors hava ideutified. Acconingly, we respectully requsst that you direct the LS. Atlomey’s Office for the Souter District of Hlorida to discontinue its invokeoanont in this meter, und totum cosponsibility for this case to he State of Florida. { n SUMMARY OF MISCONDUCT ; KIRKLAND & ELLIS LLP SUMMARY QF MISCONDUCT ISSTKS IN THE MATTER OF JKEFREY E, EPSTEIN The manner in which eden prosceutars Lave pussued the aficgations against Mr. Fpsicin is Wghly irregular aud viarrans fll review by the Department. While we repeslediy have Tuised our concer xogavdig misconduct with the Ugited Slee Aftomey's Office in Misa (the "USAQ™), nut cnly a it has remained unwilling fo adda these ins, but Me; Epsloin's defense coussel hus been instructed Lo limit is contact to the very prosecitors who are the sybjoet of this miscondeet Souspleinl. Far your review, tas docament somarizes the USA's conde i 115 case Buckgroond 1. Ia Marsh 2005, the Palm Beach Police Department opened u criminal invesigation of Palm Beach resid, Jcfiey E. Spsien. Tho press Las wily repomcd that Ms. Epstein isa close friend of farnee Tresident Bill Clirton. 2 Ta July 2006, afer a iutensive probe, including interviews of dozens of wilussses, reluma of mmcrous document suhposnis, tanlipl rush pulls 2d the Sxecution of 4 avarch warmant ou bis resilenc, Mr. Epstein way indicted hy a #iorida Grand Tuy on ane. E ‘count of elany solicitation uf prostiusicn, 3 Ina publicly veleased leter, Pulm Hoach Polive Chief Miehaet Refer criticized the Gand Jury's decision and the Stale Attorney's handling of the cass. Shorty ater the Grand Jury's idiciment, he Chief took the unprosedeated step of releasing bis Depantnieat’s Fi saw police zens of the iuvestigation nchuding Detective Recarey's wicdied write a 15ports of witness statements and witness der cation infomation), that ware later Proven 10 be highly inaccurate transcriptions of witnesses” actuel stteznents. The. Chiol also publicly asked foderal authotiies to prosecute case. Jufiey Sloman Becomes Unsolved in Mr. Epytein’s Case at the Eaellet Stage 4. In carly November of 2006, Hpateir’s lawyers had thei initial contact with the newly assigned line federal prosecutor, A. Marie ViZafina. Alliovgh it is extremely wmasasl for a Fist Assistant United States Attomey lo participate i such a commumicaton, FAUSA Tefiey Sloman was preset on that very fre phose call. 5. On November 16, 2006, despite that tho fact thatthe investigation exchusivoly concerned illegal sexus! conde dur massage sessions, AUSA Villafena fesued irolovaut olcial document vaquosts seeking Me. Epatoin's 2004 ond 205 personal inoomoHax retu, and ler rubpocuaed bis medical records. See Tob 16, November 16, 2006 Lecter from M. Villafana, ‘Stowan Becames Personally Tuvoleed in a Dispute Over Another State Sex Case 6. Tn Mirch 2007, FAUSA Sloman reported © local police an atempred tespass by a £7- year-old mate. Mr. Sloman claimed that the individuel had aticuptd to nies Mr. Slomun's koe without invitation to wake contact wih i 16-year-old daughter, but he potied the Young man befor the porpetetor hud im oqo 0 eptes he house. The ; KIRKLAND & ELLIS LLP ami iedividual hud proviensly Sed the home of other neighbor aller snoring hat > house uninvited, when, looking for the bedroom of their 17-year-old danger, bu mistacaly entered the bedroom of their 14-year-old dsvghiar, toucked her on the Jog and startled her aweke. State of Florida v. Jonathan Jeffrey Zirulnthaff, Case Ko. FOT646 (une 28, 2007) 7. After u thorough reviews by the Miami Stato Aftomey’s Office, und sex-crines prosecutor Lau Adams, the juvestigatiun revealod that the defkudant und both the neighbor's 17- searcld daaghtor aod Mr. Sloman's danghiec were previously sequined. The defendant was chacged will simple frsgass in connection with his unamhorized cary Into tse wighbor’s house. 14. 5. FAUSA Sloman, however, donated that the youn: man he registered as u sex offender and objeciod to any sentence short of ucarerotion. he Assistant State Allomey in charge of the sex-critnes unit raported Mr. Slomun's oanduct during, the proceedings as “outrageons.” The defends attoimey described Mr. Sloman as being “oul of control. Shortly aficr, Mr. Sloman hogan publicly deriding the clected State Attorney, his office and Lhe state process for prascenting sex offeases, us “a joke. ‘Unauthorised Tucries in Disregard of the United States Atfornev's Manual are Used 9. In June 2007, AUSA Villafana subpoenaed the invostigaring ageut of Epstein’s atrornoy, Roy Black in clear offort 0 invade the defense cmp. The subpoena was specifically dialed to Ciscover the investigator's contacts, with sll prospective itarsses, Mr. Epson ‘ acd bis altomeys.! Nat suprisingly. Ma. Villafana issued this subpoena without fhe L requisite prior approval hy the DOT's Office of Enforcement Opeations. See Unita States Aflorueys’ Manual, § 913410. When canfrunted, she mislealingly responded thet sho had consulled with the Departaent of Justice and wos not required to obtain ORO approval setae her subpocun vias not dicected t “an office physically located within a. swomey’s office.” Sze Tal 18, December 13, 2007 Letter from M, Villaima at 4 ml. This auswer clearly sugeosts that Ms. Villafana had intentionally misied the Dspartmont officials about the items that her subpoena sought * | The abpoci swught, sromg ober things: “Al documents 3%) {aortic ted om mabe of 1s ehioaship betvcct [in investor dio Hs fn] ad Mi Sutbey Te, (chiding bt aol friar n+ reco of he Gatos hin seyioss were performed... (lop lg on tacos of dt of uimaicaions lr. Fes (o wit Ui pony mn Mr. Epsii's Bal, pots cinco eaetaoks 44 tor ve {hts in ba copy ox cleo on) for oy peiod when work was pickin un tui OF. Bi of he a Sommmaninan wis 2a0 wits Me. Spain (ox ih 3 0zd party oa Mi. Episi's bell). ee Tb 17 Tua 15, 203 Sebvsoena to Willis Riley ole Kiel, 15 7 eed i ac rast of fw lhe een nstmes which Villa laced eons miTpresetations fire a cour. On oly 31. 2007, io the rami ry qarion aii out of dis se, she fied hs "Deaton uf Homers Rese” stacking Sta deecio’s SFG 8 GOpRO:of sesh arom ie Epecia’s hoe. Sue 1 te Cimrt iy Subpoenas Duce Vor OLY-61 awd OLT-¢. No. ¥65) G7 103QWV) (S. Ph. Tuy 3, E007. Ac he five she fd Detects Kecarey's afd, She Kr coniaivet omens mil stepisiataivs, eluding oss iste of wimers sweets aud oie sviderce. Second, 9 (Comimont.n) ' 2 / i J pe 2M oon reaerber sesing hs heath and coc? 5 [HI vo bute ven cus nar rags whe the ocean wos and nen tho brtge wen: a wr SMP Okay. Soyo dolikol wort ci fe bide a [veo ventonceize edits inant we ad it fori dean. $3 oe Totes ime younre oJ 3 El ve 0 WF Okay. Ard then lw house, you sakl, yin: described it as pink? BE Rr ToT ———— - ” pink colar. LY 13 MP: Viens thera gxles or szmething in zat? vo J Veh seni ots ul, he Ech coor Rod 5k ai 35 NG 50 15 and Just like she knew that you 183 10 span k end + wasnt locked so wa 10 [st Goenen it nd then vies throm, Two Of ine Sips SND YOu [UST wal Lp 3% w hers Fd pe ti hh 1 r,s ear es Ee 2 ons some = ms on crn, i SATE of We GAB Ct cy were 46, wer Lie tin you men EA Pl ues us oer, | ums vis 6 omc house becuse 0 ran fat was pe whom suis care cot 2 08 wi Ts hid You ELS her br, ss = PET TASS Se — Pog? of 48 0533 ‘ tre. 2 wn had mat man sey? I ‘ 1 i ee Ine or nt thew we in ard he nau i) 2nd 13 3 courier, sere ae door hen vou alk 1906 e's 3 (pain) be) raiacaton ] o dt hs sind, lass Sng ve vio lochs oud 8: the Roc i Tw ou i a er ona 1s Gain cose er nd te srw Fi DOES. ! MP. Okay. just forthe tape purposcc, ic ay he yo described it. okay? 15 you J 1 wl and on tie eft hand 3427 : " 2 HE urbe Lar WP Covsevaumeroned ahi raw, wa hers? ol coma ISP: Arden ihn vo vialkad in, 0 hy ul Nar sk, whet 6 you cee? " | | Liz if 1 vias geting out al the doorway? sw Usb i 1 ht bil boar the night ! 2 we Cuan Ao ] BL —— | 2 we ow ! 2 [I ovo morte 1.0 dort hoon. couse Ras cpan, bat here cou hae sen Pane a of 43 05:34 { 1 door but was open =a di: mal y pay attention Buri hrc 1 was 3 cocrway 2 quing up 3 Me. Okay. Sa now we in tal kitchen esa. Robi? + Hl oom 5 MP The co of you? o Hl TMP hare id yuu park cor? a Jl re sven; ren 9 MP: 36 yous in the kilchen area. Wat happens next? 0 I Govern nig tere. We wee tating, just 3008 hw cout the house vias, [1 i i oh mp Qosk, Poe never nen in hau fice his. Ard thn the lady a0 tho 12 mn came in, fl. Im prot Sure. ko $2% positive. rd ha walked i, 5 was i; i ie 112 bghit arc party, ot ports but you hrc, ke aye ke Kind of rosy. “ SER hres pin SIRT ONE 8 ri acini 60 1 ERT ba lS 6 SR EE 1 ent Se Fk IRA SA ra wes MAA GERI BHT i” RARE BEBE Do you kro vk means BOW Umbe ta I SEER ead ha SE EXE Bese dn A EY ih dd SHEA FA REED Bf kwon thr 1's ike okey 2 el then, fll ny, | 2 emmeancer te lady's nace at shi. Ine said ‘ohio Pl aur fthe came) upstais. So sha's ie, cams on [JI ane vier we wakes 2» pst ard | rough... Page 1a of 43 h 05135 : © OMP. By yours? i 2 [I ves vot toi vo I cose she si sh wos gonna gt paid. <0 | | p nu ———————— ‘ i Lt i os ot as amps A A 5 smd gene an 06 wis walking psa here a a pckre of At nfo 6 a diferent couniny suid then Ten xs Thats ealy cool 2 tle lacy sad sn E aad : he vio us whinge nd th wa ik hos end then, as ee 2.2 2 litte {iraudibie) this big and it had a Gruch and a couch and it was ka another v ro owed hal vs. Aad st lh Orcs, oki oro 10 are hen my are rr as bicom ard eno tno ght again " and fers was 3 i Bac bg... vam umongous. And the tour. 1 | 2 A AT RP WY | { = Humengnus shower ike a Hon Beopic Giatd be is that saowsr, Amd han it 1 te was numcngous. And them vias fke 4 doot ere and ou open fi and hers i 15 wos Ike a little desk with paper 2nd pads ane stuff. And | dont kee {inaud bla) i 16 ke sifting en the conch dght nec. ike against my (hees's big lorey coun. And } 7 sims pink and grec. Hot pink and grzen. Ane tare ; ki MP: The room ar fhe sofa? 1c meson =» MP: Cray. 21 J Ad Whers a table win a phone an it. And wr, during when [was giving rim 3 22 assays, he made 3 phone call but | denl remember whaner he just s3ic. like 2 sd our a, hen 1 of Yeah, dnremanber Ard he mack Page 20 of 13 ! | h ose | i 1M Bggusc? 2 J ves ors oh nr cause sh sich ws Gorn Gat id, | 3 hough ant le gie-acs gona al paid in The, you kes ce privat, 4 ivan And cause wis [43 Fim and her and the Lhe” gid 4 he kichen. Ant 5 501d upline ar 45 | es waking UPSIaIS 1R0r0 140s 3 pictus of hi: Ths 5 arifirert sain and hon 1m Fie thats all cel ans ta dy ssf is) 4 and 2 she we ust walki'g LPS 2nd thers was ike a dvor anc than, & was Tog 1c 8 Ht sraulibie} this big and k had a cee Ane a 200 and it was ice ancthe: a “walking “owards thal wey 30d then walked hands, The hooy wa king foram 3 rd thet Yo my ch an this vias @ botoaun ard fn ws fusne Fioht agair " ard Ines was a big hell eo6m, 2 90... rronus. And the bidhraom 2 #20 lve & bation, hatarcom, Rag 56 © siting asa wilt a shower there, { » un aonrs shows. | ke 2 ln peadle eu. d se i ha: skewer. And toni 1 was HNGOUE. And 1228 vis li 2 dear 2a, An you opsred Lard there 15 as The 3 tle dost wil: apes 31 pads ard suff, Ann | 457 know {nntsies "w ice srg 07 the scucl ight re, lke agains: iy. here's big funy sour Ana 1 eas pins and green. Hoi pink dn Gees. And thers 18 NF Tha scon a to sofa? I Er 0 ur Olay 2 J Aver ata ot phone or. nc um, dug hon ws vg bi @ n massage, he made a phere coll but | den tromernzer what: er ha juss Said. ie = i 537d four wands an thon hug Jp. Yeah, | dent temerber. And ne mata Page 20 of 43 05137 : 1 shore call and hen Fe pu; the tobi back where twas finaudil). And then. 2 MPL BULGE l2y..50 You're upstairs 5rd you're siticd down and Ina ady's Ibare. a What is she dang? & WP: Neartho scfas? i 7 I ves Likes doron each sida and un swerds he doo, ers dour lr the : 8 Table. She toch thet out an ines ive 4 safe a7 then he shi pul 1 in he 1 9 midellz 105 1h 8 way, fe lorg ways Ard Then she put ike out th cholh cver it i i ut he aking anand fh: “cor, | ons a 10 604, he he vas : it feta b2ring samen, ys, sk hers he ton sas, Ar here ore ” pictures of He, 20kes gra on the wall an here ws ike hee vs he or big LN 13 msl 07 rized girls” the, bulls. And Han, towards the dour, Ihare wos lke & crinat hore, Bee 3 bull 1 fh, Eke final) and Lm, ere crwers in # i and sha oyune 16 ss drawer snd tere wis a winle bunch of lotons. ke 1 L] millions arc ni llores of kinds af loliors. Ane she pied out thee kinds of lotions. i Lia and put ham on hia en zmmnire kind of “hing wil 8 mirror. Ad she sot if there, i RE) Anil ther after. she ‘old me, sil hers fo” 3 minutes. Like, just sil Mere, And H 10 eventually he came nan he vias Ike hm Self snd “niko vi of And | a he's he, 11: b% right bark. you can 19ic off yaur dothes. Ard than ne let. Arg 2a the-¢'s a sedroom oul there and Iv ust wan: out there 21 Edn t knew but 2 hers s ike. pictures out there, | thick, | don't remerrber, ie look off bis clothes 22 Ne put a Towel over Nimsalt. Pui b gent now of hare vas a owe: th ng bas Faget 22 038 | 2 WP Dds vw nm ot ye? BR ———— a MP. Chay. Sih Canes back in. 5 WF: Vers you d-essud? 7 I env cv sadn, | mer akon An han Has, herd Teg he ' RL SN I CO TAT " AA 17 I vos. ve mascot vey ln on ie cv an a i boc and Kovands, key 19 MP Ne, sey it the wy You woukd if you were speaking 10 tne of your bes: fries ow Ell oe 2 III cou gg AA SE 05139 h 1 hairy Lats | pe going dawn to his butt i owe oar PI EO — 1 MF: 2d you soe the front 2 him? 8 fx Phe are serena and i wis vedy, vay Uisgustirg. Skay. That's al’ | hase 1a 5 P—— 2 [I Ne. 001 ical wom.. Su Hk sas rs ss hs s 3 { it bl ay ct is wen ins very ay. a Ee WHR TWP ves, Ho pers. Oh HWP Praca nt ig A VO SS = ay. Heli down. i ook of is To. 3 he od don, PI T= PIR TS ——— 05H0 : + IR ne cope on 2 MP Okay. Where did ae put the tow 2 = I Outontion Righ io, tbls ura 4 AP Olay. Soho id don, a4 tho TousH SI. Tahal happens nest? 5 I coc then bes tc, sth lotion, S| grabbed the ation. wiish, 1 had tok 5 eimast rakad, bt ves in Lic 3 theng 8a eal, iny ut wns sholng an he, tho ? fall se. mean ae snl was, you Knows fo os 4 ry hers and 8 was over hare red he wus he go the sons is 51 cock walk past Nm eo with my burl showing 10 £0 gel the lotons. $2 1 gul Ibe lnlions are =e 5 Ike, c's © Vie tis. fin nes ther 1 ook thet lotion ad 1 is it an your hands and " en mass cloceaise on my back cane | An kos how 10 60 12 43d an 1% he's fike telling me where he wou'd like the massage hers anc here, the rgnl to { = he It, 301 50s, up rere. S01 was 1 massaging Ei he tard and Cw stared Kaving 2 carvers, oh irs Foppered fill oe 1 ike 15 {inaudiple) ry ex baylnand {Iwudibic) what's yout heyfrend's nem. Zack. Ant Ww ne wis Kid of questioriing mi: and then ba said wit, he's Lke, soul you stop? aT ireedie ge Andi ust stopped ard Fm ike okay Anc be gol off the tahie He pr Put te omer his. Ho Bont dows anc gal he 10401 and tier he #1 the ® room: and you coud hewr kim, like, you snow, you Guid stvicusly teil waat he 2 ‘ora doin. Jus) bike. n MP: Idort ... 1won® logk 6t you bui Co what he was foing, what you lieasd. | know 2 it's kind of embamassing but... 21 IE Fe was makicg Kew ses noises. You know, ike... dont. They wore very Page 2400 43 0514 : rang nowsas. “hats a con say. > MP okay PRE ETT — PRT w—— RT 6 WP. Yoon Yau at makoga fool You im, i mR say ifs sex mises. lie 7 Je p— s Hl oor Aeuasue. SMM wortleokatyou, go ahead 10 I owas ie occotirn, ozo 1 Op okay bes making growing noes. 1 MI] on YR Top TE RRS, Wl {ow was. Hi wats making thse ies of rojeas 2nd foci 1:2 waked back Fo the 1 room, Look otis Soe! ag nd 4 5h atl rng an he he were 0 w Sam ind of massage Sux he 1 lle oh uso your HAUSE) a i rare 6 WP Yousers masiaging hs beck? 1 [I Youn. atm ne, bs Be, cont ous, tan tor 4 sce. Gai {i13ui5) 50 bach Suto 19 opm, HE Ried over ie he maid okay, ease 1 sng my boob. And one | was masseg rg is 200ks and he's he. he's EY 16, IK0 25 1 wes in I, a vias massaging, bs wi making fe same a 923 agen Ws, oh my (ios, fs 20 erbarassing 1 do fas. 113 was fe... Ze Iwetieck 2 [I He vss going ke contin, makes thosa no ses. And like & minutes se thal, Fogo dsl £3 03142 2 ' at hen ho tamet ack acount he ju stares oui Faso; an | Tink 2 he massage: was The a hat an hour bul suse dant know tic tmz 1k wars 3 a hal an hws 10 45 minutes wc ben 1505 done. And then he, | tik he os 4 bs 3 safc samewhers Because UAC ut hie didn Lava bis wade or scmething 5 RECS Hight whee 901 2UL he Oct, he 01 0.62 oul The toed om egair 3na 6 fe ut the owed on agin ard went oul of Vie rin ann He 5 10 an pit : our eloio: back on. 50 1 put Hothes ick or ane hi walks 1g Gul here 8 %€ ta 500d and He came back ke vitain a secords. Ard nes i ° ores your mores. Ard thr: ho Gave rw $306 fardred dolor b's and they © were like brand new because trey anly had ke cr esase i hem ans at's " When they're faked i aX. A 15 621 hank you far your Irma And tha hs 1 lL. Ard ha 33d yeu car oe your say 0 and was just walking ard got lost {ow rause ews 50 many aifnzant roams sed | oat la anc waked back Ww numeri anc Jes tho uel sn end cing he. guess was ial 5 he Lacy was 510 8% ther 320 looked ak io ard she eoked back al nc fady 3 an en shes ike, Ine forky's ke on, byo [Bouse i: was ime to go cause | “i uss because | was done And er, 136 wa tof i seme viay we Came in 18 ‘ord foc BE vc oh wy ost JERPOS how 01 you ee i. Lice hows much " 010 aed 10. We uch i hs pay yous And Fm lice $400. and | was Kind cf El vie 5300, JJ Gove the wi ss tice tie. She vis ooking ol me realy wei, 2 Ts other Gir hal 530 wil hor. S10 ke rely uit Iha.gh. And ther sh fist 2 Toad at 118 realy sr: ang she's ke Ting 10 gaze inka 77 sysbals, Ano 2 there went in the ca and hon we aol in the cor JS bee, tel me ses tcc Fuge 200l 43 ) 553 2 Marshals An oem, 0 7a 236k 1 Money ard | pt Li ms bck pockel a Aru i he was 0 Got 13 8G oho happiness 08 Ferhat 4 Rapper. And 51s NE, 01 0 4 ths muy Saturday. HES HK 3 ch ¢ A her, whim oe ein, the by 53 wing out and | Girasole ’ one of te cors rey but she was 1.5 oii Lo re anger set nd 8 COGNDG ths doer and than clased it, sw wo cll view rt Dic she sup aig about i tn [I So wns how eo imerostod on hat homered Be whos we eG ring. we're 1 Like inte: Ihe canes: zat bien sha vies Kird of ike giaging and laughing, 2 ie. 1 Ik, ct say, | nan, iT know i (oui a2 She { wu was act ag ouprise. 500 kno, a GiGging. Sawa ust of the ping and " gin aii JI 470 oe Ess or, 373 then wher. was ging 13 the guy tne massage. te goes. | know [snes soon woking wit me fer a “© ong tins and nen her | came back dota, Ics. sou ory pare mt we 90 so DWE: elke youtatir wo Jl dent kon 20 MPL Well oer voutet where dk you pu” 21 J Warsi or oT Mack oom of thos om Td anno Weranals. nd sha 2 Bought clack use 2 WP Gray. Oid vou scefillover that again? Fogo zr af £5 054 1 J ink so beau tis ben go rauned. 4% than thats eis | 2 GOIN rsuble With 4 igh. So ater tha, Vim pretly sure § sid. Most kel. 5 WP Det yous speac la her agin? 4 EE o.vecasse got ry cel phone taken andy. 5 MP Oxy. Sogou buvent sew [JI cr hs day you ent 1 Jil kame o Ell cores Tor Amyoserw? 2 J veer Tm nape sre 0 HR Howl ye ow Sho... 616 wii Heppner wih your du wo [I Oker Bucsusa my dud. cite tno ation of ry sister lot me hers shee n anne nese. Buby istos, on 2 Thursday, was coming hare. And wa, 12 Viecdnseday nigh, ny dag Sake ial he sar the dog borkdng an my dog is Tw my cid is ke Shek up cruse ne forgets he cog s name and the cog woukint bu Es quiet. Sc he's lie, I'm taking the dog our. And then ny cud lock ths dog. ES sid and the dog was wa in LAAs ry 24s use, ke oy da taught he El vas altaking the animale but my fd, 3 purson. a Bog, don awe Io: a fa: 1 SK Ronee 7 Ts Ber 15 Zack Bcausy Zack cot realy nud ver the while 10 situation. 20 WP Did sau tek Zack waal hid? 71 I voor ar ware unan ha puch wal and Fo fie ry os was 1g hers 2 Are Ba puncher he vial, ie my fac ws nghl fers an he punched fie val 5 ig hot to my face. Ane stared gat ad Une and crying an cating Pace 28al 21 05 : 1 I 09 you 0 this? Bian, ian kn Arc nels tke, okay, | 2 wor Ae again. Ane ice sh ust Kat of fe hong 2p and he sas fe hate a her, le her ar Inen | Aste you 150, An | was Eke aay ard vio broce cp ark: 4 then ink ir susie) on a cumputer and | tek he old [ht B hagoer ed ane she tome into an etracrgivary. lcs sky so at sohect 801 & woul lock ike, eu know, ike Ft 03d serson, Bhs Im 3 lu, Im a whare or i Soricling in she’s goin 6roUTG civ! soging ois stuf and thar 50 my 8 Patents care, Gauss hats shen 1 gol mad at es 6nd 10d her lo S09 tolking bu 3 ah OUI €13p Ung BbOLL RL. So ust g28 in 3 NPE lh er, fe 2 st fig! 0 at school, And § ot susaenced and so 9 $n bul sh orly sot suspended for “ ane day because | SIUC I. So 1g ia Taule une. Are ry 02d got 12 ely utd are be grounded ro for , Lease he found he S300 i Pry alt { 13 and then ry dad was ko, you're grounded. vue grinder forever ard he's sll a freaing out, Pow could yeu du Ors, ah, 93 Tis schol 53d you di. Arc 1 nm, cde a cohoo! Row, 16 ther | qo for fob, Eause worked af 15 HGH Hiab quit 501 510 | {naLdle) be nobody Lekved re so | vas just ” Tike betewa vinal vou war. Gauss | int rant 4 fel he piace ri vy w parcats 18 ME: ol Ishiak tal tne bos: ting that you ne Eaing s that ou being Aones:. 2 Oey? 2 Hl von 22 MP You aed Keowthal thay have a sielly gooc ideo what Hazpered kay? rage 200f 3 05148 ! 1 wp: wol thats z Hl isos SMP VE isis why WrSts nanpenng is hat | was made sw of his etuain 1 on ov sciso? SMP Imrotgonns say, chm? was mae wana of his shizfon ArG they 160k 21 5 ike you ers baer sczantage of. Nel thal you dic anythin wrung chy? Lven ‘ thaush you went here wlingly. Even hough you vert here wie, you ern 5 Slit tava advantage of. Okay? Because yau were pol iio & pasitar that you v fel ya had 10 €cios. Ones ya were ther, clare hen you wits Ising mo 10 abot haw Jeff okd you 0 aks of ue clothes? You Look your sinter #0 9.1 " said hg ws ally SleEn an 30u FANGA $0.1 1. Sou DURE 3a Lar ur, yur leg 3 when you said tia. ow dd sou aed when told you Uc fake vous cial ai? { 15 [EE don know ek know wha mise to 40 because | was the only fares is ow hare 276 hee ike 46 years a ard ni has like Sig muscles, buseuse, | dart FS Arcs, bot fm rely s.r 45 years 5d and big muscles, Eody bids: we Oka 7 I Sovius ul rtimidatod necause b's guy it of al, 2nd Fr 2 gi and | oes 12 tnt [0 wl the way downsiirs with the kedy anc what wes IRirg 0 E 00 fp ne ok the way VpRtars 50 | usd 20 AP Okay. Mow, thers ans way Fn a ile confused st accouss you said ha, or 7 Fising your vests Bay, ha: 16 whacked ofl Te. Yor said sefors hot he 2 whic of win, Whe did he ca hat? 7 J] between uns him massoge, ss when | ws vie ima 10s vs vogz Wof 41 : 5U7 - ' 0 he wars ike, Gus To “ar minute ar he ust eh th oom 2 MP Okay, satel once. Whe was Ibe ots ir? 5 [Uo owing the hing. ike when was massaging his hacks 4 MP. When you. okay, shen you vere massaging his hoats, was hs ack Tat an the 5 bie? Haw wes be posilionse” 5 I wer ne wos cr fist ong hon wher he stated Lo whack offs col he. is Back v we off t:2 aol, 1nd of ie loging. BMP Oday, whore were yeu standing? oJ vos sanding on vas von him vs sanding up C-ausitle) ard was 0 Whe he wan wars, key, bi was on tho Tobie Fn righ are and F's ‘eaing - nat way. 2 ow Oy (7 Ee fei couse ques, | om kaow. EuL. and i ws ke, ry tac, it > ow 50 Nard se wha wes going om bcs of Rie low 43 Gn 16 ost Kind af 15 hv as esd Oth way End as es, wes MP Chay, but pst eho youl sa hal, you maed yous ht, Did you sen 1“ ning oT? vs [ves sow nimracking ok: 2 MP Okay. Tats what nesd to know. Casmyou solo hi whusked of ice 2 21h Sou whakad olf i fol of youd 2 [vem 5 HA: And you saw his han doin of you sei VS C60. whit wk yr i? oagesion 45 05M i 7 EE Oo dw bis fun, facial expressions and tos 2 MP Okey. Wha sise oid jou see? 3 EE swim. 4 MP: fou Keen movin oui and so.. cts wos, be Lok hi nd and wal was 5 he dog vith his and? 5 IE cont know howto exclein i. He vss ost ack of. i MP Okay desrribe. dont 5 J Oxo. sony. te nus bis anton Fis pens and bs pa ug an oom ant he a El like: making facial noises, | mean facial axpracsions uid making rises 46 MP: So you sew tim doing hel, ve dd hatin fm of you? vw oe Z MP. Do pou know Whitt il means wher: samecns ejazuates? : “ WF. Ne, what iL meus is thi. once thay, while Iney're whacking off and I'm usiry 1 Jon wore, ay. Alves od lo a's masta, Okay? as HE ves 17 WP. Doak hal | means tc asus? A bay does i? ao I sau oou why ey dod | know why Lae do al don] sow anal it w coms 2 Me Chey 27 MP nomen Ti somes ok of hex Page 32of 243 05149 / : 1 MP Okay? mijustiacng sory... I gerna 2 you because | ir I T— + MP Okay. So fd 50s ous cd hots facet. Ards alled semen Sa 2% whi he was whasking olf, okay, did yuu see any (kid coms aur? oven ven os vo 1c ke stor ig bons gf . tr taste again 2 get tha SH Tome ce ‘ Wise re hers She be is got of av hen i wy tend of Wis wi, I —— TWP Okay. Gre ive coon ha emis Was hoi anything d stints about 7 Like 2 OT $o MP Very small traf re. Did you T0hGe..you sd 2 wa vary aon his hast ES [LET ——— 6 EE Uru ser nat sae MP bho here any wn? ® MP Yao peirkeg at fre chest area 20 [Hl veo. come machen MMP tke amoleora fick? 2 MP Chay. Sar you tell me wat he locks | ke? Page 330 13 05150 k 1 Hert he ele ra bel Ra, nets out, yo Ka, es ind of ke, 2 ra me, Ws Whe... | don Ln 3 MP He was ung gro 4 | | Yes Fe was going gray. And he had 5 MP Via color ai 11 he Seve before? lance, Dic? 5 El 7 WE Youwers descrioing Jeff Io ma, wih 16 feck ® anc ha wis Going fry one ake ol Un ive ve, ike pis sin ctor s Wie, wan Lam Hin, shen you base a sunbur, n ul Bi hun va have 19 22k of days and irs arg fn ter, 1 wes a Vie arericish fannish olor 4nd Ie hac [xc a fang ace and thai's ebaut 51 2 an remember And ie Ld a Whe Shit when he first cams in ( 12 Me Okay Se I om ety remate 15 MP. Did he have any king of ike wel on 5 bady that you rated? 1 ot member TMP Dhay Du you remenier wat zor eves ¢ hadi w Jl ver 19 MP. Did Fe nouns any facisl ah, the a inasiache? Or a postee o amyining? 20 [J mm Ne buts enti mee cally thek and they were Eush, tke 21 averpuhorn 22 A CHT sows aa BHA A RET Ree wn we NE wage 34 of 43 0551 k te dead ws 2 GRE Ri 2d patil EE BAER Isr bos 4 smardGa 5 | | RENTER HE trys drench SUING! SIE BAKED E, 6 HP Ovay Vorsak hat you sade bi 2 Hl uno. 3 MP Wist do you mean by thal? 3 J] even own on is siomach and Yvan ging rn msg, Bos |, You » mw when, ie, on, or, heh BoA? An tan lhe, 1435 SKU 971% butt “ Lah 5 fits bit above is buli. Aan |, 1wAs, § was bull naked and he was but 2 naked ane. { ww oom ta [J moat vcs. my bur cick were onthe 193.0 hs okt and ie reli of we 1 beck 06 GR SITE RI fr breil. i | 8 FH de CETL 16 WP Oday Now. did be ast yoito get en fap of Hm? wo ll ve 2 WP Ord you do that onyour cr? 20 J onesie hecouse at rst, uns giving him 2 massage ike vou know. @ standing wp. And fe, then he's like it woud be feed mors com orable if you got 2 ci back. Could you please do hat and than | dd thar. 5s, | id, um, ks, Pagadsot 42 05152 ~ 1 Iwas, at first 1G 1 want 1 £1.04 his hairy you know bull Sa it wae kind of 3 and as I'm going dows, kind of Ike 0opped vp again. Cause il wes gress. 3 || Besices | ke, you snow, well what do you mean by touching. Bre sexually i MP You een, Ha moboning, like smacking So He NO —— it} || Lik, miter you's: leaning on so eliung, tng your fares onl? He wes aning 15 [Obey Howes. 22 [ Vorwrtnore. Ls ie, was ie sling ight hee. 23 MP. Okay. Page 26 of 43 05153 4 EE Oras urd uhan ba backed ur. 2 MF: Which way. this way? i © WP Ok Pgoimto mylet uJ er sound your backs on tha le 5 HP Ow facing ves L] BP. My (gM. Okay. BT ———— 10 MP Obey, fear aver a be 11 [I Aor oiernore An vm shorn vou a wossags and sveptreg sa tha 2 TP — {93 MP Okey My either oud b..co 5 my ial hone araand your saoulders? 15 WE: Chay. Sof bobig yous ibe round by the wah I RR rT BP spend wo El ve 8 MP Okay. hjust gives me a Better piotre of yng 10 unserstand, that's why. z HE unbn 21 WP And appreciate you doing wa | dont mean tu Moke you lel ncomloiable » Do yeu Tee! uncomfalab #7 2s Hw Pags 37 of ¢3 h 03154 ’ 1 hibr Okay. Af: wveryd ng wars done, chay. did he wat you get Guessol? 2 I Mo Ce bas pote aescad vl be was ss hors getting 1a 5506 1 3 Guess that's what xs was ce ng. That's the only ning he cam: back in with. He 8 HE In ne mor, stad, do you thick. 390 | deal krow f twee is of eat, but 63 you ? [| Oh my gest. 9 [ obmyoosn tO ak about inal. Term was lots of places there oud hava 1 WME: When he walked vu... ‘he reasan why | ask is boca se be walked oul once ard 12 nen came back in, sight? EE 17 MP: Okay So ye gel dressed, yu go densi rs. Wher is that woman agar? 16 Il vovsians wine ol und te cha 15 we Cu El Er RRR Ona ES ENS SEARS loos [EOE HTN ce: 2 [I weiss ese SERIO Page oi 43 0155 LE I CSE 8 on 6 0 BDA ve 2 RS 535 SE SHS bis BUSES : BE ‘ Suns GEESE SMP Sowretchertbnge dd wk? o EE mow row har schol vert ic I, LP — 3 TSR ASA Fem ve EGR “ - 1 I a EID IBDN Et i FEAR 12 Bide ( AE Un EE SEE De ERR BP ChesahSEEEET Eo 7 HPS peg EY wv [le 1 NP: ky. What le ld ou a abort PEE TE p——— 2 | Tr ——————— A —— 2 wit of tie. bow do you soos JJ Cause srcuont up via comversaran. 1 PY sak vel | knows Haley bacause she's bern viarking for ave for alorg me. And Pane 2901 52 oss X v than te, Kind of you kind of yet the pictur, wirk ng fr 302 8rd net, “'m H siting there 34na him a back massoys. So kid of figured 7 aul 2 Me He nee soic hal, ho jose. 4 Hl ves. 5 WP sel that sha worked bor him. us J veonouccont on curvy beck bor, tat i, domes ruts wy sane if he f aun do not becanze why wo oI 26 9003 iinnizditie) for a most the sare. 5 ameustof moroy as me GME: Rich Wel why coun Le Day her th: cay io [El ortinon, besm ue tats a goon question, Cause she di usin as knew " LE con know out I prety Sune She S19 tel me, she did Ibi. Se was 1 Jt dowrstain ving a corversation. And | tins that hon wnt vi: fo he {ow SF A 0 KEE SE, EA WA Lt 1 isin and hen: we dowstars, she: wes Si Laon to th: ad 61 an she a8 oes, wher we wwe inthe Kier wating, He od ner: coma 0 the hoes 7° Sl, 510 said £7 1 Cet i 50 hil, ve AAD has anc she was | ko, and she's w Hoes su fu, yous Row, say 14S acs and then I oer gi srcablet El Locate wher ne Siw Ihe il cor in, he was 4, 150. 42 wes [4c wa ue so Jes ter ous ow [laser 21 MP. Okey. Soyaulefl and that wes the lost me you ses in 2 BE ves sre vars the st tee Land... HM Has tell everied io call you? Fuge dal 4 0587 © EE nes And 2 ME Oyen s plane nae? 3 [I Youn Artualy’ ft Cause whan as Ian, he ows uh li es sous 4 ps rember so J an +e in touch it yoL BacaLs she cosh have 5 your show nmsar. Sud di, jus ave kim my cull phere asbe | dient 5 abe him my ous mami, | Gave him my Sel pons ne: 7 MP nc howling ago ans his? 5 I On my sosh 1eoukntie ou ths dato but ies aout mosbe, on my gosh, a a inh ard a hall ago. © Gerd razky kndiv. MR IoFobany? nw Il 15 MP Bacause me's in Morch ight rn 1s I Gvorne very bagi g of Fobiuary oi te end of sansary | soudet ie] you TM MP Howeng afters you gstinte tet fig vin IER 15 [om ks week, cause. © WP Yowsolinto a igen IEE on the 5 ir I Gor. 0 vos i ws outa work ae. or before “6 MP Okay Axwho olso bosites Zack dic you lel whit n3ppsned? io Hl weren 2 Wh Bess lof couse 2 El zon: [ll 22 wp: Doyeu think [Il tas trovant coon iss shat you know 02 zs [J vo. tui che omed me te bing my sitar but that same day was gir 10 er Page 41.0f 63 05158 ES - boytrienc's house. 2 we ow 3 J Andoeven taas roa guys om, ihe wis 3 ik wae fhe érawers of itor 4 wars, i le Sho of ices 00 He ad 3a may ictuies of gl about s 16,17 aroun fas ge. 17 014 Ae hy sr ke oh ws 3 mst f of. all gels one took of jut pain maker] AR has wes i pions or 7 hey were jus’ Sanding dg. a MP: Okay. 5 J Locka at picicres 10 MP: Ohuy. Well | nave 10 03k you. Bo you know Ul ¢ differics bulwvsan..ard 1" Jones gsm woman, 20 Tm ask g you. Voute prey “are or your 398 12 Ozay? Du yeu know (he difference betwen right end wong? % * WP: D2 you know Ihe dificronue bolween the talk anc 2 °e? iv le © MP Cano lei mo wet Ro woud ba? 17 HR Gn notsagieg hen 16 ME Ute. Soif Hell oi you dre wing 8 Bian wer ght now ww [J cud you yore ying Dw ww 21 [Jl soonest ama kane 2 MP Nowgnil in evoryling jose a me Ue rth 2 Il ve Page 4201 a3 * 05159 | i h 1 ME Ase pou lng shout sugthing? i > El wo seer nmenee ! 4 MP: Okay. Swearngto Sod. thats good enaugh forme. i “ | | Iswpor ts Coe. 5 MP. Clay. is Inere enyhing ol8e you'd Ika tu lak 1o me aboul? i 3 J otecavse dus sho. oolting use soa hs she hing i TOWER STEERER La FE ERIS GE [I RT v9 See eee DR STREET ER EE Te TE np ckeRiGE EEE HNIATEANEE CEN Rie (9 We Atay en G0 sch ou. Su El seine EWP uses puting he hands 16 [ Pesices sat. no fncs 44 he tench ! NWR An pst 50 cube sums ys sn Wim hacking of 3nce. | MP Ohay. And 5 far us you think. i J 00 eT sy Re. some nora were Ling } . made when he was jiu ble). i EWP and diate | hark yeu sey euch, This wl candace he inter see The fire ] 2“ raw by my wath is dpurmximelly 305. : Page 42 of 42 05160 $orior Associates I Road pin { Page L ME STATE oF FLORIGA, | coomry OF Fo LCR.) mE: JERE? ETT 1 S— aici / i anon tarzan or #riday, March 21, 2008 1 12108 pm. = 12:18 pun 250 Ausizalion Avemas South i mire tao rd Reported 29: wwe EL Sonser, JA Notazy fubliz, Stats of Florida Consort Ausceiates Reporting and Transcription i West bala Boach Office Sone - $52. 662.0905 be rec md Trop "I. LE To { eage 2 1 neeRmRaNCES: 3 90 2ehalf of tre Defendant: SACK A. GOLORERGRR, £50. Fl AIZERIORY, SOLOEERGRR 4 HESS, PLA. 230 AUSTRALIAN WRN SOUTH ] ies 31400 ABST SALE SEAC, PLONE 301 6 562.439.8300 { 3 ALS PALSERT 1 SI00Y AE SCHEER, SO 3 FONLER WHITE, ATZ0RNEYS IT Li ° 1 12 12 4 is 17 I pt] 19 i 20 4 21 i 22 I 23 2 i 25 i osor & Associates . 0 FR Seria i np, 4 raze 3 1 Slatonens tern hofors dadith ©, Conser, | 2 Cours Reporter and Notary ublic ir and for the State of | 5 Thoreupon, 4 | having beer fis: duly sworn or ariimned, wer examin E 8 and stated as followas i 0 THR TRUSS: Yen, wetur. { . 15 37 wm. conosEeGTR: 4 1 2. Jemsifer, my cane is Jack Galdberger ani ~ 12 Dm hess with Lilly Sanches. And ve aze tw lawyers shat | E 13 sepresent Gesfrey Hpesein in som mstiers het ors secs 18 invesiigsled hove fa Pale Deash Sowniy. i 15 Barun asks you to cems in hess today, and 16 we really appreciate thst you cate in bers veltntarily. ww zoutve just seen sare ns loll ibe Lik, TB and really al that means in Uhl wre sieg tn take a E 19 sratrmont fom you. Aad it's obvious that va Just want 20 you co Tell us what you know. 21 a ohh, } ! 22 2. 2 don't wast you to tell us anything thas : 23 is incorrect or a tim da my wav. Ko sisply wart to i 24 wih here. Ard we're poing to do this very, very i 4 235 cuickly. Grayt i Fhosors Associates THR epi end Tarsipten. oe 8 kage 4 5 tolling about?” Ane we'll get it sirzight for you. 5 i s = I 10 oor. me your niesacoy, [IR i Ea | i 16 © How Long have you lived there at that " 1 EE : 24 Q. Your cw Loaffis? i Wosor & Associates \ raga 5 : 0. Fuh vor own traffic matzerar 3 9. Have you ever hed ta have au attorsey 1 represent you for snylnisgz 5 A Yo # 9. Gacd tor yeu. = Oxay Twn: to talk is you about = ma hat 8 yon kiow by the mame of Jeifrey spetein. 1 [2 A Oran 3 “e 9. Vou know Joffray, da vou mat? 55) A met bin ence - 1? « REFEREE IEE HAT rrr go) pardaneek 4 13 Seb RNLE ERE ae EE 16 epstein's vonse, had you ever hears of him befors! | Ba A vos, J pet toc ze ances vir, EEE = 10 PTE I— 20 Me. Ipsteia 2 a. she wold me tas he wev Raving girls such : 22 oI cc cvese eos dons kos wheic | 73 memes, wess reiting up girls To Bring them over and ive 20 him massages, and it was geiay to ba soricily mewseges, 25 uo phvelcal contact other then thal, snd that 1 would be v i . k Sages 1 { - J g getlirg peid -- I don't remember what she told me. I + = < Sura. 2 SR MrT IDES oie simran [I soso res | 10 £1 esses: ] = BC Kw So eaiRSRAEIAS TITERARY Sun 5 TE sesmrortmeess | i I | Boome - 8 Bi SERIE We See R EAL HES a RE | | oH £ ow | as 42 ve ews Rn IGERINIE: HEE peas | 2, HOCH SEER EEE sn ! an B woneuesss EF | 22 BE Onn wea OF EUS DRE Rees | CE i | to & Associates Lon 1 anyone haz werkes for Mr. mpatein befare geing reer i | & ene Ea Br SUBRITIREI Been KRG TRIY | 8B GREATER III pe ERG PLL Sy tras: ESA ESheseaeniy ® wa e 0 cng. solos veo thet yen cous 9 go over to mr. tpstein's house end do a st-alghe, E {10 iogitimate massage, correct? 1 A ves , % ©. And that there would bo ao phselGel ox iS 13 sexual contact in any cuy? 14 B. Rignt. 15 GC. kad I assume that waa impatiant Zo you to, 15 zo make save that Shere would ba no sewsal Geatcr? 1 EEE [p— 18 Crionss. She was oze of my best friecds a: the tire 23d 15 © trusted her word, and what ake told i swunicd 20 legizimate and legal, to ay undurs.anding. wasn’t : 21 dolog enyining sul of the way. So I believed it wasn't : 22 ton ba? to do tz sleas my bank account wp andl gel Lie! 23 sratghrenes out. i Ll 2 ess MEIEITEEREES por wens iT 3 ; Bes ATM Bi, SLIT Fore Associates | 1 ACRONIS mes cones LNAI SE | # 3 2 SEEseEsES onda LI RE SE SR ge peas Hs sevens £ ESE er ’ 5 HB omr sons uso iEEst Ee : 6 _ " 12 semua) aciivity or ses wich Mr. Spszein? H re I 18 ore thar nad drove me pver Therp -- . 137 2 Righ 39 ane driving me -- Lhey were followicg acd I ae 21 ®lsi, thet it waz up to me, 1 could say yes or ac. She ercor g Associates pi | drdece you to engage in any kind of sex? ° 4 i ° cory. xs far an vast [J == wo vou 14 oho sald Mo may ask you whoibur you Fast Eo do anything it 16 A. Totally within my rights to do watever © ] i 20 rt aseeullcc you that ve. Fpatedr. would 22 A. Yeah. 2acause ho told me in HT oom if I . Bosc & Associates ({ egy 13 2 wow f Wo Shey. met that conversation nly teok I lace after yu not to his house, right? & EY Yeah, right. " @. okay. as going wack to, to soe § sever communicater ta you, BIT you by s-well oc text oO messaging about ary onaasing th uy kied of sexsi 10 acuivityr 1 A Mo. Is was fst thet cay than I Lad | 18 x Qkay. I acu the answer to thiz Is {16 traveled smphers with Mr. Tpstein, did yout 19 A. ur: 20 a. You never left tie stare to mect with A ve. mstein, 16 ye {22 " Wa. Juerd other girls did. i {24 question I forgot to ask. ET vou never spoke «| tae Lr —— as AZbnsor & Associates YP Raporiing end Teaamiptine, Tor. { sage 11 § 1 3 » xs b [I 301 think what T'm hazing you toll mo ic v a Go Ne ove tell yu Shas you a3 So dress In t i0 A, No. I waz wearing deans and a tea shirt. i 11 a. Kinz of like today, wight? b po 12 a. Exactly. 1 jae 3. Yooh. Sha wes == well, choy told mo it was 16 ap to me. They said cho. it was fut joing To Be & | ; 13 they sald if se did £3K me, if vas entirey up 0 fx. i 12 oe Righz. 2 5 nd Ther was that u 6. Rigi. And yew ers Sold you coad sy we 22 te anything if anything was asked? su PRE 2 GA Unt was clowsly she stmvsshess that i ! Fhosors Associates 7 kl ptyettaiei,, ! rage 12 1 FR : 3 decision? : 1] a Frestly & 5 a. 211 right. Smat. t B 6 HQow you ager -- during Lhe one Lise Liab J yor wexa with Br. Bpsteis, you never toid him st any Line 12 Go You weren'l alrsli Lo say ue ta him about / 1 A Nothing. or sev. g 14 at 211? 1 an 5 We ; 1% HR. COLDRERCER: le.'s go ©f tha rucuid fi 25 ax mu cows i zn © Gu pene ay | 22 B36 Tverd SEITE i § 23 WG SEER ¥ 2 Sbriri iE CBE RUE IRA Pss mens 25 EEEALRTEEEr 1 BE Pe TORENT Bk keen i 015 [TY 3 c. Okay. Now while pou were with fpstein, did ] A. Yo, we did zou. 3 0. Rod yon di€n's touch bls penis, I sesuma? . 13 2 You didn't Lelp aim mesiecbati? \ as A Sorry. ke was too old. 14 a 1 near you. And L'x sorry to ask thess 16 A I's your job. 18 in any wey? 20 I'S rou didn't have any kind of cral sex with 24 in any way with his Finger nr aaymho rg? ; £3 25 A. He. H HOUSE_OVERSIGHT_0122688 E> & Associates i i Page 14 b A. He was 8 nive guy. T mean Tha ran going La 0 90, 1t was he wax nol threatsring me. He diZn't make 7 12 didn't want so do soncthine ace -- ~. 13 GC. Se cleasmly, you were mnt sreic shen you Fs FL Nothing 22 let's make sua sere Gizar om ihe sence, == you seat to 24 Al Corset. { Page 13 3 ok soon Mr. Epstein? | 2 pt Corract. H i 3 a kay. and you smrtanaly sever called tho i 4 police aa a rasult =. this? [ | | a © Aas yan neve: contacted Lhe State 5 Ep CEURTERIEITE ETI pow weer | 16 Esugel | 1 EE i 1 U2 GET Emm peed SSGCENIEIEY % EER le eRRIEEEE SRT TIRE ia Sid H Pas AF uy ves:des HEM onion vse my best Craend i 16 always talked to ker. She meked if T aver wentad Zo ga i 17 back again 41d T told Re: so. And she vas Just asking ms 19 chat ss a friend question, noc to ask we 17 © was 12 actaally uillieg to go back ovor thera. 21 Mr. Zpsteln? 22 LN Right. i 23 UY 1t waz just a feiend -- i 24 4. Right, ‘ust a friend scaveraation. 23 Qa Okay. Xow before you west uver there you a : i Foor & Associates y 777 Raton event. es. L sae 16 1 wees told shat you had to he 18 Ta gn over to 2 we. Spatsie's boss 3 A. teat H ! 2 Co okay, 5 £3 RS IIE pete SRE IR IT) § REEF IRC Ieey i Fe Ohba Swymanelel ERASIOME EPITONS & EBIARIEERoreIE s se wil IRs teas essay oni ssid w od SER TH EERIERISIY MBN REI TEE: 11 Akl RELERRE EL ERIE TE Or ni y 12 E CIURINH teene N | 12 ERNE STEN IRE REAL BRC : 14 chee 15 8 You ware, I guess, 13? 17 Ae I rhine 1d, ¥ pH QF RRL TOIT TARb se ir SE 16 seen BITTE HAN pears pork di DEE SOLEER) 2 REET: k 2 Re RE IERIE TRS rn aan tiag IGE i 22 moroswseele ddl BFE BAR: § 23 EI Sure wu ssecncl ang URIS EEN a Ee CLE H . eel ETS 7 “Repurtopood Tiomsipion oa. { Paue 17 i 1 LE eT ] LI 5 gok maid ior thi massage? 5 believe : gave [ills vonved for tueing we 10 Q. Giver your debl. situation, 1b was important py 12 because yo wanted to Zn thls od? E A las A. Coresat if k 4 Q Gotcha. Chay. a7 here. 24 Cc. 0 1 think what you'rs telling me is tiat i Bee, i } or _ Zorerr 8 Sasociates b 2 thar wars brovetr - 1 I 3 a. Tor hae mosi pare, yes. TI believe thas —- n SH CHAS TG EE SE i . TA Se IRE HS TET \ DBE CUS Ie i sl SG SE ST FP VE pemssumsanews olan 18 48 BEE ETE TI PEE LI Hi 55 | BPE LTE RCT we via, 69% 03S IK ATID | Ee | 17 -N Sarvact. | 20 Okay. Yaw've urdaratood all the questions 21 I have zsked you touay, righti H 2 a % Wh ] . 25 0. Okey. T really, coally sppoecicts yeu Il | Fhooors Associates t Page 19 A 1 comirg in Gees Lodav. Oa gob this done much quickez than 8 : 2 if we tad tn po to the courthewss to de ite i . « a bo. 8 Leath? : 1a 0 fo trent sha you 21d, you Sele the 3 Truth? i " 2 A 1930 ine ween 1s nso: Ko soblen. 18 MS. SANCHEZ: Thauk you. : 3 Uieseagon Ae. wastt vidas. oe 16 conndsd ar 12:15 plo. 70 a 22 2 24 1 2 m $ncorg Associates . I. i.e Sy p i “age 20 1 Tus erm oF moarnn, 2 CODATY OF PALM REACH. 3 1 2 3 RITRESS ay hand cad official seal this 2nd ray 16 of warsh, om ‘ 1 ¢ ” | rey | 1s Wotary Public - State of ilorima 16 17 14 1% 2 2 22 23 2 fi ian Foreor & Associates ~ PI Nosiy u Tcrin oo i Fave 21 1 CETRTIFLICAT® i] ha Stato Of Tlerids, ) " 5 I, Judith F, Cosser, Court Repurier and Votacy Public Tr and for the State of Korie a0 ame, 40 6 heresy certify that : wea authorized to and did stamograghizally sepust the sworn staeract of JANKLFSR 7 LAERE; that 2 roviow of tho LranocLipt Was mot sequesond; 45d thet La “orogeing pages, masbered from 1 # iy sienograskic cores of said svomn statemat. B T furmner cartify thst sal avers shaiment 10 was Lukom at ~ke Tims and place he winabowe set forih anc . hat the taking of asia avom statment was cmescd ae | 1 completad =z hereinabove sul ual. oo 12 I further serii’y that T am not an atcosney or Mill whe action, mor en § Sinuucally intersted in ine 14 action. ® dasa not apoly to any seprosusian of Lhd sam by ai 16 means sles tndn- che direct moncrol and/or direction af the cerzifying ruporses. EY SHTED thin 22nd day of Gave, F024, iB Florida 2rofessional Reporter 2. 22 h 23 21 oo & Associates VIR Bagortag wed Tumsmigt sa, ies. | ] i ; : | Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Bivd., Suite 500 - West Paim Beach, FL 33401 oor & Associates I Rei rcs. BN Ph. 551.662.0905 - Fax. 561562771 1655 Palm Beach Lakes Bivd., Suite 500 - West Pam Beach, FL 33401 cor & Associates i = Eage 24 3 il i 1 ji Ph. 561.682.0905 - Fax. 561.682.1771 ‘ 1655 Palm Beach Lakes Bivd., Sulte S00 - "West Palm Beach, FL 33401 3 Hmdnsor & Associates THIN Baperene ul Train, ire ; Page 25 | i | | it 5 1 i | ! | ‘ | 4 Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Bivd., Suite 500 - West Palin Beach, FL 33401 i 2007-01-25 I. TT i 1 1 I THE CIRCUIT COURT OF TUE FIETENTH WWOICTA\ CIRCUIT TA Son FON ay FRCL LOOM FL ORTBA 2 STATE OF FLORIDA 3 STE Or LORIN, PI serene costem, 6 Cefencant. 2 A — s 9 manscrrer or Tapco stereent or | ERO 0 { u | | w | i u | Ee 5 | i 1 | Vicki 5. Woodham, court Reporter | Th Notary Pubic, Slate af F oma | Contr &nguotiates i 19 5855 alin Seach Lukes souluyurd, suite 500 | Gest palm Geach, Florida. 33101 70 Phone = S61: B62.0005 u i 2 » 2 3] H Fae 1 “ | I 2007-04-75 [I ; [3 interview with Ms [|] Alse present 1s n served on ne for IN 1nd that's vhy we'rs % 3] MS. BELATONIA: Okay, great. 52 a [El vu want va stark off and UTE dead ns ver comet: [4 2007-01-25 [1x1 ; L — 3 + I 4 2. And home phone? s EEE tts the only one T can remember. ¥7 un Q. Okay. i » HY #5. AILAFUNIA: 20 Q. And what yezr did you gricuate? 2 0. har year xas tat that you dropped out, do you £ 7007-04-25 [= a 1 cham | 3 okay 5 A 2 had got my aco. H 8. when did you get thar? 5 A bout zhree mouths ago. 7 4. and are you going to college anywhere © currently? .- H A nr eight nok. L 10 a plans u A 1 save plans. Vows. son: a a here ars vou Usinking sbout Going? 1 A. I'm rot pesitive wnat I mane ra do. there's a 15 Get of things on my mind, but right now I'w focusing on 16 my son. Ihave a tho year old sa sight now I'm fust 17 warking 1 GENT RTCHARDS: He's 3 handful? 1 mE rTeess: vesh. © AGH KECERDS: T have one, 00 2 THE WTTHESS: Yeah. So in the future, Tm » defintely gaing to go to coleus. rn ywing » aFinitely going to go 20 schonl. fur 1 have, you know, a modeling career going on right raw that’s rage 4 a; hopefully, and tht would be great, bot I don't ¥ 8 THE WITNESS: System Cleaning. hs 9 BY NS. BIUAFCNIA: { 2007-01-75 [ET = Q. Okay. when diu you wet hia and who inzroduced 35 you ta delirey? 5 1 a, io apis J AG Be 3 @ Oo you knor her last name? 4 A. Ne. ne was a friend of one of my friends, so 51 readly didn’ know her. 7 § ov. sraroua: 8 7 ne vhen was est 5 A. I really conldn't te you. © don’t sven 9 remember, 17's been so Jong age. 10 ev ace racine: n ©. so IE introduced vou To ia. was it at & 12 party sevring on how did you guys acer? 13 A Wo. She came xo me and she said hey, would you Tike to wake 3 couple dallars and 4 said wee. 1 said 15 dong what? she said, well. I know this Jeffrey. he 16 Zives on Palm wearh f51ard and 1 bring girls there and he 47 Tikes massages and * was Tike okay. So ¥ asked her, 1 15 said nell, what about oy age? Ah SR BRALIILE 1 10 RE Re ne beh edit RE GUE (EE THEES 20 ERD SP YES mn hed n Okay. And about vhat Tiss period was ir 17at Fae © 2 A wal time peciod? a Q ves. as far as war yeas vas that that vou 25 wees in school? 1 A EBIERE 2 0. SE 3 evs maLarouza: . 1 were you a Froshmse or a soohomure, do vou id 5 revemher? ~ 13 A 7 couldn't tell you, : cowlda‘t tel) you. 7 erobably a soptemorc. 3 a. now you said val IEERGEE 0b hae 5 TEIEEEES oid she elaborate on whit types of 10 massages? 7 aE SEHR DE fe kek iil ds SERGE 12 RARE ade oR Re vant s a BSNS RS REE a a. and do you knon whether [vac given win 53 massages? 1 A vesh, she said she's done it before, ” a. and do you knox whether [I nad taken any 18 other girls over to see Julfrey? 1 A Ves, she prananly did, n 4 Did she tal) how mach vou sould make? Sage ¢ 2007-04-25 I x | . a A. ves. i ” GQ. what did she 611 your i 2a A. We go <here and we rake $200 in 30 ainutes. ! 2 Q. Now you suid that you asked her, you kom, whet i i do T need to be worried about my aga. IH FESRE H 1 mesa 1 » A Because T don’L want to he - you know, Tt mac } ~~ 3 Tike + we underage and I vas young and I was pretty 1 LS 4 Stupid and T ide’ want th get I didn’s bang to get ; Sin crudble, 96 Céeidaysaadal ie £5 GRAY 5 FE fy, i eo J 7 CHES ETSIECHR we Frm does ESRC ANE IGE! } 8 EEC i FRC — ! 0 0. row [EE did she - Weds Fal BETES To arz 1m school? what seting? 12 a RESBEENFHALS IRE ay girltriends 13 house. 1 con't know what girlfriend's house it was. i 18 verybosy was just hanging ovt. and she said -- she care } 15 up to me and she asied me. She said, do you waa tw make couple bucks and T said sore. | 7 Q. SER Res eA in bak SHREGL FORE H 1m SEGEERORA2 costeiadich shi TEL ZAI FU RELTH A | rage 8 } i i i ( un separ ET Sh ed FE Hoos pr oF wtghorevee GH SIGE INE BERLE Sor WKY 2 ws LhvenstesduUEeE SIL SGN 28 KoobE ARITA ROA si ve niod B BRESRS TRI. 23 obDiren En 5 EE: 9 . 1 erm. eLuaa: { 2 a so cock vou that. “ist time. but then 2 El after chat you conmunicated directly with Jeffrey’ + A h-hh. B Go Tel us about that First time that you mend to Gis house. ha -- how did vou cet there? ; a ane of BEER: Friends and shey dromped vs 3 off and then ue wert. You know, we got escorted up tn 9 the aussage room 2nd he told me everything. He suid, 0 ister, 1 Tike massages, And ve had the vhale sassage I table laid out, The lations and cverything. And sha was 2 in there for the first like five minutes. and the first 3 vine I gave Bin 4 ressage, she left the room and I gave 14 his a massage. And she old me, she says he 1ikes omen 15 topless massages. So I willingly the First time tok off 16 wy op when ¢ gave him a massage and nothing more than 17 thar. Aone BLD BIE RAS Seca a I 2007-04 25 ET 18 was out of there 1 9. Okay. Let we just ask vou 3 couple of 20 Folim-un weston. You said thet someone escorted you 21 up to the roma. Da you kono oh tac as? 2 a. one of —- what's her mane? acruaty, [J 23 [Ilivst sid, you know, 3t's up there and she just told 26 ne where 3 nas X 10 4 1 upstairs tagerher? 2 A uhhh 3 a. and IE <ioved in there for the First fen © wines? 5 a. uhehun 5 Q. was Joffrey already in the raon by the tine 7 Er B A. Yeah, he was fn Zhe roam a Okay. bus he thers hen you guys showed up in 10 the trom or did he cone n after you were airuady there? n a Sd ake REGRET EY) 9. And you said that you Took your Top off. Dic 31 anybody ask you to take it off, fike dio JN sav it's 14 tire for you To take it off? EH A. No, she wasn’t in the room. Page 10 1 | { i a ay che SS LT cy. a7 a. Belaidy SANT Sb HES UE HERR OUTER. ERS Teese adil TE SRE HEN re 1 HR Sah HE ETRE A 0 ERE EEE ote bu HIT FIO BGT n Hag et Garin Toe Fives wi 0 248 27 that you gave him a shoulder snd neck massage? » oo BEIBRARBE Sat = Was Yo Face dom she weet un thie Be oo 1 A ven i 2 «od vias hd ond rio sh esa SH | 3 you talk or | s Br. nd wat va yo Sah ot i ie . Be Ty. OE J GEST Voto a 7 we raked about haw my Tifesiyle wus, what he did for a 9 ©. ukay. what wes he wearing when you first came © in the row un A. I'm sorry. when he First -- when he Tirse cane g Tin the row, hemes fully clothed. And then he said, vou | 52 now, wait a onc. gusng wu go on the massage | BH teantinnte tel gun binds esa ! a ¢ 2007 ors J h REY masseuse would do. 1s a. 01 he undress nc put a tows) around hin? v Pa 1 a oy 1 he ER Ee ERNE TE OIEIGE pk 0 ERS 2 And ater the sassage was aver. you received 2 he sam 2 JA ———— 2 @ Tmaerry. Was that before you started the 25 massage or after the rassige he give you? » 1 A. The tirst time, he gave ne tae money right a 3 Q. okay. And ce's the person that paid you the © swur 5 A. Mo, it's always NEES 5 0. IE gave you the sony? y P—y 5 ov scour rrcnes: 3 @ wats J's last nave, do you know? 0 aT donte kno, u VR. CISOIERG: You can't Tork a1 papers. 1F you think you know. you Fan. IF you doen't know, -= vage 12 M | F——— 2 in the door, ne end [IN 24 «. she paid you befor: yuu went upstairs? 2 a. and how much was [I paid? 6 for your name and telephone number? - 2007-00-25 I . 12 Q. Did he write it down upstairs? fe had a pen i a handy, 1 Fope? i 2 A Uh-huh. i 15 BY MS. BILAFONTA: } 16 Q. on thar First massage, you said that you worked | 17 on hm topless. But when you first started, did you take i 18 = What were you wearing? i ED A SEES EE SC BET Sh A i 20 GREY A ackaERER od EBT SRM oe J 21 Ge iceoplensu ERE: SGOT ELEY fe i 22 {WOUREE DEAR and he's |ike yeah, T co. 1 prefer 45 thet. and who wouldn't, vou know? So I said okay and © } 2 rao it orf. 2s 4nd you Look OFF your bra 25 waTT? | | 1 i 2 © and you left your jeans on? i 4 Qo, sev ams BEITEERRL GHIHE | 5 COME ube movin Gack Te BE ! 6 Ac RE? v Qs SBE BER TH IE arma ssid El i a Pa rage 14 Li or anyhody who corked for his? 2 A. The next day, he had called me and he said i} would Tike to come out again and I'd like to see you $4 agatn. Tadd sure. Took a faxi there and 1 went 35 there agin. 16 a. The Flowing day? 1 A The next day. 8 0. okay. SRA SHERI SERENE 10 od FRISCH HED para 20 aes BEEREED beer I <0 a EEE Seid 5 Ee I Ee » = a. okay. and she sald Jeffrey says he wants to 7 sme you again? x a ves. % 15 1 GQ. and then you said you took a taxi? ’ a ves 3 9. 15 that hou you would normally cet to and fron 4 his house? 5 A uh-huh, if 1 dide’s have frfands because T © done drive, yeah. 7 ev seo samo: « 4. lor did you get hone the First time when Page 15 I 2onr-0s-7s [I or ) 5 EEEEook you over? Did she ger a Tai? 0 4. un, our friend come back and picked us up. u GQ. which Friend was thai? 1 A. Wis nme vas Brian. 1 don't know his last 13 name. T really didn't koov nC L dido't keoo her 16 friends or whatever, but 1 met 3a7Frey. And once | mer 45 Jeffrey, se was a very amcsose guy and T Just © don’t 16 know. I ended up giving hin wy musber so © coud - 1 17 did’ c went [Mor rian to drive oe amEore. T 15 would rather go <n in on my om. Bes. snares E) a. when you auld Lake the Tus to and from, 20 would he pay for thes? 2n A hob, 2 GQ. And he sould pay when you arrived? . 2 A vhs | ” 0. And then he would Just give you sxiea sony 16 1 shen vou left to pay for the Taxi? 2 Sno, mu JHE AEN eet FASE BNET CER 7 RUE mR EIR CR 4 a. Okay. So tron the mney thar he paid vou for 5 the message? « a. Ten hundred, yeah. Page 16 Ie 2007 04-25 I vir i f 7 @. where are you 15ving at The Lise? | fi A Las living + 9 located on EEE Sn T would reke, you knox, w straight [I coon to whee © “ved. n Qo you cemezher about bow muck That taxi fare 12 as each way? 3 A. teenty dollars. " @. and 5d you always use the som tx) service Bere i A. Wo, 1 used different tain all the Tire, so -- | wv Q. and you would just cal) and have then cote tu | 3 your house? | 1» Ac Uhhh. T used a whale bunch of di ffurent 20 taxis, whatever is available un Q. So you menrioned hat the socond massage, was i 2 il any different than the First one? { I 2 A ves. % 2 0 on was Tt ditferem? : 25 A. when I went there, | went there by aysclF. And | | bd | LZ vent up to the sassage rou and Jeffrey wis Just Tike ! 2 regutar like he was before on his stomach and he had @ 3 1owe) over and we started the massage and dadiid (Bb: 4 oF BWERIE a00 after the massage, hé@shaedNE | 3 se EIB DRIES ae ied : i 4 sour-oa-s [IE 6 EEE BH x safer sos une de Furie WEAEE ard this ws 7 Mike ar the end of the kassage, our 30-minuces massage, © usually it vas even shorter “han tut. And he 9 masturbates ut the end of the massage and i was “ike Tao 10 seconds and 1 was Just wopluss. n Q. and vhen ka turned over, SHEE 06: foes 12 EERE eu 3 AE TERERoIG Bier GY BIGRIRS 1M SE TREE SR 15 9. You didn't ke continue the massage shile he 6 GlsHe ha fi on nn 7 Aw 1 Q okay. I cut you off. You said he didn’t ven? El A HEISE Rep mend be 35 20 epwhehdddialn) # un Eid ho aver ask you a rub his chest or rub his % 22 nipoles during the massage? 2 Ao Actually, Tater on —- Because T an hin for 24 ong time. Later on, I asked him. you know. anc T asked 25 in I would give hin -- you know, L would rub his 1 1 chest ur whatever Whe ives Bip a0 ENE BE 7 EEE ae 3 a. So sventuslly you vould continue the massage rage 18 | { 2007-04 2 | 4 4 and he xould maskirbaco at Lh ene (ine? | © bv A BI EO3 7 a mame 1 ay ! n © Aways? every tine you sen here? | 2 PE | 1 ov ace Recs: | 1 owas ic atays [I chac paid your | 15 A soratines seffray would and sonecines [I | wuts. I pp— { 20 would go downstairs end 1d get paid. i > 2 Q. Su just sort of tell us, when a massage ended, H 2 ohich T assume was after tie clacolated? | 2 A TEVESTE SWiREH TE BREE SEED 2 fa— 1 | | release. SERENE TR HEA maia LR ! Fe 2007 04 25 EET s Ghar. ue when the massage was over hosever F< BG, GR JL gr Grn and tn He 3 owrsetf or did take you domataivs? . [EA ————— 7 great. And TofToey wewld get dressed and he'd cone down 8 with us sometines or, you know. iT wasn't -- we had fun, > WESISEIERE 1 a. okay. vow many mssaves do vou think thal you n ave Jeffrey? 12 A SEES ERG TREESEAGEE. 1 can't tel) 13 you. ER Eh kid Ga a 4nd how many tines -- woud you sen hin vaskly 15 or mare than once u work? A ven. 7 a. Hore chun once u week? " 1 AS RBA) CIC OF. L 3 19 0. kay, but either you would or either a girl 20 that you brought? n J — 2 0. oy » A ort after a while, 1 wasn'T 16 nore. T had 21 browghe gins, Suu 1 got paid $200 tu bring girls. 5 a Oy. 5 let's Talk ince abou she you were 2 rage 20 H v pertoming oh nasoiet DT ngs 2 would tamer? vou said that sometimes he would Just Tike 3 his feet massaged. Win due vouldstehind dnd i HE BREE © EER 5 ® Wi ever sing mestiilol. L] A BEE sasensrhiu ball BREE) 7 x frfferdne ot Yokoo biMinb sachs SRAETARE 17 ¢ DESPed® dibsbent meade Sha aNhiS Read pas ang 0 BETIED DRI AS wots SoralaiiedT 0 GESSAHGH TIAN. CAME AB Seve ane 63 BRE I sheneihd SESE HORE 1 wi BREE SETAE BAN Wis fa SG FaTE 13 shestines hi PERRI BEE ol we des AEE EAR AGE 15 fe eadeoviihEs DRCIETETE PEL eer pw 36 gsfeonplers Vnabeds¥ dil AEEIHOEE AH SRIINTE 300 { 7 TETRA GF yt be Erothing Ey ASA pubes wall SET RG 19 HEARERS Fa bis aioe REECE STIRS 20 GETRS §AUPYER «aE Femendes bib § REFN un WR 2 a ow. 3 A Totally tine with it u a. and hon did that rassage ga? = A acnually, JUBA SERN saa Kh Ra rage 21 i { e— . 1 SEHR we Winans base zhi HisEibE PT I ER Foto ie 3 AH Hn Se YO ON So hog? 5 5. Cr Be Sy le 5 0 i 5 EE BFL sho © SEAN Ser geeviand SUSIE THY 7 2. WVBR Erevers . Fig PR — w Pp n pts. i yi at 2 Q. vou seem Tike a nice youry Yady, attractive, 13 He never had any urges tw -- ° I 0 A 17 beauctful vomn aft the time. 0 vould be om, I — 0 ar WERE SEES A TT a sag 2 Ar LEE Ro of deen ShARaL RT EEL Bo See BE i A starred bringing other airls over? vage 2 Hi ovr-an-2s [J »n 1 A tcheh 2 GQ. low did that stare? 3 Ae He likes to see different faces 4 Q. So he asked you If you had Friends that jou 5 could bring aver or azher girls 6 A theo, 7 or linia URE TR TOGGERE V8 dosh is. 5 dere a A WDE ToSSHEAS BREE GD TE vie 10 SEE WOTIRST How wlembouss EUGENE POEL 26 1 RRC BAe tra pee mnie $8 URE Wi Lp did EGER AED ITAA Rove dus i 13 eciehRE SIGE RIE Thm grant SAT ¢ 11 CeNsmedi Eh SE EER Ne ys BE E V5 CUFIREG. A he igi uta, ARTES DEE Re 16 GEER RA BA Soret. S BalilH TE RR Ee 7 GHEE Yan BENET Gt rss ES i GEE FREIGEER Wd yourme wd BRL 19 anat wow @NEREE EHTEL Hi fine Hoosen n wd didn DYES BE SEO DIR Bioterd 2 fey messed GEOL IGIATSE Si hivane tan 2 ieee sad in ERSTE IED I Q. nd did any bf them xeTY you what happened 2 after thar 25 A. Always, aloays, | even asked them. rage 23 ¢ 2007-01 2: [NE vr 5 ! z okay. And with the other girls, was it the : 2 same as what you did or different? 3 A. veak, yeah. mean, nell, Tuas more willingly 4 to co mora, you know. Like = sate, §REETHEHENE 5 ovemtimon wuteiierobliol FIEIE CHEE BRASENG LER © bps sense bald RE Bie Hae be ES 7 SORES RR Le or wie wisp ney isha 8 RE ° @ were ther girls char you brought back milsinle 10 vines? n A A cowl, a coule, but be really Tiked 1 see py 2 different faces. ee 1 a vkay. a’ dust wondering are thore sone iris i 16 he really liked and others he didn't like or dic he have | 5 any preferences in terms af blondes, brunettes? | 1 A Ue Tiked girls like ne. i v 0 okay. hin and attractive? | 1 A. Touess. veah. very attractive wonen. and he 13 GEES RRL SECTIRG n 0. od you ever bring anybody he didn’t care for? 2 ho tvheuh. » a ar n A ean 2 Hon was she different thin the others? » Ae Whack, © sereved op : page 24 | { 2007-04-25 [ | 2 | | i a J ST | 2 Ae donsn’'L Tike black uoren, obviously. | 3 50 he Tet you knou? te 01d you that? | s a yeah, bus he was st rice and he still gave i 5 her har 200 sven Though he dida's sven have a massage by i 6 her. i ? GQ. How d5d he = he 5a’ you $200 for bringing J Beach tri? i 9 A uhh. i 10 and when he Told you that, I mean, that's what { AL he told you shat he mould pay you $200 For bringing the L 2 girls Bn A yeah. Ha said iF you bring se = 37 you bring 34 me girls, 171 definitely. you know, give you voney, 15 compensate you For your Time and willing to do that for 8 we, yeah. w Q aad you said at that point you sapped i 18 performing massages for hin? » AAU that point, © din’ L = iL auld be 20 sporadically like. usually, T had so any girifriends at 21 the tine that, you know, there vere sue new faces to be 2 sav. dad iT mo ome xas maitable, then ESOT go. ” oT or you i as Ex © 90 you knon some of the girls that you brought, wage 75 | 4 sor-cns [Ee 2s 1 some of the thelr names? > 4. 2 don't remember, ceally. They were Tike nat 3 even friends. THOCRIT TEE BFsbetaes sie Riin &F © GERBER TRIE DIRE De 3 © we have = 1 don't know. 5 have sume Bessages © T guess that some girls’ names that would call Jeffrey 7 nd duave a wessage. there's sume 3s mane thal we 8 refermced. we ware jus: wondering {€ you kre then? \ 10 WS. BILAFONTA: Jason, do you have that? Ep en— 2 o J oe RE a. 1 dons know [J vo vou know ber Tas: pra 5 MS. BFLAFONTA: We were hoping you did. 15 THe ress: mo, © dont. 17 wy Acer Kxcuaus: 18 o 1 A EEE. that sounds Tike u black girl's 21 @. well, you brought a black girl. what was her ra 5 JIT — 2 o EEE Page 26 N L Be So % y a uno is <her Tent ss abou IER { 5 a Aver or ta? x 2 A GEEISEER GIN WeesH EE IF EL wi SBOE 1K bn mani bil Bh ya Nl ik a PE 1s Doyo know where she live? nT just 1 owt her tm saton” ane 2 told her aber $e n Go 2 fr shou on Seb Ah Where 2z A. well, T said give me your namber. I said you Trae : 24 you're confortable with it, give me a call 25 0. NG Show ECL BRT 1 a SHER 5 PE k, 7 A ma . ot Ti . ho What she tooked 1ite? ” + (start side 8 of tape.) 5 wos. anarins: 15 a. we were talking about JE vou vere st vw ch ive 1 oI oo rage 28 2 PB crased ll 23 wv acer xcs % a ob yous | 2 PRT © » 1 A. 7 uant ta kon abut every one you browint ] . 4 something? { 5 A. No, she died. wnfortumaely, she go shol in 6 the head. You guys probably heard 1% on the news. the i 7 got shot in vhe hesd hy This guy. L con's nt to even Blk about Be because 10 cry. } 9 avs. omar: | 10 Q. Let's taik shout the otter JE. | 11 a, ¥ don't even know. 1 don't know. I con't H 12 non. Ther vers sose girls Tat us 1 would take one 13 time and then I would never talk to again, so I don't Pa 5 a. iow many girls do you think you brought ro 16 delfrer's bowser 7 A. That's a good question, 1 bring a Tor, Tike 18 maybe -- 1 don't know, maybe 30, maybe 30. TY sas all | 79 bows the moncy 0 na at that tine. i 20 Q. Mow any of the girds thu you brousht, did any pA i 2007-04-25 [I 1x: i 21 of then leave Sheir names and nuabers and then they vould | 27 eu apnoinmems directly from Jeffrey or did they alwys 2 oo through your 2 A ESHER BARBEIERG ovata. » a. 50 you dunt know? | | | | 29 i Tv sana Ris: H GQ. vou weren't getting paid, right? 3 A. 1 wld them, I said, Dun'i give him your H L 4 number. H 5 evs. sneronar © @ It you brought the same girl wore than once, i 7 would you get paid cach tine you brought the or just qev i 8 the initial $2007 1 9 A Fuery single tine © brought « girl, okay. or 1 10 referred a girl, 1 alaays gor $200, always. 1 Q hven 4F she cone a second tine? I A Yes. 1 ©. vou would get 5200 every tine she came? 1 a ves. 15 a. Good deal. okay. what soot [EE 1 a 7 a. soy J trot vou broueht ta sr. Costein's 18 house. rege 30 | ' ] ( % JR xi » a here id she go ta school? a Ashe didn't go to sehaol. 2 [Er—— £2] A. EEE been my -- she's wy friend in the 21 past. How did 1 meet JR @t « erty or ste vas xy 1 time and Bes HEACI EEL { 2 4: you asked her iF she'd be willing to go to ~ 3 Jeffrey's house? 4 PE 5 Q. And ohen -- do you remsmoer shen shat wuld 6 ave dent ? A Actually, 3 couple wicks, 3 counle weeks, T do 8 remonber her. A couple weeks after I set hin 9 Q. sn you brought her pretty sen after you met Wo erry? u a uhh, 2 eo. arae $150 IR 13 A. SeEneen gl 1 a. and what happened when you broughe [I 15 A Te sane hing ® a. okay. well, T know thal sometimes you suid 1 hac che girls would Tet you shat happesed? oe 31 ‘ 2007-00-25 I 18 A. she went in There. she had a massage = she 19 gave a massaou on his Back. she sent 3 couple tines. He 20 Iked her. She went a couple times. (HESSEN HE 21 fie rhe bein £95 SEILER THERE HEHIY 2 UE BERNIE ST AR Ramee 1 23 EECFBERMES and then she went, ¥ think, ike tro 24 times after that, And yeah, he masturbated, but no 25 auching, she didn't - there's no touching of him. Ho En £ 1 touching of her. HOB BAAR Ske hug Amy onl i nd: - 2 Abed ed ace HT BEA RIE TATIS DAES 3 ERGEBNISSE + CHBEEDRE Hetietene eid FEIENIT 5 GEBEIEMRTIES RY. his sohidE ae 6 abi dE 7 4. Wow sould —= Boo would you sake uppointents 3 for girls to go over there? 9 A 36 Call them nd they'd say hi. do you vant to 1 go Jeffrey's house? And thay'd say ves or 10 and we'd naa te 2 a. How Would you Know when Jeffrey was going to be Bin tam? t a Gaara vo cold GOT BS: 15 Q. Did she always call when thay were already in Page 32 Voyeur 5 A SERERIEATE RE Sherevhon var d neat; 19 peach ThEEADEE EXER! ron Ana They've 20 never calied re from anywhere else. It was always when I 21 was in Palm Geach. They'd say hi, we've down here. 17 22 you num <0 coms und sce Jeffrey, you're more than 2 welcom to 2 GQ so you muldn'e have Tike a specific Line vhen 25 you eld gn aver. Tike be here at 11 or be here at Du? % ” 1 A BTL, TC vel them, 17d say —- nell, 1 wenn, 2 1 have to sor around his schadule. tie’d have to sork 2 aroun: mine. hab GEER) 31 WSMHEDR DEY 4 ED RETA RR Re H GQ. 00 you -- 7 naw: that you said you tathed to 6 [cn the phone. wes there anybody else that you would 7 talk ra aa che phone? H A. IF sebfrey wasn't there Tike if 1d call hin to § see how he was doing or whatever, you know, he had -- his 10 chef would answer the phone, Kis maid vould answer the 1 phone. thers 12 tut vas I the only one you talked to abour 1B making appainzuents? 1 A. uh-huh, yeah. weT3, yeah, AT Jeffeey sasn't Page's) i 2007 04 25 vx: 15 auailable, they'd, you kaos, he said, the chef o yeu 16 know, whoever, said Tetfrey will get back tu you. veh, 17 ER wade the aspointments. 1 50 when you mere calling to talk 10 Jeffrey, 20 A Uh-huit, yeah. n 4nd how ofan vow you calk ta defTrer on the 22 yume 3 opposed to Talking to one of Fis assistants? 3 A Me and Jaffray hardly ever talked on the phone. 20 bers alas busy. 7t vas mostiy J ved 1K when IT uoutd ge there, you know. 50 it as Tike hey, do you « n 2 con, bye. fi 2. 00 you kia sonsone whe works for Jeffrey nan a | i 5 AZ think T mec her one tise. 6 Qaeda do you know about her? ; A she wae there. And the person 7 think § Imo positive, okay. Tw preriy sare she suid that 9 she’s [rom nen vork and she travels with Jeffrey, bu | 10 think T wol her om: Line, F that's the girl thet rings 1 the belt, you know, 6 fy heed. dia T think i that 12 ore person I met one tine. rage 34 i i ; : zou 2s I 2 whether ha vas gesting sareied. Did you ever know hie Lo 15 have a gisdiriend vr a steady? 17 never had a girlfriend snd he coesn't vant ta hava 3 16 girtfriend. 1 a. ware you ever asked to bring a gir] for sovsonc 20 else Vike to ¢ive a massaye to somebody else or to anyone 21 other than seffrey? | 2 a won Xgl aE eraser i 2 Shion band id ABE ITEERT i Es A sting ase Jl eR IESE TT i { | | 3 | 1 sur anyaody alse, either any friends chal were 2 intomor- " A No. Ses, my nother $5 3 masseuse and 1 have 4 experiance mazaging and he alias Hked ry rassages. So 5 he roo I about my massascs and she said, yesh, I want ] 6 a massage so 1d go over there. I think it was one or ! 7 tw tines and 1 gave her @ massage. 3 ©. Now when The 9irts were upstairs with Juffray | 9 in the bedroon, what would you do? 0 A. The chef woile make ae carved tomrtocs, put To som ced seat in itand I Just eat, wine and dice. it i 4 | { 2007-04-25 [I ~~ E 2 was wonderful, great. n a. and when you would Talk to the chef —- 1 A ves. i = would ansbady lsc from the house he there? 16 A. ves. I don't know their names. Ica’ 17 eemenber. there sere ike ai these foreign girls from 18 == Tike they're beatiful, kraut] fl wodels that are from 15 different -- they have sccents. and no, but it was real interesting because we'd talk. And, you know, I'd learn 21 & lot from then and they'd Teaen 2 Tor fron me just being 2 american. aud an, cucry tine § sens there it was a good 23 rime. did k Deus Tos Shedd 1 REG SREB TE 2 ERIN CREI CIR 5 Q. And hax Tang you sould the ache gic] be 3 1 upstairs normally? 2 A Teenty, 25, 20 to 50 minutes. 3 bv Acer rxcummos: . a 0 eack EE i: chore anything else S about her that you can remesher? vou ners friends with 6 her. she went three tines, you Think? id she en back 7 without going through you to set up any aspointments that 8 you know about? a A 1 done kom. Pago 36 1 brought? + know you hrouehi other II or wriple 2 evita. 4 last name, then I wouie provably remesber. bor 1 don't. 5 0. any IEEE oid you bring o IE? is EE veh, tha sounds faviliar. veah, NEE 17 EE ear. ww 0. IE » B— 2 A. she's alder than we 2s © Go you Know her From sees or 2 A No. ubers Hd 3 meet fer? © met ber nny 25 netahbortiond and 1 asked her 11 she mantel to 0 and A 56 1 veun JE she wes only there one time, though. s wats she sy? age ¢ 2007-06-25 I 0 \ u 0. what did she say cbout him? 1 A. she had fun n 0 she hud fun? © A uh. 1 GQ. What did she say happened up there? u AE Gh sop fe ELAR A rs dey 55 HE EE AR A Sv a ASE 3 ems. soeIn: 7 Q. vid you ever, cither when you gave him a 18 massage or any of the girls, did you ever use a bin buck 19 massager or ie was only manual massage? 20 A. No. it was only my hands. we never used n anylalng else. 2 Q. Nou shen yau were working for his, shen you 2 wore cotng over 10 Jeffrey's house to give massages, did , 20 you have 3 boyfriend a 1 4. Okay. tom Hd he feel about vou going ta 2 aeffrey's hause? 3 A. lie was a jealous little bay, but he didn’t 4 care. being hone the bacon. 5 a what's your boyfriends? © + I rue 38 ff 2007-00-25 HL v2 , ; 0. Hon 1 an vou a YoU mermonee hat you hai 8 a baby. 1s that the baby's father? 5 Ao, mo, thank cod. To a —— 3 | » a oe, I #04 vere you suit) going 3 zo aefrer's when vou wre pregnant? " AE wuld bring girs “here when £ ous pregnant. W or so did I a SEES hun 16 wher you were dotng ar sefTrey's hove? ” he RETREAT Mines is Jeffrey actually threo ve my baby shower and he got me 15 furniture and a mice rattle for my san and Just realy 0 wien tings, 1 Tove wom Francs. 2 Q. Was the shower at his house and did he attend? = Ao, mo, at ay house, at my hoose. nd ro, { 23 cftrey wasn’ there. tie Sust sent IE bring se L 21 gifts for the baby. = a an, okey. » © ov sem caches: 2 a. oid EEE ever go over there with you? ! Pa . owe sed away. 5 4 Yo, ne d's go. mn Fondo 7 207-1. > k 3) BY 45. BTLASOMIA; 7 @. 0d Jutfray ask you about bayfrieds? (sean, 5 was he curious about s A. Vesh, ue always Talked shat wverythisg, yooh 10 ow you have a boyfriend. yaah, ao, you know. se talked IU Hke friends. 1 don't knan. Just shout noc 1ife | 2 stories. You kaow, he prodably knows my whole Tife i 1 sary. | 30 av ace mavas: 1 6. wom do you sti] have contact with him or = 16 A who? { 17 Q. deffrey. i 1 A. Ko no one's allowing me. 19 OV ¥S. BTLAFONTA: : 2 0 DIO hl AES BEER i , a BETES Babar ba ! iS 2 = EC TRUERIED BI PUR a | 2 EHRGgess | 2 © GE EEA EERE | 2 Fo ODEN ddr anwiersn ee THE DRE BE 1 NRE BRI re rell an TARR IRIN Bl SE Se | a IRSA RHE a shes mdb ERE 0 | pane 40 { oom oi 0 SERIO cat 55 5 thes . © hat lt you sor ea Bb hoes 7 ore Ll wasnt Tike begging me or anything. He asked me a couple Twn ol the vine, he dust 12° 2 courte ives he aphed. 1 we can, you know, try to fulti 11 your dreams, Gif 1 45 wiih SA BAIBESTR 2 ds vm snd av lidnE TNE SE 16 iw apie 8 EEE. i Be ives 4 AS WRN SE 30 ast han O84 he SeTY sou vou win #0 be 3 ” tr Tmsmniiitig Wiens Wing ms 2 caterers sow seh uur? tre on Tig ot 9 yo 2 he afvsr she bug, we dies. veaily eve sak. 3 0 > was -- [was tozally -- A changed. You know, © was a bad 2 Tiztle gir? and I vorally changed. My whole life La { 2007-01-25 [I 3 crunged. A couple times after I had the baby, I brought 4 a couple girls Thera. Tr was 1% tho tire. snd then 5 ae and Jetfrey really stopped talking. We just stopped 6 talking. 1 Bad ey oun Hie mud he had his, 50 x don’ 7 eon. nr AceNT nics: 5 Did he ever make any arrangswents kiowing shat 10 you wanted to be a zodel ar were sodelimi? He has a Tot 11 of connections with shotograprars and sTuff. 1 wean, did 12 he ever sel up any photo shoats or onyihing Fike that? 1 A. Ko. ho, bscause he asked me FT ond Hie to Wau m0 sursue shat 7 vented wa do, hut Tike © said, for 15 he second tine K Qf man in aun here, noi 10 travel fn Nex vork 17 tor a shoot or anything? 7" 3 ARE ws barade d TE TEE SBE REE DE i 39 SEEEHES CARS ENF hin ar doominet 1HEEES 0 mows. nia: 2 4. ld you ever get money from Jeférey when you 20 cide’ esther give 3 massage or bring 3 gir] over? = a ves. p GQ. Okay. when did thar kaspen? 2 A. 1 had tw pay cent and Laas Tase on my rent. a Page 42 | | ‘ 2007 01 25 [NE rr : 1 This vas before the baby. Awd | asked him -- 1. asked An 7 for like 300. AEESEERAS T don't T coun’ } 3 tell you how T gar iri AERERAEE) DUBIE Teves 4 BEERASRE ét veke 5 Q. was he there when you bent to get the money? | B A to | ; ©. 1 you know was he in town or did you call hie? 3 AT dant even —SYSARAF CRADEKA EIS. DaEE 9 ENG he RENE TE SI SE n a ws Ut the only tine that he gave you voney 11 that wasn't connected either fn a massage or to bringing 2 agi 15 A. tie bought gifs for the bahy shover. J can’t 14 remcaber nov. Not oft thc top of my head, no. I naver 15 asked him for anything because © just fell == 1m not 16 Tike that, jou know. I'm not a user and I'am nor I { 17 don't Tike that. I've never asked hin for amey. so -- | 18 0. what boul presents. either birthday presents? i 19 Vou mentioned gifts for the hahy. Any other gifrs that 20 he gave you? 2a A. Yeah, he gave we a —- he hal went to 2earil amd 22 he case back with « hole bunch of bikinis and re told ne 23 to choose one, so 1 chose ane. 2 Any other gifts, Christmastine or birthdays or { 25 anything Tike chacy | | | | i Page 43 f | i | { 2007 cs 25 [vr » ! 1 A to. H 2 0. o10 he glve aay of your friends that you | 3 browchs ites? } Fl a vee, we air wo died, JJ ve eve ver i 5 2 bathing suit. too, fron Srazil. 5 ©. we have sone zeicphone mumbers that we wanted 7 ta ask you about. BB AGENT RGVRDS: 9 GQ. Just to see IF you recognize these or IF you | 10 ever sued any of these rumbers that might have been 01d | 11 taleshone numbers for you at some puinl. I don’t hem | 12 how many cell phones you may have had tirougs the years. i 13 sa if you recognize any of Ihse. u a. EEE vos ny rusber. ; 1 ov ks. sTLONIA: X 15 0. hae sas [© nusoer? EY a EEE | » a veah. H 1 A. what, my baby's father? EY a ven n A Oh. T never knew his. Always T just. you kaw, 2 called hin ad T never knew his nusser 23 ev eT amos: | p G10 was programed in your phone? i 2 A. Yeah. Se don't crow. T just know JE | sage 44 | ¢ 2uor-oe 2s J " 1 because thar was oy 01 nubs Tike a long Time ago. 2 vows. snavouma: 3 2. AU the time thas you were bringing girls mer 4 to the house, were you als working regular job? y A. Tworked at City pizza for a TiLile while, buc 6 no, kind of revired and splarged. I didn't have any 7 bills topay. I saved. I put money in the bank, so = « Gwe hae zatked about [EN before. vo 10 A IEE In 0. and oho 4s trac? 2 A. T brought her u couple times. bho is thact a GQ. T xean, did you go to school with her or how { 1 dS you know her? * is A. Oh. I had asked ons of wy friends, I said do 6 vou have any It vos 4 guy Friend. I said do yeu have 17 any girls that are willing tn give massages and I met up WR with her. 1 called her. 1 talked ta her an the phone. 13 I wet up with her and she said yeah, cool. 2 Qaeda i SORE SE R60 HbR 2 BREHSE 2 ne FEES hoe SertidiE, SBE REE 7 AEE EEC TET Ere eines bd 0. Ht BEIT INE Syer wink ishats HE 25 Sharsheied rage 45 { 200700 2; [> m ' A. et I know of. That I know of , yeah 2 Q. okay. wid you ever te} any of the girls that 3 they mould be goind Vb 0TH ide EE. El A. BE 1 told ther we were going to gn Jeffrey's 5 bouse and 4t's cofrg tn he 3 Topless massane pretty much. 6 anyihing you don't want to do, you don't have to do and 7 it’s $200, badda-bing, badda-boon. You make S200 1 30 § winoles, ° QE BOE Shh sted das To HERE dun then BFE SREY un ER CE TT TR Ld vo ORERREARL A. a Q. Moone called you and said, 1 think that you TM should call ~~ 2 Shik SEB ENE SHAUFE EAT 7 bet poiicud is ER 3 fe Np Me omits Es fe BE EGHE reo) wend WAGE BE ERIE GERFE. We 18 Gwe Just nave phone calls that seen to 0 consradict what you're teTing ust 2 A. oh, sv you think that people came tn me and 22 said that T'm To call the police on Jeffrey? 23 br Avent mauns; ” 4. us tore anyone That thought toat stat ar 25 Epstein was cing was inappropriute anc was concernad 3 Page 46 % [4 2007-01 0 a 1 abun thas 2 A BEGTEDEG 1 eoine ti SebiAL HR HTH 3 tee lereding ER OE SIEIRYERR SR fee «I a ox I. 5h GE SIR fh erg hee 5 BECE ABeIERets erconabic IGE PHT MET And as 6 far as 1 now, ve 311 had fun there. BERREULIN 7 Feeds iENENE REDON wo nechaddl BREN § bk 9 TMA, was there anyone that thought what be 10 as doing nay have been a THEtle BIE wrong? oT Aanting { IL to report to the police, but just sayinu, you know, x 2 thas Kind of nerd? n meme EE TEESE Ser 20 GRECO in tehoudhe Ast ERASE PIRAGTiRe 15 oped i KHEE Bd one Fhtisoant GopcraLI TREY 16 Aden Bok AE BIEN! ut other than that, wot 17 calling the cons. ev ws. sneoura: 1 0. wus anybody upset that he vas masturbating? | 20 know that you said you tald thew that they would possibly 21 do the massage topless. They might have cxpected that. 2 was sonchudy shocked —- a A. Yeah, of course. I mun, he aluays told then, 28 okay, rd I told then, too. {4S wR TH SET 23 RG Eh wd BEEBE 0 Sie ng SAE SSCS vage 47 id 2oor-00-2; [l= a 1 CaFeRdbie vi A couple airls when they did come out 2 of there, they're Iike oh, wy Gad, T wasn't expecting al? 3 of that, but he aleays asked them and 1 asked them. © GhEENIAL TRY GE Aa Br 5 esflHIE REAR BE IEA ves Hevbe they 5 mere scared. who knons. wr vesh, they came oe of there 7 Mika oh, ay God, that was kind of neird, you knox, yeah § ere any of then upset about it? # 9 a. 00 They Hike regret it or sumetsing? L 10 bY acenT rICwRDS: un 0. ust shaken up, you know, just kind of shocked? © A A counle of girls —- nell, ses, ne ners sa 13 young and weifrey didn’t kaon that. Like the whole thing 14 was shouken up when X brought them there. and see, I 13 dont know. eho Rf REHGCIES SETRIIND RebE por erat 16 EGET rhe Taverna dia ERE RIA IIE 0 20 URE ERR ee so wachdele ds BEE 18 RAEI pr oa Reh Sh En iy 1 RULER FUTERERE dt vemos niicl BRIGLLE 20 ABA LEI INE AOE Me hd ends 20 wud Ghd TRY NATE JR TH ERE SHOHE Nek te amie one doje 27 hinge But and aftervards like if he climued or 23 whatever. if Uhey ware Tike shocken up, T'n Tike it's 24 okay. you know. aad they were like oh, I wasn't Page 42 { 2007-01-25 J " ” 25 expecting hat, bur they tla Jeltey that, you nom, a 1 they were comfortable with 11. IF dyeing, vou knows 2 maybe they vere scared and they felt Tike obligated, Tike 3 trey didn't want to say. Cus thinking that they didn’t 4 want to say Tike no, you know, I don't vant to do that, 5 so who knows. [wasn't up there with them, zo 1 couldn't 6 es you 7 BY AGENT RICHADS: i 8 a. who were the Tadies who mentioned that to you Ea 8 who were kind uf shocked? © A usally, the girls that © vould bring like une 1 tire and 1 woulén’c even sea ther again © GQ. Gan you heTp me oul wish une mimes, tough? th) A. Hubuh. Kb. T can't remember ber mane. She's 14 on the top of my = oh, my God, £ don't remceber. I 25 can't remember. 16 mow. Elona: I” Q. wong wf theial 15 BEES BO BYE TR 1s AHEITEIEY Nobody was that upset that called you or 19 spoke to you that was pret with what hed hazpencd to the 20 point that they vanted to report 117 n a BEER Etre esos vol II SEE 22 bee SERIIADT EE Hnbeys 2 ev agen axauaos: pige 40 ( 2c0r-25 HE & 74 a. oo you know the somes of some of the girls thay 2 you browower TW RR AN A LY 7 A. there's about 30 of them, so you've gat to n said, key, mould you like to make some woney? were's my 2 number. Do you wart To make money? Here's my number, va ww ® a ve 235 thure that we haven't already seen snd you brow, JO of 20 chew and we're just trying to = » A. Tdon't knew if T brought 30 of ther. a 1 a. swproxinater HB veh. mo, X have ne clue, oo idea, 3 ews. maven 4 GQ. Did you stay in touch with any of the g1xls Is H that you brought? © Ac duh un ? 0 EE vy of the girls that we've 8 talked about? OTH aa shih iyo amR EIEN 4168 2 gin BE SETHE 40 i me vsaes pf EG 10 friakdunyitags i Sake DIV HOH EhERS Subic 0 ERE 2 A Bed Be on SELIG THE TRE Hae ES OF a Sad 14 A BRE 5 Qe DIECHD EERIE RS dash 350 DEM 16 Sabahod SEE RIDA IEEE 7 me JRE DREOR SEDI Mie vasinordrih Sha: 1 @ USERCEURE RTI $08 Bodh ERE 9 ie ES wo vage 51 ‘ 2007-42 5 2 a an gust so yon kro, [ED verre not talking 22 sbous necesearily crack coratne. Ne're mondering 11 2 anybody was taking any prescription mlivatton? 2 Fo dons ku 1 they mere txt prescription 35 madicavion, Thit's their problcn. dont kaon w f RA yo UNL give anybody eTen iy 2 prescription dupe? 3 ) We Hou te Vien 2 wns 36, 3 mb pu bt os $e a (start of Tape 2.) s WR. exsenser: okay, awa, back on the record: s And T axsuse you mean prescription modteation nor ; for prescription purposes? f TH WMS 2 thought you meant Tike for 9 pruscription, prescrived. Wo, T don't knay. 10 [REn——— evs. enarouas 1z Q. BUT vow weren't taking any anti-depressants ar [ER P— PM A Mou mo, T Just seaied pot. hut 1 mostly went 15 thera sober. I us confortable with Jettrey. 1cffruy 16 always wade eo fic] 30 comfortable. 1 shought T was a Vo big eint. 1s, I Q You £218 that you stapped. hy Ui you sop Pac 52 ‘ 2a 0s 2 SE 2 Q. what bappened? 3 momen amen = 1 GSE GE TE BS ERG AR meh RBE { 2 Gt Gol dua tered 8 ey pride and joy. I didn't care for anything else. I 14 Q. Having 3 haby 15 a 1ife changing experience, 3 tie Va ven tea tas, ars i 2007-04-25 I xr h w A. mesore. Tove ir. lave it. 10 0. yeah, he'll be tw in August. 20 A wine will he tao in June. 2 sy Es. aILarOnLA 2 Q 15 thal when you started morking with the 25 company you're working for now? El Ac well, Las - the whole time I as pregnant, I 25 ms taken care of by vy baby's father. then I mas a sz 2 worked at La Fitness, Rowo Pisca. It's been a year nov. 3 and what do you mean, is thar why I'm working? Ll a. Mo, £ just didn't know where you were working 5 1 thuught you said you hed gotten = job afterwards, After Bi the haby was bora? 7 A. Yeah, T worked at the Taundrosat for a couple 8 af days. 1 just |ike to -- 1 wanted to soak in my san That's #71 1 did and I was like a hermit crab in the 10 house, you xnow. And if anybody — T told == 1 told 1 HEB 1 said, vou knon. T have a baby now and you knas, 12 1'd rather stay at howe with my buby. My old man wus 23 tuking care of me. I d7dn'l cave about raney. 11 vuerything sas good, so a new Tifa. £5 BY AGHNT KiCHARN: page 54 { 3 o srmnai NE IIL on sa ons i IR sheet SERGE BRET ark dete 1s BE: Pee donnie dbo Bl ITS ATO TE i FEEBEIR DY » PO 2 oS STE we Rar A 2 in general? Did she ask you it you had any girls that Boome andt ane Desi ain the cunsom er? 75 i Saag hel hat. cov given ETS 4 WT 25 Haw did che ask for these appointments? L 53 1 A ENTEARhE hovel wn SE BEER SARS oR 2 DERE EFERCNERE Ger pes EERE HEN 3 oe SUEESEE, VENER hemtors delle 3 a ivan i SSRI 2 VE EE a th 5 ibbarieadie GEIGER se. 13 PENANG srpcaic © TIRE i es ELD TEA AE S 7 TUMBS ATION Saavik ATERE ' a oay. ues, sxuroua: 1 a. vou said that you sr J had devetoped a 11 friendly relationship. Lidl ever tell you shat types 12 of gies Suftruy wanted on % think you sad hac 1 sometimes she would soy he Iikes thin gird or Tw sorry, Whe Tikes This grr? age 35 { 2007-01-25 [J 5 A vean. 1 @ what exactly -- what suidance did she give you Tabet recruiting the girls? x A. she didn’ L give me guidance. JeFérey from the 19 qet-uo, I really Tike aomen Tike you. So shea T world go 20 searching to make money or whatever or fy girlfriends, T 21 know what an ateractive person Tasks ke and 1 would - 2 1 would bring them, you keow. I didn't bring any 23 overuesghi naople, I Just knew chat Jeffrey |iked, you 20 kaow. 5 a oid you ever atk co [lrassases when you { st 1 gave then, what you did, what you vould do? 2 Ae wleuh, SRR kro EbiahE EEE IG 3 QT have a picture of someone and £'a just 4 wendering §f you recognize this person? 5 A. No. was she 4 girl that was over thers? 5 ©. ust a face that we wanted to -- 7 A Okay. No. I dur’t know 5 ov AGENT scams: ] Q. When you would ask the Tacies 1F they'd Tike to 10 yo over Lo sce Jeffrey, hat vas the percentage? hou wan people wuld say Sure, that sounds good. Let's go 12 dott. and how many sould fut sav, ao, i'm not rage 56 16 that € had brought eke ETRE E PIYE HITSK wy, 1 would 1 sy. LRSEEENE Ie hecond TE BRE UI Frente andi at LSI Ee Raced § VHS ET 0d gs 13 walkman yRiiRE so iF 1 was off the wall, say I was, 23 0. that's what T wondered, whan yuu approached ( 2 Friends gp mueslibc SALT DRA Fane sy hibit va GoE 211 ep 3 BRAG Wihiiger AnilEeadERTE BERRI bora al TE ER 8 A. vou know, everybody 1s a different person Page 57 ( 2007-04-25 [I ox ™ 12 AY Mo. BILAKONIAD n @. 030 you ever say unything about you know, be 1 careful who vou talk to about this or 1 quess Tn 15 wondering why, you kow, were rumors guing around at 16 schol or hae did eurything esp under wraps? A. Everyboly knee, I don't know. sveryhody wide 18 jokes about it. rike it was not in school. It was mare 19 Tike in ay auighborhosd. They wuld call se: Hedi Fleish 20 and everybody fust made fokes aboot SE. T don't Kok. 2 It easn't -- but T didn't care 2 0 might = A. You know, 6 wasn't iF you didn't get out —- ft Mme cally a big thing to me at all 23 A. 7 guess Tw just wondering, you know, kind of / \ 5 1 the ay that Uris all came out was Finally a parent found 2 ous about ir 3 a yeah, T heard a Q ~- and went ballistic. Mow did you veep these 5 girls’ pares fron finding out? 5 AX don't knw, probably cabarrassing. ThE 7 Wi pedi side SEAR BRT FRE shes idate fol b s EEEE: 3 oid anybody hassle you at school? id anybody rage 58 2 Q. why did you drop oul of schooi? 19 that's why. And that's in the cleventh grade, that's EZ) my goals and that's what happened. Hut then I cnded up. { # » . Wlerders wil INLHIIRIG Che fv vob ent ERE re nt eh fh SE IER LY anaes A her E AER, BT BREE aml Bahl 3 a ChE 5 classmates or -- 7 207-00 [l= 9 A ET wasn'r <I sasa’t involved in the school so 30 wen xe was juse choc I oe in whe schoo. uw 0. way. so she nas really the only Tike 12 schostorelated - RE] A. Like person from sehoet, yeah. a okay. 1 A eu it was mostly out of school. So T wasn't 16 really hanging oul with the best crowd. and all the 7 people that I did hang out with, They were drupouis. So 18 it wasn’t anyrhing in stool. It was mostly Tike the 19 neighborhood people or my friend, one of my guy friends’ 20 uirIfriend or shavever, you know. ve vere 11 young and 2 stupid, bur Dems enanous n ©. anything else? bo vas have any westions for - 2 any of us. for me or - 2 2» EE = 1 BdmenE £8 ERtET Babu ak san saarik lin i i v GEESE Bk RAE STI a ERE REGAEOD BARNA AE aU Sid PRES WR STE 5 Q. Are you in ove with fim av 217 6 A. ny God, mo. I Tove hin as 2 frienc. T love Page FO | i | | 8 nor in Jove with him. 1 eld Jeffrey, do you vant to i a7 (end of the tape.) - 2 22 i - | | 5 | 1 CERTLITCATE 2 | ’ Page 61 1 x 6 County of Pals Beach. } , . > i 1% pated this 26th day of april, 2007. - 1 u 20 A [3 vicki 5. woodram © | . p— | Wile 3 page | ¢ | i i is { | at Frnt, ® wt | J. Coasor & Rssociatos Reporting & Transcription UEL Ln H-8 n EE Wa.. fot Ee Ss 173 hanyivme re 2 oh ime 0 oprah we sn. lars 23 techie uf te wnt Tmt, agree hen om cot sont Fa Balin emesis of [EY + fe Ere. yews mare EY } ean i Soko S : A SU Unden TO Uke 15 RENE at ae fis A ard ale, wl sk po ike what sn rms) LE ah er Io Twi se eer Se ES LAER S55 BIAS ERE a ny 0 EE PRE A lA kde an eb! well, ] Pee J Whe ties wat J. Consor & Rusociatss Reporting & Trauserizies 561.682.0005 SE — " [i Le FR Lon tvgr, ers AIT tater 4 Chav. Eowdees sh ky vais? Toe Ja braid end I hes saying 1s. Jo some se ssan. I” 1 TE Myer x roms se eel Wet +N Shot oto 5 tos lls be sel ted? PIR hospice i Hie Le ents tmsiios Bwntivitava Tn 3 tiv 10 rn meld FHA Be 20 lio bn img rahe Pond a 11 ak Sabet be hd be pe ir © thay. Did she lie year whee! oF hex an oh juan veh cha sf waves Ad) ons he 13% Wotehtanl dat oatramntithaeis aivah Aslan bone bu ovhoP 13 nina worn ston snd hr Ha 11 > © TR Su ve ek own pes 0 ou © Colonic athe sm ko Pang ty hae a3 vu ov lh So is Keo br anh bo rap FA ews © Toho es re oe ed amd 8 50k me oad wd 250 Go ey Sokbern homie FR ANON ST i rsh Rg 0, Ld sn, 13 UY DEC VE DAWSON em dn bk aed he so ale se den 4” sd hk 1112 et es gh rt As dro 30% rd Bea 2 on \ © lho abe v4 nga Bb honiof + rd min rom me lo 5 mone SAK ms I dh ening FoR © all ud he ke aw he vines SA ITs 2c i ld mate +0 Ta. Ata ei race ean in 1 € bade mame oi a) TIARA larry carl a «BY HER rites RR A A pir 5 alkeTyon dh ua pa Cote Bor Grab 0142 Bane 11 uk onto Lo ie vty ear nd 1 dra en FEI Ay 320 Veolavens wna whos LL mba ants ho gal wl AR 3 ag en vst 5 aude ge gon ats A vm [Ro 35 anit stedrenpain Ta oeoheiet or GW ee PE HN irq i Fe thowpe Pak Sule vy 1A aaiealicie a wena) wale tk © Sih be het hart suave cp nd od 1 asin £3 tev Eg vn on i TU Caen + bit BE 10 ee 1 an po I mdb akon Of Wis aber, 1. tk Sr sh re <tc benits g. Mas Te wut Sot om ou ET 5 Cho pte me Vin ly verbo (ws 7G Wall inmate skeet ad | Yemen § tn 8) J. Consgr & Associaton deporting s Transsripiicn 561.632,0505 0g : Tow a] wit} srs em, Webasto © 50 Ch Do tne to ok si 3 andi unin ERS every FR aT SE fe a we © 6 ky What det det wan ayo” men Eas TR en cata Sept, tn Seto ats PET Mh Baresi Ato Eudeaiaats LJ Fr —— [arte EE jem SR ow vars tne [5 3a BEE ve Le SL i A — en ete fon bb samt ae Ve TR Wer tntmen lh) NG. fre hat 63, } emer 3 Ub Dd ose A TT NTR J fh Aig §i2 cuntestme gm 53 Seti ments som idt Pig 53 A Cabin wets 1 PU RTPA A Fs 50% ve Pilar BR Aha ent SX Crab iene FIR Rr rill boob Si 7 wager £1 Sen Yom Bt nr EEE vf OTOP RRP PR is | + ee Lon fe Or hs be ha on, IR raha shot abet ( DG om en rw rg ET IVI Bir yng tei | io dba ey tb en Fn. 3 3 oon ss Or ee 1 Ke pt i dda a. © Wks unas bmn en rane peatipiuniioal nist agHen S E e | © i hat bien frp hm > a1 tv want vege | lo tha Wd FEAL 3 mr. i LT vn bow et Ts 51 ites yon hed . J Aa or DOR emmy entat (he: ERNE = ror er RRR riverboat ON HW 3 senators 17% oer america arnt TAMA | FT San betta ea REE 5b ou nw 2 aces vapsenrs bX ay vag dampens: 1+ ned Ee 3% eid cern dike 6 or and then sie asbist ov whan 13 Seoul 4 v wii 21 ven md dt om opp dat dn 4 3 FRET 31 edb oud my i i rong LG 23 lee doch vs hed po i ren an 2 ORBAN veers | ii icpemistng tna fo SIRT I reining 24 Dossier? 2 dity obi rE) Sh 8 PL A No TAS eh tugs tinier | 1 word wlan ben 130 Oh Fon gg ah oe et | J. Lenser § Assoc.ates Reporiing 4 Transerivt on ABI. BET.OD05 P——— oi12 ( [ER ey re — © OEIC RECAREY: Oka. Gogo kal 5 vie wet an 041 3 WRIT DSO 3 bunthow ety ods om baton 4G Maher nl doe? Salas gree ~~ Ya HE ati coretanadmmnng | Ko zoscatany son oor and a6 Weird wl eed Fd Bh tose ike thal 30 wre Bike 0 7am ld ey. H 7 eaphats © BY DAGCTIY HECARIY + 70 Cubs ree alias 1 Dds on err vgs PA de 2 Rn de 100 Nevemeris © Dern meer eri on voi DA no lated aot me wr ly [FER EE rant es Hen ve oof {15 A von earthen rt cr Ware oon i, 13013 Chom. ho src ow lt? + a hist fn ow ve | ie A Yer Thee was anober i via br f- tina's Irom Balk ag a vn fe ner i ese Ta t k = 3 5G theta REE —T— [ERE CEReA— TEE appucinhe wo i fo kre vot He 122M Instr woul prsble ano hermes hes abies Oats 127 A Unk Fis eames avr obs sted oo BIC 0 she caylee out To ea ni [Et wigs ase ar piy A 11 mmpthagbecouee set wows amor swncalart ve. © ebb 525 aan - 0 Lo ven leu eho id clic pir wax! £ 1 Merean the “item aes) 1 ( POR Lem H ” | \ PR a i £0 tthe baoco S © ; — E) © Rt tbe sii sm 5 120 integrins donk tite 8 i | 5 ato sv ides 01 or hs i chmadleons Leon om keen bin 12 £5 wihelairse wt res madbeased ibe 1: T3 feallr Tone 3h ho ems ee Oh dma 14 £3 tp nh i ow nS frtreysiw i Ar TI © ae xe LEA Ruliebopwbe gets how sles Py [23 nea wis sod e+ x ! Co Conwor § ASsco’ales Reporiing & Transcription bE1. 662.0205 : [EP PES——. gu | | J. LOnsur & sseotiales Reporting & I'ranscriplioa S61. E87, 0205 : ER ——— is | DRAFT m . = \ | vert k 3 MS KOBSON: — sop snphing ogous re a — 1 tradi nen PR 2 ox TADENTIED Mf Svbans EEE Se T—, 3 0 eshm weseam gmp a Ww $33 To bomor wk nig " gp mbm rts 3OR a A Lo Gon west to ol ayhony en. Pinan C8 Ck, 5 im Canon Seppe J areas sign. vcr moet 16 G lnten was an montis! ia AE i air 3h Copter 12 EAI, EQ Yan 15 an eet oe mist Id dei 33 dow, prog hen Brat avmem £5 i 0 Varese is LIE Rp —— 2 Thnk St et ok dm rong. HEB rps Ee | 133 Counter Ir bastog PRI TOM 10 gob habe Sons A eb De 25 boon abet privy 71 "8 Taha, Wess abs decom (218 el BRA park ho, Svs | 12 gies a dart ocho ot omen 157 wns. 53 fo 72 uti Rabie fete 53M pans £2 aie Ve wi ling we weve ern ERIE WOON 54 EA ul Tr 0 5 AT TASK: 28 Vented © 3 eo uoneat Er Wom ot en TE ST PIN GY ripe mre 4 5 BOT, Gosh £m to ant, * Ho Thanh 052 our onding oki se wn 1S ® EERICRATHRCS EEN 3 en ty mt T Sembdrame pS on ged 3 AT EDR ns i i 2 a Se 1 ee 1 INERT ADMAMESTANH Svea TT cane bho do Mey ort [ER ct pest un AE rar 1 mat 3 mgt 13 mm mean x a AKI Fri Ee ——— 5 AN I 81 SERS nsdn 13 ada 13 ns man RN ia PRN dies REE ene 21 rr rt SF 20 peeve he vee + vm at £2 Fi FS ratermaieriiie oti | SG on 25% mpm TE me Er am 7 wages 2 1a 3) \ 02506 cos Pam ; rs ! ; +0 Mtr east 3 6 he domme i 2 vig £16 oh WT MAL DRAKIR { 5 carat de ve 1 Ra © I erecnon con © tog om le 5 ven et ec ave actors 13 Oh} don shel OMI bar, Wi on Sr de be ae 1 EHD ibm rede TEE A RA Ely tts empties heat 1 ttm oe eo ome e Sk Kammer wt on. Sh srvisane 15 may Sete rn AY 1 Tero 32 ant nt id Wome HSER TO SEG vide shin Rd vimac die BT oe 13 eg i [Er — PR itd HANG risk bat io BOI JW. 22 oy bre secs, Et 33 a en ence 2 Sram LL ERs ER ro 33% Immonen bits 3 iii Smt re | 5 Stvctien, A nT 3 Ta wt To on os hove wot? Vee ag gow. Lurie | 1 co cmnendion into <tr vo J oro 51 Eb asin Br 1 Yer 1 Raa Bosh sn 3G te wet lhe mee pinbh Ex Wc wey Ee et wee 2 ar 5 FE Ra A r—— 1S tens dior [RI erie A DC RARY. Tio to th. 130 lo mer oe eon ais om Rh om Ro Erba Fi ontety ir dion LH Rg Hawtin ER enon HE en vamp atm RY yom Seine. Th on Come: pn ph 5 inna lie ron? Tome Fd 3 {Pages 6 To M0 02507 —_— DRAF D3 ev Delke ive techy HER ON— * HR ig tei) : I Aired ME Coram ye | ar Loma TAL SPEAR pe | 2 a che vids pie at? 32 me ER | [ER EES TN rr RO { noah 16 Nh Namo re | ES 15 Su con oon 1 Bi on UB | ER in pt 10 Sha Dotoutae oh tama? Rr gE — } [1 A J wa det IAigos 13 arian nah | ize And lew [lb bebo FE | | [Brrr rite © EPRRETRNE ey re 33 Vu ITB, om Bons nme | 52 TL 4m fet hs sarc i 73 Gomi mig on EE Te" hake 3 Robina) 2 mite . | mien 10 hems pet wn 2h lms I 3 Siena or sencher tlic, |B Di tek sn nb cheer tn] 3 © Mower wae an wrenches | { = TTA aL Okay. Were botgsr | a A Some ober, Moral fom bs some of ew \ Loe 7 ilo ti I : 3 hace tno. w= 0 NN Det | ) a PG de i Goa Tey BN ger on I std tt IE yer vetnetioe, Re ty vos I 1 a nt os I 52 rane tot mn nnd) | Fier 34 teatnpons Gratton eet [LE sh seman £13, 1 1G mon ERR a SE TN IID Fr ——— 15 I re 1 "SND ALS ARER 2 ime 2 12g ; Ea 2 Semetsrteaters soo EI | 2% OV (NIDRNTITED MALE Ssh Mo as 22 vans ef vis 30155 hk kd [Ep girs 23 fats nic on BG ie: 25 STONES bluse ab 75 A tin ses) Eel] In coche or i | 1 tages 10 ma 13) { 02508 5) rr ” g- NE. [oe BE ‘ pet 3m { 5 IY BTECTIVE RECARKY: i ER ema r— | 7 tetsu mon Few aR 5 nto BE Theo rn (io + ibn 3 ive LE per chats Bn 3 hdmi 0 pew Tamer gate a 15 Cosi ey lian 30 emir tan deere 21 octane beach 22 tray monet F-Sent oy 150 Stewie hoc Uneaten 125 dspch ncupe mks CnenIiey ese I [ae [RP — ee © Shame sho pe mie Oh. sy H 13 TR lh bu bo (i) wh {dD sek po se desoiate | 4 3 mans Vowarnboy Jl Oo mign A emi H i +" DNIBINTIIED MALE SPEAKER. Gach) | ! 13 ikon hee endl H i" i 1” H 1" i i H 1” i bY iu b 3 i Jet 5 (ogea 1¢ to 16) \ 02509 oan 1 | DRAFT | | ] he. 02420 — lt SR ee 0 zy : Fo arise cay 5 Brum , Ton? lke ad sos A © TQ edyeune stan WE Til) 3 nape skands wh me ke dn £ ihm Prise: 5 ee HOR wt A lt and | sh | ara 7 Wha Bon of os Pin 1 das tin 7 sadism kag epee 1% srr! oo E— 5 a Anben i dws l 5 on 1 101 [neo om Ei me 20 taken wh. nis i th dP | aoa Ley SREB ASR Rm i ERR a EN Soh ya shad cs Gn. $5! | A Men SHER SORE Pomrehn dhs I i 5A veh Ly bdo rn a on et ob { FE re — 16 tnd lg a ap ier ve | Boa 38 1 iy wad cote ck 1 TQ fia. Covers heed brid D0 0) Ok, Fel rans dass 22 oad ncn oI a Be SAME 25 on enorme an 1 5% Ebina nhs rls Gu 22 "A Tasmmksgant rose don | 2327 Coy E00 cola ov he «Wan } © neigh ke A WAL “vin | 2 Vs Shale ron | li eo hen gre i 3 son ep es he 5 sl ke kod sched hon wh 4 and 0 ¢ © Rm £3 Fis imi pe i 30 eter nm ERE ara FE — FR CTE “Adu 108) © hm Tim be shaun ta? TD Be dnb or 8A Eamptoby sh’ do £5.30 os 3A Nelms BE Gi Ee ER Be 3 nt {TERR ETO Bids | 11 Welham tats fa LE SEE hat ad dna oh {15 i 1 SF monet 1 dn wenn Han Ae a 15 ©) Ch Dues olson seem | 13 es Li reine 1 saris abo 15D Yassin 7 7A No edn debi now 17 A ion 50 Ole EEA wa TED Oh Dibra iw owt 2a cnatof maa sb db drt 12 A Heo hebloob leang ceri 20 A Weld de osm won Ske 20 wanker cu en Tans ih a hk ot ly ! 21 Convene nc sade me hems on aE 122 Bn, Tem reed sons Sr oR so i 52 thera bk crews and cor Pu ahr onl {21 (tat wih mx odes Sh, of] i 23 tics dF le 23 doit udu i EG Ga ve stale narrate 9a Gh Neu nos ei rms a om 2 Pages 7 to 5 / | A | N on | | | - I3 a wet ae toms sve sere on Lack BN Ne Lio 5 wan ty at id Bh 3 wel nd Bra 23 wn pit rms, lu dhe i sg un lk te EEN Som NW theca lead PEs bk you knoe, Be bic vo cokes off od elf lke F 35 a Chis il JED hee wich in ea wal fcr . 1a ved A wa { : Da Om weenimane 5G a aks dps Boehm 30 Ate oo 5 It wow wt enh Tb Ohm. Conde mt Vo Foci | 3 SEAS CAREY. bavi © too a is ak he? 5 mains 5 id re gk vend 3 1D ass: 13 rene ip ian 5 Q Ra Cars divs wha bbl bake 30 TAULCLLYE AAR, ha 3856 51 1a 27 va , 50 Var? ten shew bmrontis chet? ; Poke 5 Erp. Goa 83 No vite aumats? «ira JER TS — HR a | 10 Thm wh dur onl eel a ERTS Main GQ Oka. Okay. dene heme sore you endersiond | Aon LR CYT FERRE drift hte EAA 58 uhm mnie” EE 2G Re fh omambrschs ror i lak? PER So edt dt éprivlore EHP rm 02423 { | NORE: IFFTIEY FRATETN | DRAFT 4 02578 HOUSE_OVERSIGHT_0123684 = PE EY TEC oft TO ; Po Ee — rT i 0 EE™ ee enn Hl sinimmnmi REIL Bi Lo ha 8 eed acon 0 a en Ry rae 5 man seb anaes 1A we ve PY ona BE thy. en Sagem bean un [ET PTE BR cone Bh rite to Bd OR i 2B yasmin FE —— 11 vl hs smite ve eo © JR fhe ir ilchettint ot U0 Sati ¢ FR bof obit 11 in LB Tin 38 Manes SE CI RE | iit Mr oi 3 2b wd vn B&B morsetente obi I a, 1 ane Horn waren 3 Bb Wb ebemsimtnen 0 8 Seite | © ER en { fg 30 See Ebi wa er #1 me FE 5 ero ER PE tyr SOR 32 A Sembee GD es EET re — I EO TIE CTR dior arp Brite mire ann 5 em ee Z (Pages 2 to 5 02528 — ! \\ = 1 Ha wi a jo shat 50 Vemavin & A vem i © irinioatns DAT Ae Tale 3 5 Yan Allene | fri a PEIN i i i ie EE en Sorta ir vor pn | i 3 snd Zin ey hc pT HME] ©) Ducmpawi ete mesgis bcs, i 16 Clin Whence mad? REx 0 da hee mam be ec mg Buse on moe] 2 He DE She bo ou the bed, mana Sed 17% A Hn Nowe fis ons a sa Bis Fla te i 3 wen and srt sng, Won hn met; 23 wacom i 3 theres § La 2 | \ \ 07530 DR \\ - B PEA Rolkigolse. Afi | was Anish Acaally SO Dh The sues dw,» 0 oko 00 bark der | Fis 138 Snmtresspn Gon tty wos AL I 3 Gn tw dyes evo Did 0h tongs [Hh Goa | 12 thor. Ohm Sotainen dove? 1 Na nt ey ce | 1s a led me 15 ah gor ats ot 150 oy pith rk pone em cr kon: 13 11 neh eb fr rss ] Te Sm ; ry rca Cs 113A hy Ae Age i 33 ea Fa | 122 0 Dial kin your Shen mast (220 Ok Didyweice go Ga massa wilh an i 23 A Nekhenron) IE3 reer sqm? H SG kn. Od EER ed Fo king out [ETS i eae 11] ate 17 i 5 pe bein: 18 7 a nh tion convo J 13 hy. Youn er ANN 3 vu ccs, Jn kb en: + — Pa, PR iv tobeat elo TIT Ry ghrelin 1 (Fages 10 Le 13 [Vi = TA oni onde ei neti loe §7 off £3 7 vibe cvr wn po as smd 130 DC Rp p— 2 epee i 15 comic mh mien wr gan ek TE Mon NE me an 1% wes ng. 3 was he all pwn wn) Wimsatt i PA — 3 War i 51% canis baseniak win 21 0 Mamba | BA vw 23 Choy Doyuabas of atau pei die ves | qos sm 21 comers tut | bee 13 wh " FY Was 3 A Teheran scotuviiron dems | TS Ind atage in aes Amin 10 Ture few 4s rent 4 Twa a Far enti 1a versenbe |e ei dae } iz bias be3h hun id 3E A SE mal Soran GRA 115 Bow ick abt on I CRN BERR RRN foe 1irra 117 tats. mobs nevatarelillins mows rt Hp TENOR I fs ror Viiid | 5G Ar bet 2A ashen da Le gn | A tiny? pth weld. 28 shoe owbed gia 80 Tne Sor Wk 19% Arne 1] + iPass 14 Le 7) | i : 02632 z i 7 ware ate sm PG ln he 13" ie Sean 0 — { Poh van Pe — oD weber isdn € NX NY ackane wr bok. SoG ashes ll CO due Adee LT A To 8a DF Diem resonant sn Cr ako EE FO fei Hy i LQ Dich veh rum vided FOL ——— H EN va HER QE SS | P12 Q Allright Didi ech sou wih Ns Pads D330 On, Was ws he a tae vat bid cress ith. H 12 3 Nn ehank: re, | 36D Gar Ohm. Vast ony amber 13 png ho Yok aa ren To Ete i 9 Durem 9 Alt ro marines 2. £7 Ure Did Se cver meant Bis Fiza in sou? ia |] i 2A meta fog Tr — | 3G funded bi wrote 35 5 Tent mia Fok | 21 meee? a) New Vark? Neborbe eli fren th bro lin cae) H A ——— 25 ates epee ing i O Tsun Atbmse decison | A Clebubelie; ! 3 7N pak tan 3 re i Spel ws ] (EERE CL IT a | Lif ade 5" <a TK em meat on RR EEN RET i 17 Q Yamddnlcabeon Auerbach | 7 A tw | BO aston on psa andrei C3 Widens 2:40 i 2 ra men 5G ar 50 Toumathrrs Bon Alig Delp 11 6 Nadie ERT 120 Mow i Rr GR Ns FEI Jr Tr PN tr GD A mean 35 ig Io gon Sonat Bod SoG Dune och bin mz 15 aman, Gr ow pmo SOO TA me HAI (3 CC phos Gh? DS pest Co vo och 1Q toto hema thm signs 16 ME) of aa Amro de pare 3 na ve 30 opr bo sro re ome FEI J rv — 2 i 52g Tope mg ene dy gon oa 52 1210 Shen woven? <2, 0 MED oso br me is a & {Pages iE to JM 02533 = { en Ey AE 1 Saab ant i Erfraich Pi an roe 2 DE eh aie shit 3 BQ Heniamte so Cras bad une 7 pee raearos on td Sona 3: sma 15 resid ei | Tagen 7 ta 201 1 02534 & 1S. Department of Justice [4 Oftico of Legislarive Affairs J —— Wes, 30: 2030 : Noverber 3, 2007 “The Honorable Tot Coayess, Jr. Chairman Gomme an the Iodiciry US. House of Represematioes Washizigon, D.C. 20515 . Der Me. Chien: “Tas let press he views of the Deparment of Justice the Diepauiaat or DON) cn FR. 3887, he “William Willer ures Tralieking Victims Protestion Requborizition Actof 2007," 33 introduced By Congressman Lanto on Cktober LE, 2007, Ihe Deere as siggiicant concerts, which er detailed below ia section-by-ection snsivsis The peoposed Legislation, as draflzd, woe] slimioat the Departnenr’s lei. several important steps in the: ‘ict ideatilication proccss, nd thereby sega kgact ous shitty 1 uso he safely of victims and hei fn, zs addons) victims, nd grand end proseeots human - ‘malickers; ould brood he ial stuts cogaiding prosecution in 4 menses st ducts { trom effective Gnfoevuent silts and raises se jous federalism implications; nd t would \ wnconstitutonally intrude izto Executive tulority. 1 Senter “The proviso 5: subsection (eK 2)(B) mtherizin the Diteetor ofthe fice to Mosier 14 Chabil Trallicking in Persons (GITIP) tthe: Dsparimery of Sao 0 infer view victims should isfy haa the Dirsciar i sabar:aod 0 80 50 only wih re consent of th Atormey Cieneral in an oe where un ongoing investigation o prosecwion mig exis. Otherwise, serous issues could aie that would complicate or even scale prosecution. Tor example, 1 stetemots wade 9 the Director woud presumptively uve t3 be med over 1 he defeose and 2p satomnss (bal coniadict stan me to aw enforcement or prosecutors would x ToquiTed 0 be fumed over fn the dele. 2 Section 103 1201 finds seccin 193 vanecessary and dulicsve of exiting cet and. therefore, oppuses i inc wic i the bill. DO) and athe Federal agescios ae ready oflenog he types of assistance thet ae ecsertbod i th s2vtan. Suthenons, the new oieetin (05) weld toquirs he United Scares Guverzanent to provide iehrical assite-oc grovids legal finswurks am ir grograms to foreian govermeate and nougoverental arganizstions to i ( li nus “Ral orsign migrant Woks a2 rawided peuiecSor, equal to nationals of the fveig: ! coun.” Lis pavision docs ao iffecatiore betwes Jogal and oo: legal mut workers, nor. oes i distinguish betvieea fread labor and on-cocceed mig fubor. DOJ kolo that ay intonation stand thot 1c proce mest mor our nostic sancerds, Simla, the now i svsaction (aY0)(4) could be read 0a cnoonreing cuuslies lo loosen their immigration (aw, ! soning that the United Sistas Gaverninen uight od be vlig do. Subset (b) neds the Foreign Assistance Act of 1961 (22 GA. § 2:81 erseq)o provide specif sistance for 4nf-raficiing investigation and prosecution vais fn ecg Fi courdries. This subsection could be cog: ws priorsing sox racking aver bor i uliking, As luted 166s, DOF believes taary intotutons] Sandard hat we promote st minor ou dosnstic sandards, which prioritize both sw ieficking and labor ai Seiing. | Fuhr, the amendinent ts 72 US.C. § 2152(d)a)(?) should laclude a Ferenc to abot #ralfciing snd ld, thereiore, read “ineliing vestigation o individuals and ences that ; nay be ivohved in reicking in persons tvolving sexual exploitation ar forsad ahae.™ 3 Second “The Desament objec tothe augiage i tos session hat specifies the grou ith which the Unifed Stes Goverment wust consult and oooedingls i offering astimance and Eeoection viet of Suman e(Tcking. Such languags bof pleczs undue resccictions on the : Unit Stes Government sid could Tit the Goverment’ iy to dea wih sore uecessary frou. hon Seem th consis eat practic of the Department 0 coceult vic with a ange of - stake holders 32d res befoce design » progam of foreian tisave on bums. raficking, . { ‘Sach an additiour] requirement in the sac itery Jenguags it umieeessary. We suggeat tha the : Jauguage be arteaded to read, T7Tn coopezarion 3a) sooudization wih ara zations which may clude the [UNHCR], the laesttiona! Crgagization for) Migrate, and tht elevant Organizations...” 4 Sectourts DOJ recommen hat section (s) sls equine tt the elfectivenass of usstons : Drogen: be meusurod hased am best clfors to elite coupon with aw enforces, sion i with lhe other enter 5 Stone D0] opposes tie bar in subsection (b)(1) asainst focuding cases in which probation or ow sentecce a piven, Some of the muck important cass re fhe anes against cooperating defendants that esult it nim! snences in exchange fo infomation ores imcty. Ermbaseics : shold have (i discretion to tke such situations into acco when evaluting foreign oveconncat eTocs 1 combat trafficking. The Depastoent recoxnasends amending secon + Q)() by striking “stall po be considered 30 bx aw” ar inverting ir. it slave “sel be 4 coniGered ou Case by essa sis 0 deseaming Ail will be consideved wu” so tha : wil ive he i cretury of Sta greater Nein in cyalouting the efforts of ober counrics, 3 y 2 | be i “Ibe Depaciment also objets 0 the new paragraph (11), which Lists 2 3 citetion for H asccrtaming whether the govern in question hus made “serios and sustsined” ifort | Jinjazte laflicking "| futher (Be povemmen has made seria wnd sustained efforts to raduoc Geizand fer conmarcial sex acs and for ari ation in nleemational sex sea by tional of i the conor.” We ubicct 0 his language besauze itis vag sud wD, by implicatios, reqnive the United States Govamment o evaluate itself nr der this “seciaus and sustained” standard, The ‘Department prefers the langage tht was added by the 2005 rewwthorizaion of the Traflickiog i Victims Proection Act, which crahuaied whether counties “adopt Tetsu” 0 ress i Geizand 6 Seton 107 : Section 167i8) of the Ae aises aeparstion of puwers aod Chad concerrs. Section i 1073) would aad 8 wow 23. US.C. §7-05I)(D), which would limit he etonat of in that a | constr cousin on the Fer IT Wet ist (0 tw yoars, “ila the Secrlary ef Ses ; Srovides w th appropriate songessianl amenitces odio evidence thal” he contr had | ken curin sir to aks igu:ficeal Bor to candor iaficking. Thit provision furthne i quires that “| sloch credible evidence” shal hu ruvided to Congress in 4 report. Ta the exten: that ation 107(s) purports to give songressional committees authority to deni whethe: the Secretary's decision 1 exes & country 10m the watch fie i based on sufiesantly “credible evidonos,™ he provision would ive (he couraitees tol in cxaculiag the oe i he Constitution does not llow. “Ones Congress makes itn choice in suactng. - ‘ogialation, 6. p-toipaon ends Cangress can thereule control he Grecution of 6 enscumact 4 only ndirily by passing new gio ion? —tha complics ih the bicemerali and 2 prasennneol ceqitemants of Ailicls L Burasier ». Symar, 478 U.S. 714, 735-34 (19361 see ao. HS w Chaclha, 162 U.S, 919, 951-52, 958 (1983). Ta avoid is concern, we veounead seplacing “provides the approprte songressionwl commiices ered vidkince” with “detecTaines;” ud placing “Such orediole svidence’” with “Such dsenrination.” T. Seotonios 10 opposes the requirement in section 108 fu cieeto u delabass “con bivigg ull apslicabis da collected by each Fedal dezarraent nd agency repressed on hs sages Task Fores to Monctor end Coma Teall * The datbose woul contr, Jaw anforoement scustive infoneation. which would prevest 5 dia fom being access bl fo pada. : eaforoe ment ugeacics, muy of which ero prt of IL interegeney task Reee. Pursbermors, 805 8 database would be JifGul: to crate, partially withia ce tmelLazie provided he cate Decause it wnald resis information from dite agencies ut cofiec dara jn vasying Rms nd level of speciBeiy. 8 Secon 108 “This section saticizes the President to establish an awa for eats speins maflisking : and dizses Bim 0 cstablish procedures for sect rocipleats of the award. DOJ opposes his i Foovision, a5 i uefezes with he Presidents policy making authority. i § 3 ¥ 5. Setoniiy “The Deparment opposes tha story langage in subsection 11 G(&)1)R) iit | specifically Tenions ihe (1.9. Gove al oozaccod hotlines for teporing instenss of i callcking 3 peraons. S0erly sroriding for th ames of Or hots oold miceorc with | the Presidont’s policymaking sutiericy tn chang: the Sotbne structure at a later Jute. i Farthormors, Th Art, ug siren, misudes; re hulins 0. Seetion201 fs section 201. the Deparment abjects de new subsoction “(55)” To fue extent tat P such a sksescdon is acesary, a questa thr we Eafe to 60 Pepctment of Slomslasd Souity i (DFS), he dscisiou sega =coperaion shewld include the Aticmey General in witioa to he i Secretary of © Dept: of Horses Seuanity, 8 it docs in Section 2010). DOF defers 10 DIS regard o sustestian (4)1)(8), aibough we would nate rat by ceanving (56 “cusas and savers hur” stradus, sicims 31 be clighle for 2 T-via upon lower shoming of ext zac Eurdship.” Tho Depieni aso deions 5a DHS i regard to subsostion: (02), whi would exlomt Tvs parents oo sibhogs of aff vicais. As fact! mater, Eowser, te provision should be aancaded to stk any reference fo a 8 scsuh of the Feu's cooperation Sith Jaw enforcement.” TealTckers Jakn victims to nomides he uke complissce wih rsficks' p demands zn to exalists ox victims’ escape, ot because of law enforcement ccopsraion. I is { couner-facual to describe the pater of cats sad etlition ws iaked to Fas euforcerment ~ coapazation, ad discard th ist hat eats oie only subside wien law exforcement tues mest to sccure dhe mi oc punish (up rallhers umd shel associates Who deste ction : fame, Funbermore, itis onclear raethe Le reercnos o 61g encompaseca het minor I nel aul blings, and hehe spouses ax hildzen of adult siblings sould ho digits fora T- i In subsection (6), DOT opposes the rw subsection (SNE), hich grant sole anhosty bo he Secretacy of DHS to consicer whasher “exe bdsbip” exists. Tho now seston, howeves, also requires conseliation with “Frosecuion,” wich pesumobly Tefers o prsesutors ut DO, since DOJ 116 Jad prosecusarsa agency fee wes vofving vos racking, Sinee these prosceutors are under vie Atomey Genecul's axoriy, fhe sou lator. sequitement $30.1 i include consalation with the Atloracy Geaers. Sabsccticn (61), wick acuics the new scbssetion (3 4)() i section 1070) of the : “Toullicking Victims Brotecinn At (TVE A, should mie agplicatios for conse preecacs fo those being mate by “Fedonal” kw enforcement oficials, Lining the applicGuns uo those : submited by Teeral Jw eoforsemon asists in he victim idencificaion process, The ‘Deparment hes estatisned a memorsaciun of understanding with DISS tht ensures hat ne Diop tmet’s prosecutor ae i» uted when investigators apply for continued presence. ‘Furthermore, itn 4¢ applications © thas submited by T devs] lov urement casirss he | ‘unifonty of sndands ia making the essrmination 5 te sehen dividual 3.3 vit ofa | / 4 severe oma of eafikir in persons and eligible fot contra presence, Folly, Focora low | safozcenent involvement i. the process allows edezal prosscctors ehe ability t idonify | sattzcms of wear: tra icking acvity hat might san alipl faz aw caforeepent Juidistions. or hese seme reusons, the news subsocton (3X1) should sid “Federal bofors law enovversent” t ni the ahoriy 0 segues pusole ee relives to Fadel Le enforcement oficial Th nw suction (3) (ANS) should sd “endeavor ta” ite “shall” so tht a leglty actiasble obligation is not ercatcd s lo Fede. Juv ferment’ rel in roteciog. fe uty of truftcing views ang furl amber. While the U.5. Goeommant mes very odor fo root 193Tikirz viet ms, tho tatctory ang. mp, 15 or, iuuld be construed to create 3 legally soguinble ght and cod lead to gai La 1c new subsoetion (YAY, DOS oppesos sxterding contisnied preseace for the doraion of a civil suit. iL also cues the putautiel for usc because of Ibe Jnglhy 1nd plaintifTitiz-vorirlled delays in cordacting evil itfarion. unzemore, physics) prosence in the United Stites it ot cacessary for he sess means of a cil scion. Vitis Have fk opens to hin stat on th Usted Ssls, ich an T- snd Divas. HOT asses echnical change tn subiection (A), which curently bas ko sbeector. (6. £ DOJ recommends sriking hs second "(2)" sad replacing it vid a (31. i I Section20? { ‘The Depart oppses (bo lunguse i section (a) hat logislatcs the 2xisience ofa. spesific ws fore, such 3 le Trafficking 5 Persons and Worker Explol ation Tusk Farce. DOJ : records debtion of hs tefereuce aod Ae placemeat nf ts naved ask force with the. ; Atri Geaeral™ D0] 815 opposes th 120 day dealin fn suSseaion (1) 53 wares sozable due lo imgunge i barrier and ransiaion needs. 12. Section 203 I shsscions (3), (W(1-2), nd (€) DOD sppases the “angage removing Lhe Alten Genoals ole in detervining wheibes hs elevant speicant hag complied wilh reasorable roquess for assistance. au apurtan ctor th decisions regarding -vieas, oe that 1a myestgation of prosecution é complete, Because the Department i invalved i is prosecutoial 8 wel uss investigative oles, DOJ uelicipetion fs critical Ir assessing assistance wih low y enforcement, an i is well situuted 1 ascosn whether vicion has commlied with easonsble : “quests or ssitanes that sont Mog vestigate sgencics outside DIS. such as cases i invustigalo by PRI or DOL, Therefore, a joint doearieation is appropri‘ becuse of te umber ef diffu lw vufbzcement agencios ha nay be involved in partisulas mile. 5 1. Section 205 DOI poss the 3ddlion of the new subacction SAGANENA) tho Immigration aad Naliomalizy 20 Act (8 S.C. 1220650) unless the wove “Federal” is seed bo “lar enforsemat offical.” ‘The Kame 0posed subsestu currendy sates thatthe Secretary of he i Deparinent of Hemeiand S:urts “shall grant pale” he relatives of wafickios, victim DOJ recommends slaying this language ta rad may ran parale” so the Secreta Ins the late to make sa appropri decision. There ty be rcesuas pesining he Circumstances efile relatives of the iatickng victir fo which the Secreta howd Eave discretion to deny sure. Putter, DOJ ids i necesary ta stoke any mance fo “as a esalt othe iien's encpersice with Lw enfirceraane far the teascns acted above. In subsection, 6), DE cpposts a satusey reqpireancal thal parle bs exert dicing senting oivi actions. As indicated above, his scfion pal cx 3 Sotenia! for atuse because ofthe lengthy und glasifTictin-controlied delays it vnc civil ligation “. Section2nl Tho Department opps the cludge of the “and” i ubscetion (1)(A} fo ta “or loth tbe A'toraey Genel and ths Secretary of DHS neod to be inves vod i the centificeion process. The curren: oeifeaion process is welt<sblished 0d weeds 1 laulory rensions. DOJ asa opposes the cage i subsection (8), whch would resaove the Atorcy Generis wthorly if stain whether & person's pecnenco cessary 1. casing, an effective pozecuon. As th - gency thal prosecutcs ccs of musa tr Seking, DOT's involvement yal importa, “The i { Department has th same corse wilh the proposed chige i subsection (2. 15 Saenz We strongly poss 2 luna in his seston dha irapropristly semoves law ‘uforcemat fiom any nial derermination of vierim sans or benelis eligibility. DO) and DHS play a critical ul in protecting te safety of vit and servies providers. Any ils 10 + involve Federal law enforcement inarediately uper suspicion “hat cri fas bee comiticd ould thread the safe of he viz, impeded eats to prompt rescue vietns 1 in s jonpuicdy, sad possibly oot i he offendecs 2v03d apprcicusion. DOJ tecogmacs the : important of inchiliug THIS ut Lhe iis ages forthe pemese of fuciliteing promt delisery of tke full ange of available benefits nd servize fo aching vies. DOI oF coulis fo work : eth DHS ai ITI bs cosine dhs interagensy guocedre afford victims of tea lcking prompt protection a access a hose services, The Depatitest fuer objects oho provision set forth in saragrash (Gi, which would coin both Fedesal and sate a forcement offcilat infor the Lépastment of esl and ; Fieaan Services (HITS) ol the exile of pont viet, bul doos not require HHS, odicr Govemment offs, oc noo-avemmentsl service provides to form Zor or stale by endorcement of 6b a vistim. To the Salen) lat such a nofiScaticn prosedors most exis, if must i also include auiificatics athe Acoriey General snd to Secretary of DHS, wha bes ] cesponsibility for prosecuting und -oveatigating instances of human raffisting. | 6 i I DOJ also opposes substion (). Sinse the pissage ofthe TPA, DOJ has besa onc of : the prncinal agencies conducts amings fo avid: of audiences oslsding ah ores | PATA Ae mar Agr H Larne aloo us cxpecience fn 0d tig tating on ovenila vizims rough te inoceac Lost Naional nite, 3fcaive elfrs 0 comet tacking mus ili th capris of HIS, DHS, and DOJ L103 also oss mised ing fu lis now subsceton (FYE). “dibiity” ms of “agility” 1. Section21s Section 204 of he bill alhorizes be Any Geral Lo muke ania fo asia viene of i severe forms of a Ticking tp tn ¥2.5 alin in 2008, increasing to 313 linn 1 2011, The. : ‘Dopitinont of Justiosuready as authority lo make ani for 12 provision of secvioes for ers H slim ind doss 101 fee in excess OF 5250 milion a secs. Ali, he authorization of ver smother grin ogi iz Counter t to AAIFITioo's gropesa] in the 21S Fides 10 consolidate DO's more tan 70 rant progres, Worcover, any provision purporting to expand ar ale defioiions of individuals of : quallym er vic busi ut cle Wi requianca bt & Fodezal lane enforcement agent . must declare h JuEvidst fw u vii of severe (rm of clicking i persons, ad tht oc i sictim agro 15 Googe ten (he vestigation and gcsccutiun, o at th vim bo wider he ge : ra ofl, : DU opores the comsulstion cequkerent i, sehsecion (3K 1) wilh the Solar of Sake 1 ctahabing programs to serve doseste, U.S. citizen raffcking ius. Such Cometic aston fll 5u3i0 of he mission and experi of he Department Sate. DOI also opposes hs mara os sulsion yh non-event xganizons (KOS) toganling the roviir: of services. This creat conflict of cee. since mary of the NGOs wil spgly tor od cul ] Teczive ants under he pogeam. Fall, any section egasding he provisiun of victim savicas | ‘mast so contain angunge tha nelodes crganivations tha srovkd services 0 ovens : satgecid to Gadicking, w defined i setion 203(e) of th Tafticking Viet Projection Reauhoizaion Act of 2005," which would err al te fonds orice ve Attomey i Geneal dor ssablibuant of ants will go ward the wk and develo ofthe Tunacence. : Lost Tosi Fores. TIO opposes susection (1) has i provides Victims of Ceime Act of 1954 nds 1 prostitutes implicated in violations of the Maan Act {rtminaliiog rasportation f prostntes 1 Intestate commer). Such pec do ot me he <gal dedEutien of icin” 45 lr ] elim in the Li, Jes he pers prev tod i under the age of 1 at he tre the. crie sas ] conuaried othe eas, theougl he pplication of ano Federal saute or egolaten, sis the Tegal denim of 3 victim. Such persons src skeady sigh under he Cras H Victims Fund Act to eceive beaedls. i i 7 IS 001 opposes seins 214), 5 could Soeoariucd ta rou te Alleney General and 8 the Ssorotary of Healoh and Human Servioss to mek kis) sive reatmmendztions to Congress in bh violation of the Recouendsiivns Clase. To avoid this corcom, we recoricnd inserting ©, if % ang, alles “ccnmrmdaions” section 2: 4(A)NE). tubes, DOI fads sybaecon (3) : redundent. 4 thorough stody of serviess available to domestic and forvign victims was wenduated by the Senior Paticy Operating Group in 2005-2006 and fend fow stetutary J A WE rs on Svbszction (d)(2KC) containg a riundant statement, Vicims of sex uxificking ae Vela Sos em er Ya 7. Secionz Io subacetion (3), DOF apposes the change of FemuinciakEaPL EEE DERE 2 ET RE ; ] Bic i aad op chlo This chang of Law would esc so abily ci, wg 1 1505. § 2023 ih alr seve 1 yen . Seater im sete. over SORA AHL SETH 5 eerily Foinb ori GB 10 538 TS AIERHELR Se Therefore, 0 suggested subsection (a) DE " 4m vn tue i EA er. Aosta prvi € Ely of egies } Jegel cha Rouges. p 500 opposer scion (b) 3 emits. The proposed Image: ts both over slusive und und chute a mow Fai alt, og nag agen. Motcovn, th L roviRion in unaccoacy bene sucticn 1539 aireedy probibits many of Tes eefvilics when Toul in “aio ar whee yal on sm aepel he mc “The Deartmect pposes subsection (11, which would expe ihe ann Act o include was “affocit1g” intenstete comme. The Departmen does not requice any addiional statutary i att or expended fucdioan nde i confine sucess prusealion of an : ring cons sim comin soe Tos SS BET SE oe regs FART Eee pe v Eber 1 Dep eat mer urn 8 1 2 Yr le 1s soe Rng sud pees icin chads rd conv md Soot re he IT EL Hh A rd ; RSE als his allocation betwen site and Feducal enforcement authority does aot imply tat these ares arc loss serio, rt rather reflects : import sczerral allocations of responsibility bation state wd Federal governments, Th : forcealizaricn of these crimes would treat lem éiffezent’y than other serious crimes such us dr spd pe. hel roses ah le ol Kihappios gx Fat va Vd i rine ou whem it involves Samsputaiion “it” iniratete commerce, NAibehvate, Bier L y . go 0 0 MUSED DAIS is pS Se Mp ha: i high votame of peostituficn-related crimes, the Federal poveranent ‘2cks the 1ccessany resontoes. and capacity to prosecute these offenses, Thoiefore, to the caient tht fis SR LE EE Es ed SP RED RETR HA eons DO leo aposes subsection (5), which woukd expand the sex mas offenses to “ncude those who Lravel for peposes of illicit sexual activity with adults. The Deparkaent's corrent efforts with regard to extatcrivoriel offense foens ou ehild sex iourism, which are very domain Or ev Cote, Tr lg oleate chon, Pinging victims 10 the United Sates to eslidy, and suerdinulion wih foreign law enforcormcos agencies and. foreipr: governinents pemensily, umoay olber matters. Any expansion of authcrity would be a dsteacinn from those prority eases and would cxacerbete existing burdens un investigetiva wae. procctivn The Departmen: believes that the addition of 18 U.S.C. § 2423A is wnceorsary and that 18 U.S.C, § 2923 does nul need w he iraended. Stud Congress create 4 U.S.C. § 24134, DOJ believes tht lagu shout be reused in 18 U.S.C. § 2423c) ‘bac Town the Government us charge aliempt or conspiracy for ” 8 115.C. § 2423s) criws. Finally, DOY notes thet ihe dedinicion of illicit sexua: conduct 5 wads 10 To: ytd o include peodection of child pormography. 18. Section 222 As a genzral mati, the: Depachrant opposss the expansion of jurisdiction oves offenses nln nom dan: os Fens of ios Gi we commired CREE i Unfed Saas. The pansion of fisdton in i econ oul hes 53 OEITANS So SHE ec uz adit, Lhix new seotien’s jurisdiction description overlaps with 18 U.S.C. § 3271. Should the choice >e made to keep the jurisdictions) provisions providsd far in this section, paras it would be ore Gi ty pad scion S17 ! 19. Section 223 “These provisions ars not dircedly related tw l=ufMickios. As ibis section is related to aliens . brought into the country for the pasposee of position, without a showing of force, frand, or : caercion, and the Intentions] Mamage Brokens Ax (IMBRA , this bill is not eke vebicle for bis logunge. Lirthemore, siasaction (if 1) removes dae requirement from secon 278 of he Inamiyration snd Narfonality Act that suc cunduct be dome in futherance oF the itportation uf 1 ho allen. By renovin is regents he bl extends eda to cover ll anc of i “pimping” sa slien. H s | Fi i 2. Senion221 : This section misunderstand the urose and effect of the model law and shouts be £ deleted, Te Departs’ mde) 257738 Der designed (0 A0ppLaTt pro-cieing, sate Laws ‘hich target pimping; pAnCcring, or srostituSon, but ather tn amlrent those ls. Atthe time that the Deparaman’s dct kev vias sod, mo: sires find Sopnbeasive Lvs adessing prostitaon, pimping, and poncering, Hasieves, mos! sates did aot have xe focused ua man trulicing. The Depauiaxa’s ov wes designed fo iso awareness of he $6552 OF TRHTEKING al (0 coturage sites m clavely cxmine cases fo ensue that casos invoiving fwd, force, and common ace no aboled 9 srosCiution offenses. Tao Deparment believes ie law bes been suocessul in accomplishing this god. 2 Section 231 The Depamienchl opposs any Setitury clings to the amma: spat. The che ia subsection (1) a wmaccossuy 45 his guage ts cameaty irchidzd n the annual spor. The ‘formation regaestod in hw subgosticn (1) weld Be excassivoly burda to ther. . 2. Seerm2sz DOS cpposes tis addition st wmsrsay. Vormas Tafficking Lawes that da of reine he prual uf force, Towod, x coczeion, nan Laws that conceen minor wii of severe ons of bun walickiog, ave already dissed at be annua! conferences, Tothe extent bat is 2 prevision wonld ‘ait lao Dopartnest to discuss Ran taflicking Laws perteming t adult { vicims dat do hol cece the swing of ico, iad, or curmvion, such Jaws would ad ful = under lhe deffaiion of uo Gatto aad the anal conlreos won Le a0 nAppeepiste von for tbo discussion. of such laws, Howerer, DOJ talfcking ~mpeiors UZlize a wide range. of saute in 304iton © Chigtoe 77 oerses o addres a] criminal conduct associaled ‘with human afficking, Ths clues the Man Act, moje Judes, visa vod, immigration offs, cirinal lebar violalions, and extorion, jn addon (0-00ke semis! wats, Acsordingly, DOJ taining a anual conferences, the Natisral Advocacy Contes, the Nutoral Contec fr bissing anc Esplofvd Childe, cad field haining with tr Deprimeed of Justice i funded Homan Trs(Fckivg Tisk Forces and providza thzvugh the lanoence Lost Nation 1 Initiative inclade discussion ov. the Emporia of using al) wvlablscrimina: ates as ecsectil 00lz chring decisiors. Thus, this secon 3 umccceswry. B Section? DON opposes the chung to section 206 of he Tracking Vieira Pewcction Rouborization Act of 2005, which Woulé emmave the sera. oa pris in forming the Sevioc Policy Operaling Gow (PG) of gents. Such a ching could be ad 3 giving the SPOG oversigbh amloricy over grant. It 50 als 0 ke oto considecation sn ations hire ‘srant-amking ageacies may be arable 10 50ify the SOG of tho grea. { 10 i 24 Sertion nt Tow Departed upposes subsection (a) es an excessively bunionsoms and urksccaary creation of mow faye of bureaucracy within our agency. The Depainueas docs not lieve ha thane ig cuerealy any bk of coo di aon. 20d 2 ac postion sould ead 10 dnplictic: oF efor. Falbcsurs, subsectof (342A) maorroctly lists he Civil Division 1nd aot tho Civil Rights Division. 2%. Section236 1a svbseciion (v), DOJ questions the reliability of the congressional findigs, esposially wid respect oe estzusted number of vizcius and tho inforeaco that the eck of kid victims is direct 72100 13 ack of odacagion individuals who may com: fe con(act with human tes ickdeg victims. och Fadings, willout Zul body of evideae, ace counter predictive “Ihe Depastancad also opposes substion (b). The Afioney Cieaeral boul be insved 2 any program tha focuses op combating child trafficking at the border. We propose that section (b](1) 8 nd to read "The Scerstery ot Homciand Socuris, in conjunction its th Sccretary of Sta, A forney Gee:al, and he Sosretary of Teak end Boman Services.” Furher caest of 1: childeen intcrdic ed a the bordec are wed for smugyling ard sc vot afficking vietnzs. 1 subsection (BXSKD), DO] believes thet he proceedings for zvoval 1 goa. concigons countos ae problemi bees DHS necds mare f1Sxbiy 0 hwadle gang meubers, lerorists, [EpeaC ofendees. and tale offenders. Funbcmmore, the canis oceplion { evided Is 100 Dau0v to protect he national security ntevsts ofthe couatry. We oppase subsection (611) to the extont tht bits he Admistation'ssbiity to detemmine le best ereangement for custody or varios classes of UAC. The administration will work with DHS, DOJ, ard HES to ccfne and modify burrat detention nractics where eceraary, The Ineragney process the bes forum 0 €onslder the ious berets of wnacoonped minors and 18% ex forcernéat unl fo develop and adapt policies ht, aon ulaee ings, rowdde Tor de safely of all cox cond. We took forward 0 dscuse.og tese developments wilh Congress im the fare. “The Depart opposes sebscstian (4)(2) us (00 row comsrued. Then: are ieamerons east, outside of Loe <hild proving to be 2 canger to bwself or crbers, tht require ‘chiklren % be kept secure fifty, including the saety of the <7 from dngor that Js sat scif-imposed. In edition, the standard for plcing inns i “Secure” caro i 100 hic, Tt requires ic least istrictvo sering lit i 0 he best interest of the child.” RHS only places 1.4. persees of iors i is Grew ly & Secure” Custody armangement. ais could megn that miners Who need is wrvangement wold inrtcad be boused with chile wha live mo history of violeras or criminal behavior, HHS needs ue exibiliy und there should not, thereon, bo roraited to make 20 “independent fading” of the ils danger to efor others. 1101 opposes the mpage of subsection (DY Ke) 5. would afford 118 scoess co fs caforosiacan semis dabises. { I H “To Tangunge of subsection (45) must be changed row “shel cna.” This implics 3 icaa] obligation os th Veceral oversea ty ovide vywyosd 24d corcamin right on bebalt i of ict ta goverment fended coawsel, which is Fupptopt.ate and 031d subject the i Boveri tgaion over ho Dele and scope of he purport oblgacion and ight. i Ite Depertment also opposes subsection (6), which creates a gnardian ad litem Progam. Sul program rafas sri conflic of inkerest onacerns, 20d DOT hs apyosed init Laaguags inthe rst. Feablisfunent of a guanan ad tem progrars is oo urmzcesacy in the 8 USC. $3500) leas ets forth detailed procedares which provide foe sc apoio. qvadians ad lism Jor oh rer. who as ict of o sacs lo crimes volving ise or axploiaion. Stibssction (47) ray revit in unintended consequences dt to his confidentiality ection, “cilectively combat ratickiag, relevant information muse be tensed fo as caforcement. Law anforcanont is wal-cquippod 0 peeceve confdentiaiy concerns, The Pipi believes that subsection () undemizes the 1897 Special Inigrane ‘ favre vefrns amd cppos mig his bck: aver he tes, where | wat inberenly Cave Ti scetion 2060), the effet of the amare rulccactivity of fhe geasrat applicabibty of hese smendmcats fa “a1 less i ie Ute Sues before, on, or ae th date of enactment of this 62” uae seious <orosis bout re provision of bene und services and bas the Potential Lo route serious problems or tho Department iu 2 inplmcntation o the programs ( described a this section. 3 26. Sutin3y OJ recommends sisking the 2 prccat cup on nding for triring and tecasicel nssiuance tha is in 22 U.S.C, 7105(KZ)H). The vais comyiericy Gf the nafficking isu and te level o coordination neceesay to 2fssivly scve tafBiiing vias requis uch more (caeing end teshuieal sistance han atypical OF? provi. Siring the cp or, Taina aod (esTnical sistance vil allow OJP 10 better aloes the wafcking Sand escives. The change could be implemented by he following Stervory Lapua “Paragraph (70)(2XDof Db. L. 106 366 is amended by: “(0 insering ‘and ater de est scsicolon;, (0) sing “Gi tough and’ 2d (3) staking i)’ anc inserting ‘D1 27. Section 302 Sceton 302 re-nthorizes hc $5,000,000 Approgsiaion fo the Pilot Progra Ul was : fst authorized by Scion 203 of (ue 2005 version of this Act. Tho 20 version, hcefors, i should add Iangoese umsendiag section 203 of the 2005 veo © provide tua: HES docs vot : Terre the exclusive auberiy for davelopioeat of he pio plogeaca. DOT end DITS ust be included in he develope of Lis progam 10 ensure tht th ebiliy of Federal roscovtors snd % 2 | 1 L Jew vofucoemsat in gain aces fe these victims i 50s pegatvely pawed, Moroores, Lhe Depry’ Lowledge about these vic, Ohi Usaviaus, id re demgers tat re eset . in prnvidag shelter od servis to tiem won be insrarental crewing th fasocss of the i prot progres. This sostion sfauld uo end sibsetion 203(8) of ths 2005 reauthorization to i iachuis fcr “Secretacy of Haa'th and Human Services”, in callsboration with he Amey Genel and Seorory of Home Seri,” Subsetfon 203) should be Fecnise t mended. - The Ofc of Mansgeman ard Budget has diel hac the is 0 abjection te he resem alin of Sis Jose from the ssn of Fee Amiiaticns programs. Snceces, | EAS push: Priscipal Degnaty Assistant Axtomzy General The lonocable Laver S. Sri, Ranking Mea, Howe Comite othe Tulicincy Th Honotsble Tor: Lanios, Caiman, Hose Coie on Foreiga Allacs ( “The Honorable cana Ros T ttn, Riaking Membes, Howse Comptes cn Foreigo Adis ~ “The Honassble Patist J. Leaky, Chain, Serste Commie oa te Judisinry Tho Houanuble Aden Specter, Eanking Mersber, Sanate Commitee on the Idicety “The Honorable kdvard 4. Kenedy, Covireaa, Senso Comte ou cal, Education, Taber, and Pensions The Hoporblc Michael B, Ev, Raking Merobes, Sense Commies on Heals, ution, Laer, and Penclona The Hlororsble Joseph Biden, Chwicman, Sense Comite on Fore Relsiors he Honorable Richard Lxgst, Raking Member, Seoste Comite on Forigs: Reluions ¢ n PRESIDENIIAL AUTHORITY 10 DECLINE TO EXECUTE UNCONSTITUTIONAL SYATUTES t this memoraschim discusses the President's constimtional authority fu decline to execute snconstieutional statutes. November 2, 1994 MEMORANDUM KOR THE HONORABLE ABNER J. MIKVA COUNSEL. TO TERE PRESIDENT 1 have reflected further on the difficult questions sucrounding a President's decision ta decline to exeuule statutory provisions that the President believes are unconstitutional, and | have a few thoughts to share with you. Le me start with a general proposition that | believe to he uncontroversial: there are circumstances in which th President may appropristoly decline to enforce u saute that he views as unconstitutional. First, thore is significant judicial approval of this proposition. Most natable is the Courts docision in Myers v, United States, 272 U.S. 52 (1926). There the Court sustained the President's view that the statu a issue was unconslifutional without any member of the Court suggenting fiat the President had acted improperly in refusing to abide by the statute. More recently, in Freytag v, Commissioner, 501 ULS. 868 (1991), ll four of the Justices who addressed the issue ugrord that fic President has "the power 10 yelp encroaching laws ... or cya to disregard them whe (hey are unconstitutional." 1d, st 906 (Scalia, J, concurring); see also Youngstown Sheet & Tuo Co, v. Sawyer, 343 US. 579, 635.38 (195) (Fackson, J., concurring) (recognizing éxistence of Prosident’s authority o uct contrary to a ( statatory comunand). : Second, consistent and substantial exceutive practice also confirms this gegeral proposition. ‘Opinions dating to at icast 1860 assert the President's authority ( decline to cffectuate coucimeats that the President vies as nuconstitutional. Sc, o.g., Memoril of Captein Melgs, 9 Op. Ally Gen. 162, 469-70 (1860) (asserting that the President need nul enforce a statute purporting Lo agpoint an officer); see alia anotations of ultshed Attomey General nad Office of Legal Counsel opinions, Moreover, wr ‘we discuss more fully below, wuncrous Presidents havo provided advance notioc of thelr intention nat 1p enforce specific statutory requirements that they have viewed us unconstitutional, aod Ge Supreme ‘Court has implicitly endorsed his practice. See INS v. Chadha, 462 US. 919, 942,13 (1983) (noting that Presidents often sign legislation containing constitutionally objectionable provisions and indicate that they will not comply with those provisions). While the general proposition tha in some situations the President may decline o enforce ‘unconstitutional statutes is unassailable, it does not offer sufficicnt guidance us to the appropriate course in specific circumstances. To continne our conversation abou these complex issues, 1 alr the following propositions for your consideration. 1. The President’ office and authority are created and bounded by the Constitution; hé is required to act within its ers. Put somewhat differently, in serving as the exceutive created by fhe Coustiution, the l'esident is required to actin accordance with the laws — including the Constitution, which (kes precedence over other forms of Lav:. This obligation is reflected in the Take Care Clause and in the Presidents oath of office. 2. When bills are under cousideratian by Congress, the exceulive branch should prompely identify unconstitutional provisions and communicate its cancems to Congress so thal the provisions can be comected, Although this may socm elementary, in practice there have been ocoasions in which the President has been presented with enrolled bills containing constitutional flaws that should have heen corrected in the legislative process. 3. The President should presume that cnactments are constilntiona), There will be some occasians, {however whona state uppears to conflict with the Consition. such cases, the President can and should exercise hix independent judgment w determine whether the stawte is constitutional, In reaching a conclusion, the President should give great deference tn the fact that Congress passed the statute and that Congress believed it was upholding its obligation to enact constitutional legislation. Where possible, the President should construz provisions to avoid constitutions] problems. 4. The Supreme Court plays a special rol in esolving disputes about the constiutionafiy of enactments. As a general mater, if the President believes that the Court would sustain a particular provision as constitutional, the President should excouto the statute, notwithstanding his awn beliefs ‘about the constitutional issue. If, however, the President, exercising his independent judgment, determines both that a provision wanld violate the Conslitution snd that it is probable that the Court swould agree with him, the President has the authority to decline to execute the statute. 5. Where the President's independent constitutional judgment and his determination of the Court's probable decision converge on a conclusion of unconstitutionality, the Prosident must make a decision shout whothor or not to comply with tho provision. Thal decision is necessarily specific context, aud it should be reached after coll weighing of the effect of compliance vith the provision on the. constitutional rights of affected individuals und on th cxecutive branch's constitutional authority. Also xelevant is the likelihood that compliance ar non-compliance will permit judicial resolution of the. ste. That is, the President may bane his decision to comply (or decline io comply) in part oma desire w afford the Supreme Court an appartunity to review the canstitational judgment of the legislative branch. (6. The President as enhanced responsibilty to resist unconittioal provisions lat cacrooch upon > the constimtional powers of the Presidency. Where the President believes that an enactment unconstitutionally Jimils his powers, he hus the authority to defend his office aud decline to abide by it, unless he is convinced that the Court would disagree with his ussessment, If the President dacs not challenge such provisious (i, by refusing to execu them), thors offen willbe no accusian for judicial consideration of their constitationality; a poticy of consistont Presidential enforcement of statutes limiting his power this would deay the Supreme Court the opportunity lo review the limitations and thereby would allow for unconsiliozal restrictions on the President's authority. Some legislative encroachments om cxcoutive authority, however, ill not be justciable or aie for other reasons alikely to be resolved in court 18 resolution in the couts is unlikely and the President connot look to a judicial determination, he must shoulder the responsibifily of protecting the constitutional role of the presidency. This is usually true, for example, of provisions limiting the President's aulhority as Commander in Chicf, Where its not possible to construe nuch provisions constitutionally, the President hay the authority to act on his nderstanding of the Constinution. One example of a Brcsideatial challenge to a stants encrosehing upon his pavers that did result fo lisigation was Myers v. United Sules, 272 U.S. 52 (1926). In that case, President Wilson had defied u taut that prevented him from romoving postmasters without Senate approval; the Suprerae Court ultimately struck down the statute us an unconstitutional limitation on the Presidents removal poser. Myers i pertionlarly instructive because, at the time Prosident Wilson ucicd, there was 0 Supreme ‘Court precedent on point and the statute was not manifestly imconstitutional. In fuct, the consiituionality of restictions on the President's authority fo remove executive branch officials had {hon dobated since the passage of thc Tenure of Office Act in 1867 over President Johnson's veto, The 5 closeness of the question was underscored by the fact that three Justices, including Justices Holmes and Brandeis, disscated in Myers. Yo, dospite the unseted cousttutionulity of President Witson' ustion, no member of the Court in Myers suggested that Wilson overstepped bis constitutional suthoriy + or even acted inipraperly — by refusing to comply with u satvte he believed was uncomstitutional, Tho ‘Court in bivers can be seen to have implicitly vindicated the view (ht the Peosidont may refuse to = comply with a starute chat limits his constimational paswens i he believes it is naconstitutional. As { Attonicy Genera Civile stated in a 1980 opicion, ‘Myr is vey nearly decisive of the issue [of Presidential donil of tho validity of statutes]. ‘Myers olds that the President's constitutions) duty docs not require him to execute constitution] statutes; nor does i require him to execute tein provisionally, agaist the day that they are declare unconsiitutional by the courts. He canot be required by staiute 10 Kctain pastmasiers against his will unless and nil a court says that he may awfully let them go. If the statute Is unconstitutional, itis uncoustinational frum the start, The Aarne General's Duty to Defend and Enforce Constitutionslly Objectionable Legislation, 44 Op. OL.C. 55,59 (1980), 7. The fae that a sifting Prssident signed the statuto in question does not change this analysis. The text of the Cansfitution offers no basis or distinguishing bits based on who sigacd them; there is no constitutional analogue to the principles of waiver and estoppel. Morcover, every President sinco Fisenhowéx has issued signing statements fn which he stated that be would refuse to exceutc unconstitutional provisions. Sce annotatians of ulachcd signing satements. ds we noted in our ‘memorandum un Presidential signing statements, tio Presiden “may properly aununce to Congress and to the puhlic that bo will not enforce a provision of an enactment he i sigaing. 1150, then a signing statement that challonges what the President determines 0 be un unconstitutional eacraachment on his power, or that anounces the Presidents unwillingness ( enfore (or willingness o lliyuts) such a provision, can be a valid and reasonable exercive of Presidential authority." Memorandum for Bernard N. Nussbaun, Caunsel (a the President. (rom Walter Dellinger, Assistant Atiomey General, Office of ( Legal Counsel at 4 (Nov. 3, 1993). (Of canrwe, fh President is nat obligated to aunouace his “+ rcscrvations in 1 sighing scatenent; he cin convey his views in the time, mauner, and form of his chousing ) Finally, the Supreme Court recognized this practice in NS v. Chodha, 462 11.5, 919 (1985): the Cour siated that "it is not unconuaion for Presidents to approve legislation contoining parts which are abjectionable on constitutional grounds” and then cited te example of President Franklin Roossvelf's memorundum fo Attorney General Jackson, in which he indicat his intcation not to implemeiit an unconstitutional provision in u statute that he had just signod. 1d. at 942 1.13. Thess sources suggest that the Presidents signing of a bill does mot affect his authority to decline (o caforce constitutionally abjcctionable provisions thereof. In accordance with thes propositions, we do not believe that a President is Himited to choosing between vetoing, for example, the Defense Appropriations Act and cxocuting an unconstitutional provision in iL Tn our view, the Presidcat has the authurity to sign legislation containing desirable elements while rofusing o exevuts a constitutionally defoctive provision. We recognize that these issues are difficult ones. When the Presidents abligution to act in accord + with the Constirtion appears 1» be in tension with his duty to executs laws coacéad by Congress, questions are raised thal yo to he beart of our constitutional structure. In those circumstances, President should peocsed with causion and with cespect for the obligation that each of the braaches shares for the maitenance of constitutional government. ( Walter Dellinger { Assistant Attomey General Brief Doicription of Attached Materials Aiorney General Opinions . 1) Memorial of Capiain Meigs, 9 Op. Atty: Gen. 462 (1860): In this pinion the Attorney General { conoluded that the Presidont is pemitied to distogard an wicamstiuutional statute. Specifically, Aftorncy ‘General Black concluded that a statutc purportiog © appoint an officer should not be onforeed: "Every Jaw i to bo carried out so fr forth 3 is consistent wilh fae Constitution, and no further. The sound part of it must he exesutcd, aud the vicious portion of it suffered to drop," Id. at 469. 2) Congittionalit of Congress’ Disapproval of Agoncy Regulations hy Resolutions Not Presented to the Prosident, 4A Op. OC. 21 (1980): Tn this opinion Attorney General Civiletti instructod Scorctary of Education HufStedler that she was authorized to implement regulations that hud bosn disapproved by concurrent congressional resalu(ons, pursuant t a statutory legislative veto. The Attorney General noted that "the Attorney General must scrutinize with caution any claim that be of any other exceutive officer may decline to defend or enforce a statute whose constitulionality is merely in doubt." Id, at 29. He concluded. howover, that "Jo regurd these concurrent resolutions as legally binding would itapair the Exeuutive's constitutional role and might well forcelosc cffective judicial challenge to their constitutionality. More important, | believe that your recognition of these concurrent reslutions as legally binding would constitute an abdication of the responsibility of the executive branch, as an equal snd coordinate branch of govennment with tho legislative hranch, to preserve the integgity of its functions against constitutional encroachment.” 1d. 3) The Attorney Genecal's Dut fa Defend and Enforce Constirtionally Objectionable Legisiation, 44 Op OC. 55 (1980) Atiomoy General Civiett, in answer to a congressional inquiry, observed that "Myers holds that the President's constitutional duty does not require him to execuié unconstitutional statutes; or docs it require him to execute (hem provisionsly, aginst the day thut they aro declared unconstitutional by the cows.” Id. at 59. He added as a cuulionary uote that "[i]he President has no ( “dispensing power,” meaning thul the President and his subordinates "nay not lawfully defy an Act of Congress if the Act is constilutional. . . . Ln thse rare instances in which the Excoutive may lawfilly atin contravention of a statuto, it is the Constitution that dispenses with the operation of (he statute. The Bxcautive cannot,” Id, at 59-60. 4) Letter fiom William French Smith. Atiomey General, lo Peter W, Rodino, Ir., Chairman, House Judiciary Committee (Feb. 22. 1985): This letter discussed the legal precedent and authority for the Presidents refusal to excculs a provision of the Comporition in Contructing Act. The Amey General noted that the decision "not to implement the disputed provisions has tho beneficial byproduct of increasing the likelihood of a prompt judicial icsofution. Thus, far from witaterally nullifying an Act of Congress. the Departents sctions are fully consistent with the allocation of judicial power by the ‘Constitulion fo the courts." i at 3, The letter also stated that “the President's failure 6 vel 3 measure dues not prevent him subsequently from challenging the Actin court, nor does presidcatial approval of sun enactment cure constitutional defects.” Id, at 3. Office of T egal Conse! Opinions 1) Memorandum the Honorable Robert J, Lipshutz, Counsel to the President, from John M. ‘Hannon. Assistant Attomey General, Office of Tegal Counsel (Sept. 27, 1977): This opinion cancludod that the President may lawiully discegard a statute (bat ke iuerprets to be wnconstiional, Wo asserted thal "cascs may arise in which the unconstifurionality of the relevant statue will be certain, and in such a case the Executive could decline to enforce the statu for that reason alone.” Id, - a3. We continu, stating that "fu]nless the unconsiitutiouality of a statute s clear, the President {should aticmpt to resolve his doubls in a way that favors the statute, and he should nt decline to "enforce it unless he concludes that he is compelled to do vo under the circumstances. Id. We declined o catalogue all tho considerations that sould weigh in favor of non-<nforcement, bat we idedtified 0: firs tho extent of the harm to individual or tho government resulting from enforoement; and, second, the creation of an opportunity Jor a court challenge through non-enforcement (og. Mycrs). 2) Appropriations Limitation for Rules Veroed by Congress, 48 Op. Q.L.C. 731 (1980); Tn this { ‘opinion we rejected the cunstintionality of a proposed legislative veto, prior o the Court's decision in Chadha. We opined that "(t]o regard this provision as fegally binding would impair the Executive's ‘cmsiitutional rolo and wonld consti an abdication of the responsibility of the Executive Brunch, Id. at 734. Ieshould be noted that the legislation in question was pending, in Congress, and the possibility that President Carter would sign the legislation did not affect our analysis of tie comsGlutions] issu. We simply stated that, “if enacted, the [legislotiva veto provision) sill nof have any logal effect" 1d. 3) Issue Rained by Scotion 102(6)2) al HR. 3792, 14 Op. QL, 3801990) (preliminary print): This opinion ls addressed thei-pending legislation, in this case the foreign relations authorization bill for fiscal ycars 1990 and 1991. The opinion found that a provision of the bill was unconstitutional aud severable. Regarding non-cxecntion, the apinion stated that "aC least in the contest of legislation Gut infringes he separation of powers, the Prosident has the consliutional authority ta refuse enforcs ‘wnconsiittional laws." 1d. at 53: The opinion conclu that if tho Presideat chooses to sign HR. 3792, he would be constitutionally authorized to decline fo cuforce” the consituGonally objectionable scotion. Id. at 38. 4) {sues Ruised hy Scction 129 of Pub. L. No. 102-138 und Section 503 of Pub. L. No. 102-140, 16 Op. OC. 18 (1992) (preliminary prind): This opinion concluded that two statutory provisions fhat limiled the ismance of official and diplomatic passparls were uncoustitutional snd were scverble from he remainder of the tive statutes, On the question of nor-cxecution, the opinion rejected "the argument that the President may no reat a staute a invalid prior 10.a judicial determination. Id. at 40. The + opiniou concluded that the Constitution authorizes the President ta refuse bo enforce a Law that be ( belicves is unconstitutional. 5) Memorandum for Bomaed N_ Nussbaum, Counsel the President, from Walter Dellingss, Assistant Attorney General, Office of Legal Counsel (Nov. 3. 1993); This opinion discusscs different categories of signing statcuents, cluding thoso construing hills to avoid consututional probloms and those in which the President declures "that a provision of the bill before him is flatly unconstirutional, and that he will refuse to enforce it." I, ar 3. The opinion concludes that such "uses of Presidential signing storeaeats generally serve legitimate and defensible purposes.” Id, at 7. Presidential Signing Statements 1) Statement by the Siatc Department (Announcing Presiden Wilson's Refusal to Carry Out he Section of Gre Jonos Mezchant Marine Act of Jure.S, 1920. directing him to terminate treaty provisions restricting the Goverament's right to impose discriminatory tonnage dues and tariff duties), 17. A Compilation of the Messages and Papers of the Prosidents 887) (Sept, 24, 1920) (Pees. Wilson): The State Department announced tiat it "has bocn informed by the President that he docs not deem the. direction contained in Séction 34 of the so-called Meroaut Marine Act an exorcise of any ‘constitutional power possessed by the Congress." Id. The statement also defended President Wilson's decision to sign the bill and noted thu "the fact that une: section ofthe law involves clements of illegality rendering the section inoperative need not affect the validily and operation of the Act asa whole." 5 Green Haywood Hacksworth, Digest of Intemational Lave 324 (1943), + 2) Special Message 1a the Congress Upon Signing the Departmen of Defense Apprapristion Act, Pub, {Papers of Dwight D, iscnliower 688 (uly 13, 1955): President Eisenhower, in signing 2 bill (H.R. “i 6042) that contained a legistative voto, stated that the logislative velo "will be regarded as invalid by the cxecutive branch of the Government in the. administration of HLR. 6042, unless otherwise determined by u court of competent jurisdiction.” I. a 689. 3) Memonindum on Informing Congressional Commitiees of Changes Involving Farcign Economic Assistance Lunds. Pub, Papers of Joli T. Kennedy 6 (fau. 9, 1963): President Konnody stated that o = provision in the bil ho was signing contained an unconstitutional Iegislative vero. Ile announced that { “Tits therefore my intention. . to teat this provision 2s a request for information.” Id. 4) Statement by the President Upon Approving the Public Works Appropriations Act, Pub. Papers of Lyndon B. Johnson 104 (Dee, 31, 1963): I'esident Johnson also found that a legislative veto provision was unconstitutional und stated that he would treat it as a request for information. 5) Statement About Signing the Public Buildings Amendments of 1972, Pub. Papers of Richard Nixon 686 (June. 17, 1972): President Nixon stated that a clause conditioning the vse of authori by the xecutive branch on he approval of a congrossioual cotnnittee was unconstitutional. Ife ordered the agency involved to comply with "the acesptable procedures” in tho bill "without regard to tho uncangtiwtioual provisions | have previously eeferreil t." Id, at G87. 6) Statement on Siyning the Department af Defenss Appropriation Act of 1976, Pub. Papers of Gerald R. Ford 241 (Teh, 10. 1976): President Ford stated thar a commie approval mechasism was unconstitulional and announced that he would "teeat the unconstinafional provision . to the extent it requires further Congressional committee approval, us a complete nullity” 1d, ut 242. 7) Statment on Signing Coastal Zone Munugsment hwprovement Act of 1980, Pub. Papers of Timmy Cari 2335 (Oct. 15,1980): President Carter sated that a legislative veto provision was unconstitutional snd that auy aitemp! a a logislative veto would "not [be] rogarded as legally binding." a * # Sulementon Signing the Union Sration Redevelopment Act of 1981, Pub, Papers of Kouald { Reagan 1207 (Dec. 29, 1981): President Reagan stated that a legislative velo was unconstitutionsd and sonounced that "Jfhe Seerctary of Transpartation will not... regard himself as ogally bound by uy such resolution.” 10, 9) Swretuent On Signing the Nutiopal and Community Services Act of 1990, Pub, Papers of George. Bush 1613 (Now, 16, 1990): Presidont Bush rejected the constitutionality of provisions that required Presidentislly appointed board cxercisiag executive ATthority 1o include, among ts 21 members, “seven members nominated by the Speaker of the House of Representatives ... [uid] seven members onuinated by the Majority Leader of tho Sonate." Id. at 1614. Ho announced thal the restrictions on his choice of namiioes to the hoard "arc without leg farce or affect.” 1d. 10) 7. Compilation of the Messages und Papers of the Presidents 377 (Aug. 14, 1876) (rss, Grant): ‘This is one of the carkicst of many instances of a President "construing" « provision (io avoid constitution) problems) in 2 way that scams to amount fo & refusal to enforce « provision of it. An 1876 stato dircoted that moficas be seat certain diplomatic and consulur officers “to close heir offices." President Gran, in signing the ill, stated that, [in the licral sense of shis direction it would be au invasion of (he constitutional prerogatives and daty of the Executive.” Jd, In order to avoid this problem, President Grant "construfed]* this provision "orl 10 exercise the constitutional prerogative of Congress over the expenditures of the Goverment,” 201 to “imply[] a right in the fegislative branch to direct the closing or discontinuing of any of the diplomatic or consular offices of the Government," Id. adn. a ther Presidential Documents 1) APeesidential Legal Opinion, 65 Harv, L. Rev. 1353 (1053): This was u legal opinion from ‘President Franklin Raosevelt to Attomey Generul Jackson. President Roosevelt stated that he was signing the Lend-Lease Act despite a provision providing for a legislative veta, "a provision which, in my opinian, is clearly wiconstrutional.” IZ. ut 1357. The Presiden stated thas, "(Jn order that L may be om record as indicating my opinion that the forogoing provision of the so-calied Lend-Lease Acts unconstitutional, and in order that my approval of the bill due to the existing exigencies of the world [4 situation, may net be construed as a tacil acquiesccnos in any contrary view, T am requesting vou to L azo his memorandun i the official files of the Department of Justice. Lam desirous of having this doe for the further reason hat I should not wish my action in approviag the bill which includes this invalid claw, o be used as a precedent for any future Legislation comprising provisions of a similar nature,” [d, at 1358, 2) Message to the Congress on Leisfative Vetoes, Pub, Papess of fimmy Carter 1146 (Jun. 21, 1978): In this memozandum President Carter expressod his song opposition to legislative vetoes and sated that *[iJbo inclusion of [a legislative veto] in a bil will be an important factor in ty decision to sign or fo vero it.” 1d. ac 1148, Ho fucther stated that, “[ajs for Legislative vetoes over the excciion of programs already prescribed in Togislation and in bills T must sign for other reasons, the Excoutivo Branch will generally reat them as ‘report-and-wait' provisions. In such u case, if Congross subsequently adapts a cesolution to veto an Executive uction, we will give it serious consideration, but we will nol, under our reading of the Constitution, consider it legally binding.” 1d. st 1149. Historical Materials 1) Statement of James Wilson on Decembar 1, 1787 on the Adoption of the Federal Constitution, seprinted in 2 Jouathan Ellial, Debales on the Federa] Constitution 418 (1836): Wilson argucd that tho Constitution imposed significant — and sufficient — restraints on the pover of the lgislatco, and that ho President wuld nof be dependent upon the legislatins. In this contest, he siated that "the power of” the Cansiitution was paramount to the power of tho legislature acting under that Constitution; fori is + possible that he [ogislamue ... may transiress he bounds assigned iL, and at act may pass, in the ( usual aude, notwithstanding thet trunsgression; but when it comes to be discussed before the judges, “+ when they consider ts principles, und find ito be incompatible with the supecior pawer of tho Cansitution, it is heir duty to pronounce it void... In the same manner, the Prosideat of the United States could shield himself, and refuse to carry into eifcet an act that vials fhe Constitution.” 1d, at 546. 2) Lettec from Chief Justice Chase to Gerrit Smith (Apr. 19, 1868), quoted in J. Schuckers, The Life and Public Services of Selman Porlland Clase 577 (1874); Chase stated that President Tohnson took the proper action in removing Sccretary of War Stunlon without Senate approval, in ight of Johnson's beliof that the statutory restriction on his removal authority was unconstitutional, In tis cegard, Chase. commented that "the President hil a perfect right, and indeed was undor the highest obligation, to remove Mz. Stanton, if fie mae the removal not in wanton disregard of a constitutional law, but with a since belief that the Tenuro-of-Office Act was unconstitutional and for the purpose of bringing the ‘question before the Supreme Count.” 1d. at S78. Congressional Muerials 1) The Presidents Suspension of the Compeiition in Contracting Act js Unconstitutional, LR, Rep, No. 138. 99th Cong., 1st Sess. (1985): Tho House Committee ou Government Operations concluded hit tho President lacked the authority to refuse Lo implement any provision of the Competition in Contracting Act. Tho Comittee stated that, *[tJo adopt the view that one's oath 1 support and defend the Constitution is a license o exercise any available power in furtherance of one's own constitutional interpretation sould quickly destroy the entire constitutional scheme. Such a view, whereby the i President pledges allegiance to the Constitution but then determines what the Constitution means, inexorably leads to the usurpation by the Fxecutivs of the others roles.” Id. at 11. The Commitice also stated that "[(Jhe Bxceutive’s suspension of the faw circumvents the cobstiutionally specified means for expressing Executive objections to law and is a constitutionally impermissible absolute veto power.” [dat 13. + 2) Memorandum from the Congressional Reseasuh Servios tp the Commies an Government i Operations copcerning "The Exceutive's Duly to Enforce the Law" (Feb, 6, [985), reprinted in % Constitutionality of GAO's Bid Protest Function: Hearings Befors a Subcom. of the Tose Comm, ‘ou Ubvernmient Operations, 99th Cong, 1st Sess. 544 (1085): This memorandum stated that the President lacks the authority Io decline to enforce statutes. The CRS argued that "[flho refusal of the President to execute the Jaw is indistinguishable from the power to suspend the laws. That power, as is true of the power Lo amend or to revive an expiced law, is a foglslative power.” 1d al 554, Cases {uot included in the submited terials) 1) Myess v. United States, 272 11S. 52 (1926): Ihe President refused to comply with - that is, caorce =a limitation on his poser of removal that he regarded os unconstitutional, even thovgh the question ‘ad not been addressed by the Suprcine Court. A member of Congress, Senator Pepper, urged the ‘Supreme Court to uphold the validity of the provision. The Supreme Cow vindicated the President's interpretation without any. raember of the Cowt indicating thal the President had acted unlawfully or inappropriately in refusing to enforce fhe removal restriction based on bis belief that it was unconstitutional. 2) United States, v. Lovett, 328 U.S. 303 (1946): The President coforced a staune that directed him to withhold compensation from theee named employees, even though flc President believed the lay to be ‘wnconsiitutionsl. The Justice Department arpued against the constitutionality of the statute in the ensuing litigation. (Lhe Court permiticd an aitomey to appear on beh of Congress, amicus curse, bo defend the statute.) (3) INS Chadia, 462 15. 919 (1983): This caso involved the withholding of citizenship from un applicant pursuant ta legislative veto of an Attomey General decision to grant citizenship, Despite a Carter Administruion policy agaist complying with legislative vetoes (see Carter Presidential memorandum, supra), the executive branch enforced the legislative veto, und, in so doing, allowed for jodicial review ofthe starute. As with Lovett, the Justioc Dopartient argued igains the consitutionality of the statute. 4) Morison v. Olson, 487 U.S. 654 (198): The I'resident viewod the independent counsel statute 45 unconstitutional. The Attomey Geseral caforced it, making findings ud forwarding thera to the Special Division. In litigation, hovivor, the Justice Department attacked the constintionality of the Hatuic ond left its defense t the Scuate Counsel, as amicus curiae, and the independent counsel hersclf. 5) Freytag v. Commissiongz, 501 U.S. 368 (1991): A unanimous Court ruled thet the appointment of special cial judges by the Chief Tudge of the United States Tax Court id nat violate the Appointments Clause. Five Justices concluded that the Tux Court was x "Court of Law" for Appointments Clause ‘purposes, despitc the fact that it was an Article | court, so that the Tax Court could constitutionally appoint inferior officers. Four Justices, in a concuatcace by Justice Scalis, contended thal tho Tex Court as & "Deparument” under the Appoiniments Clause. The concurrence stated that "Court of Law” did ot include Articlo T courts aod thet hc Framers intendod 10 prevent Congress from havin the power both Lo create offices and to sppoiut officers. In his regard, (he concuzrence stated (hat "it was not ‘enough simply to repose the power wu cxcente the laws (or fo appoint) in the Prosident; it vas also , mecessury lo provide him with the means to resist legislative encroachment upon that paver. The {mons solccted were various, including a scparate political constituency, to which ho lone was “responsible, and the power ta veto encroaching laws, 3c0 Art. I, § 7, or cvon to disregard them shen they ore unconstitutional.” Kd at 906 (Sealia, J, concurring), 6) Lear Sigler, Inc., Kesey Products Division v. Lohman, 862 F.2d 1102 (9th Cir. 1988), withdrawn in part 893 F.2d 205 (94h Cir. 1990) {en banc): The President refused to comply with provisions of the Competition in Contractiniz Act that he viewed as unconstitutional and thereby allowed for judicial {resolution of the issue. ‘the Ninth Circuit ejosted the President's srpuments uhoul the consitutionality ‘of tho provisions. The court further determined tut Iear Siegler was u provailing party and vas entided t atiomoys' foes, bosause the executive branch actod in bad faith in refusing 1 exceule the contested provisians. In this regard, the cout stated that the President's action wus "ulorly at odds with the texture and plain hnguage of the Constitution, because a statute is purt of the Lav of the land that the President in obligated fo execute. 1d. at 1121, 1124. On rehearing an banc, the court ruled that Tear Sieglor was not a prevailing party and withdrew the sections of the opinion quiz above. / { { 4 -0929104. XT BT —— VF SORLEL TUE PIETER Amici imiim— pre fit RS 2 + me mou, eo prion oo Rohan phn ye 7 pow wre Eel Bene, sor 20 { 0629106. THT 4 s COCONUT GROVE. FL Eas Ww C4 bull of tho Lefondait 1 JACK A Gon DT RGER, £90 BTTERGURY, GCLDBERGER & F155 EH 260 ASTRAL TA AVPALE SOUT I SUrTE 760 I ALT PALN BEACH, FLORIO 33401 551. 558.8300 in 15 ALS PRESENT. ALLL BRETF. DIRECTOR OF MII Thi 3 on ELA D1YIS10N, wv E57 ® a 21 2 2s 2 7 25 LY 3 1 Tune x 2 mms; PaGC 2 IRE DUNINATION 4 4 BYR. TEIN 7 NO IXII HITS MARKED 0 . Ns w n 12 3 vage 2 " » w by p 1 2 Flaride a= larg, Nn Thc above cause. : — + { ; asz0108. TT 4 18 a hak you. 1 tay cal sou 2 A nn » 0 EEE 1 going tn ase you a fos 2 questions, soworsl questions tacky. IF oT any Time you 25 want to take a Brak. You JUST 18 rm Aen. Okay? I a oa » 0 IF you at ny Line don't urdorstand ano oF 1a questions, el 11 you just please let me know: fi ove a Q Aad if on any Sin you're nat fooling weil 4 or somthing ke at. you'll el us, right? s Aves 0 a. 90 you feel okay todays ( ’ a Tas. * 8 a. Mot taking any alcolui or drugs or anything 3 1 ke Unt, righ? 0 aw 1 0. So you rac) rasny to avs your deposition ©? tae? 1 Aves " 0 EEE A is your dcess? 1s Am corrently ving AT ay aunts house and 61 dont Kieu IL fT the top of my hezd » 0 mare wu we Ain agiter w® ow is your ant = A EE 2 0 Ww ele in living shore 2 A EE oie age 4 Fi GAP2104 TAT 2 0. Anyons © se |iving thre? 2 A he » Q The conteme mewios Wat your mother +. lar 1 against you futher reazrding your fifty million dallar 2 laws t egalnst Jetrry Epsloim says that you ive with 3 yeur aunt and wets and ave bixn vig hors: 1s Let 4 correct? N GW long Fave you boca ing eit your a A Since wy Father Kicked mw out . What ons Thanksgiving oF this pact yew? » A Yes, wir Pp a 0. Okay. DINE did your FireFightar boy { vz friend IER 5cr. sn ApaCTOVIE For Tho Lao of 1 yar a A Ho. sir. He hes an apsrtment. but by 15 himselr © 9. Did he ger an apartment for the Ta oF you To PR wo fre you planning ta wus 0 with nin Es A Maybe ane day in the future. p QB you ave w plan Lo wave in with bin 2 presently 2 PR 2 0. Have you besn To ae apartacnt that you ard os ER =: ised ovina in wanerher? Page > Id ~0020104. TXT % . A 1 have been Lo the caartment. 2 a. wera is tha 3 + I s a. Mave you spent the night, aver hn? 5 A ar 5 bo you know the sires ure? » A dae a a tant your sister EERIaTing on 11ving saith you and 0 PE n 0. EE sou know that this cont cass 16 8 12 criminal prosecution. curt vel? 1 A Carron. 1 9. od you know thar. it's a criminal { 18 Co you know that? Ao 18 ou agree that curls u very sericus 0 tte? 2 Aw 2 0. and ymirre aero Iu your lawyer 2 wr. Luopold. right? 2 Aves 2 0. AM you krou that 3. Leopeld recently 3 Filed o lamwit in federal court against JeTrey Epstein, 5 1 seeking firry miltion dollars. 2 14 LOL: Lot me just object : ME (ec wo vrstruct you. Fmyshing that n you hava learned Through conver sat lun setwsen you Page i It o0z10. TF B ant an ara prrtocton. 59 IT You Kick a of ak ‘ aneaer. Sul iT Ue unly cay you kno it is s Fv our discuss, da rot anos that. ° question. BIR. TEN: n PS [pe —— 32 Filed 5 lamsuit, in fedora] court on your behalf against 3 JaTirey Epstein sasking fifey ei ion dollars 1 IR. LEWPOLD: Same objection 5 IF you Know €ha srsaer Le Ui uulside of 16 our discussions, you my meer, IF 015 Ue wv only my Ut you keen the anseer is Svnigh our 5 discussions, 6 nos ansusr Ut yussLion. w» HE WINES: okay. . 0 AR. LEOPOLD: Actorney/cl ent. privi loge 5 21 3 MR. (FIN: 22 a. You can smsuer the quession iniose —- Is WR. LEOFOLD: Some object on. 2 WRT Lot ws Finish. os UR. LEOROLD. Excuse mm Warren ' TEM: Mo lor re Tinisn » BR. LEOPOLD: Lewis, ve’re nat going fo. ds Y that. a LE: ty am 15 not Lewis 5 I'm going So Finish ny qsTion. Okay? . WR LEOPOLD: Go nox amcor wre you sor ' from me 5 wu, bn ) rage 7 ( -coznine. TXT fl Ro rbor Tran conzorsulives kal you have Fad 10 wilh ie. Leopold — 1° nat asking about ht —- orz you 0 were Uist tr. Leopsic has filed a lsesuit in federal 12 curt seckiag MITE million dol lars From Joffrey epstoin 13 an your behals? n HR LEOROLI: Sie alu ror i Anything hat you lear through it OAS INS betwen yuu and me, fn nat answor EH Those ara protectid. IT yeu know Uieoudh any. 19 Our reatn of knowledge. you may ances it THE WITHESS: No 0 Bw Te 2 ©. You have no idea Tht 9. Leopold Filed a 22 fifty million-dollar lansuil on your behalf against 23 Jeffrey Fostein? 2 GR. LEQFOLD: Sama aly antion L 2 80 wt ansear hal question If It's thregh 10 1 discussions thal you and | hed. Quisidn of thar, 2 You may ansaor. So db nSt answer thal wuesticn 1 3 that i the only basis by eich you understand a That answer 5 THE RUNES: 6 BY NR TEIN: ‘ 0. You didn’L know thar 8 WE. LEOPOLD: Don’L ansaer that question ° Fgninst. it's ottorney/cliunt privilege. Any 10 information you've loaned trough conversat ins i UeLneen yau and | arn pratocted 17 you kaon it 2 through any other realm, you may ansver 3 WR TEIK: Are you going to say Hit Tar ; Page 8 { Ie nur N au overy cuestion In the depus’Lizn. Ur. Lacpotds 1 TC LroRoLD: thon you ask improper 1 snsifons. 1 Tho Zhe thous, ti, proper oe. » We TEN: Yours going vo srop your w sposking digestions sighs vou Shag? 10 WR LLOSOLD: Wh Ure proper ©» WL TEIN: You mood to step your spain 2 objections Ps Lot's cont nue 2 RLF: Bown, you Just asked ma 2 winskion ind 1's going to state 1% an the 2 Faenre -- n \ WR. TEIN: You need to stop your speaking y : abjecsions Cher your rules % 3 IR. LEOROLO: Excuse me. for the rocord. . Count sekon ws + uistin 1°11 seats the 5 PR v 1 gai Lo be armering thi may hr tho ) doparition So long ws Uhers's irproper o Fauntation and pradicarn acken by the attomey, | " SH Rated ng Eien | west rd 10 appraprints. IT come! wishes to ask an " aperope ata word quostion with Lhe proper 12 Foundation and prodicate, | wii} certainiy allow IN the client; to amr the question " WR CoLCBERGER: wry n't you fuse star I AeEDrmay/S1 CIT pri ga an just. be dona with 1s ie. RRR 1 at the acon Lo be Page 9 7 N or “ompsnaa txr 10 TEI You ww So weste Lime 13 ona » you went £0 do. Yau wa suppor To bo ers Unis » wary ans jou Leal ly arske the deal, The 2 agreament Th you hud with us IF your hearing gor = cancel isa. 2 Bul ists mave on nd wayho you || step 2» SPIE ING hls deposition 2 . WR. LEOPOLD: | think tha rocord i vary 2 Clear anor vs ssand thus ur 2 15 thers a racorfing Saen of this a ception s THF CUAL RPORTER: vos . UL LEPOLD. sr mak sur ts { :: preserved \ 8 BY MR. TEIN a 0. Cote Ehibiz 2000 wll, borat you dv 10 noe. JE. > you aware tat a losyer named Jor<roy 1 Worn Filed a bausait on your baNOIT, $05 or 07 » MR. LEORoLD: oajaction x Any conversations that yeu and 1 have md regarding Tan. IT TST 15 Ue only sey by which in Sou undarssand box to ans That Question, 56 not answer. 115 atsorney/client privilege. 5 wi 1 ” 5 any oomersations yeu ray have hed with the ® artarvey from Wiawi. That siso sttorney/elient © privilege. fod I'm assuming n 1 TEL. You're acrustly wom wot the n Slurnayietient privilage 2 BR. LEOPOLD: 1% sssuming counsnl is mot Fone 10 { az9100.TXT 2 ssking vou ta diigo atterney/el wt = 24 WR. EM. 0 course not ave Tem: , oI va sei asoco conn mortem PB ANRRTOPIGYE I wadow of Guo) BOSH XL AE TERRE WY FOE HE REWER STR Bele Wie MEET RT fl WR. LROPOLIL Sams ons 10 s WR TEIN. Ue ve heard the objection 10 s tim alr 7 WR LEOROID: Gans, cxie ws. 5 WR TEM: Just say stearney/cl ion ° privilogo. Stop INESITUpEINy my questions ® WR. LEGROLO: 1m snitled to mks an " n ObJSSTIon Tor Lhe racord, Shick 1° doing, ane ( 2 10 me te sam oojoccion. And i it cals for 1 witorney client privilege. any conversations you 1 a1 1 hav Fa, do not: ansuer the question 1s And 1 think that IL might be appropriate w 5 opposed tof | think that. vould bo mr "8 appropriate Ter. this deposition 19 em. TEIN 2 PA a a hk yeu 2 In fact, you know that Wr. Heruan held 3 24 press confurence after bn Tilod tho Irty-m 11nd. lar 25 lows on your bahaif. don't you? rage 1 i ~ovzg101. 757 " \ A ATE t happened 2 URGES TE TER ora 3 don'L you. yes or ne? ¥: PRE % 4 In feet Tels go Lo Exhibit 20-01 5 HR. GCLDICROCR: Loos bebird you. You I: 2 sew it 8 wow To v Q lave you svar seen Su picoure bafora? » A ves n QI Ui a picture of your father, your 12 stepnother and 3. dorian St io vss conference 13 rug ding your lausaiv? i wer don your 3 nu WR. LEOPOLD: As«ed anc znsumred 12 jection 1 We GOLDBERGER: All right. You can =» abjass. Yor rv faavsenting 3 el Lnoss hora, 2 ir. Leopold. Yau ca: object ar privilege grounds 2 Vou cannoL make legal shiosrians. You have uo x Staring Lo do so. « 1 LEOPOLD: 1m guing Lo ook them anc = then -- is 1 IN. COLCBERGER: We re -- 2 IN LLOPOLD: We re going to leva or wa'rn + appropriate. Thera s mo rowon to lve Lis Kid Fags 12 Fi 0029101. TXT 5 of demoaner IF you want w have this kind ef © dencanor rithm 7 WR. TEI You ara GRstructing this i aopos tion ° We GUIDBERGER: hy den’L yeu guys go i] outside and [LSE talk Apaut —- n AR LEQPOLD: She —- her Ja is very 3 ditficult and she's not going to be abla to take 13 us both talking at he sow: Lie 1 WR. COLCBERGER. OFF the recor iH WR. LEOFOLD: Wie'ce not going off the 6 recard, Jack. Ee're mat Jack. Hur job is very ” AifTiculL. 1m going to maka the rocord 0 1 don't think iC is apurepriate, especially 9 in the smal | con*inos af ths roun, tw be wry ~ a 2ggrussive with this young ady. 5 = WK. EIN Thet's nol happening. Stop 22 stop actual ly -- 3 NR. LEOPOLD: If yau'ra gaing Ta Knterrupt 2 me, #0 going to cancel this deposition -- 25 WR TEIN. Step misreprosorsing 10 1 THE COURT REPRIIR: | now ort 8 & Line. z mw wLier who It is. 3 LEOPOLD: | =hink we're going to Tako a E] broak Perhaps you might Kart te talk to your H co-counsal -- 3 WE TEIR | don't noo To Talk Ta him. : WR. LEOPOLD: But we'rc going to foke a u Break Page 13 i { -0g0g104. 101 § s WTC Kat teking a break unless che Ww ©lUness nascs a brosk, n You're obstruczing tais deposition. Tud. 12 we reopowo: cone on. [I 3 You all wi Ly continue in this u deeanor -- » WR. TEIN: You're ohstructing tha 8 deposition Step ming spesches. Ue ce not. » discussing this WIth you, is questions sre to i your Glisti. Go take your Tiva-minute bruak 1 WX. LLOPOLO: Fine. We need to maka curs 20 the record's clear SX clean Bl Awd | went to make sire es | ve already 22 asker youl -- | Know that you're ore o® The BST In 23 tom -- TAT This Sudio -- this nesds to be Py prosorved. Okay? ( 25 WR TCI: Go Laks your Five minute break EH 1 ue. Leapold. pun. 2 Yau were suppased ta bo hers a nine 3.3. Fl i5'8 now aTLer tao. Taka your broak and come 4 back. 5 SR IFWULO: Okay. IT the demeanor keeps 5 Up, ws 11 ok be hera doyord these “Iva minutes. 7 WR TEIN: Toke your Srosk and come back. B UR. LLOPOLD: Okay. So | suggest taet you EB) retax. 0 WR. TEI: | suggest thal you take your n bro. 2 WR. GOLDEERGER. Let Thom take that 1 Fivo-minute bre, age 12 4 0320104. 7X7 E 4 WR. OLFOPGIE: BUT | would suggesl that you i take veep breaths. WR TEIN: Sugest wharcver you vant So ww take 5 brook. 18 (Thereupon, a “oceas was Laken.) wa EN: 2 0. [J so cares shor giving restineny 21 today a your disposition ix somolhing very serious, don't 2 your 2 A ves, “ GTR EN SR 413 2 [a 1 0. Let me sho you 1xnibit 31-001. Can you 2 cead that out loud, please? 4 0. WII you read thar our loud, please 5 Aon s 0 Therk you 7 A. hanya S50 i EE BEIT TDI A re i is bl BIE SSE 2 BHILINAVE ERISA ERR Like after so lang ww 10 im rey... well ya well ne ul arin Lely havi make 1 Alans for sure. because | miss u Tons Tus a wll ivn and 2 a0 00 m0 i 10% yuu...u ps. | leve ur default pic 15 aiggee. Mush xo 1" Q. Did you sond Tat ressegs lust nek ta a 15 Triend of yours en syspace? ® A wouldnt kan. There's fa catss ond I've 17 deleed that BySpics. so -- ) Pago 15 ‘ wigs xr L a. a, We v goity to Lal sbout thet in 8 second B nay ” a mg » 8 4h ve rei my pion. 24 Triend of yours on MySpace? * 2 HE HEE SEE 3 a TSiCE Tweed WSante” a Su BEER 3 Ae Word BETIS RETIVY 1 SNPS end * A dese ( d Q. Do you Find the term ne -g-g-a-r offensive? % 8 A That. nat siywhore in there. . oat word did ou me in there? 0 I. LEOPOLD: wre are you referring to. n Comal? eres 2 piu weds 0 viure. » ML TEN ont aks a speaking objection. “ TE MESS: Are you referring " — wn wor: no JE cont cor = ww 0 hi tk go the cuasrion, nom wn ® 0 et estrone von asking J 0 WROD Sho doom sk questions 2 ponding? wows, To ope 18 i Fg 0823104, 1X1 . 2 o I ec is tro ost ord on tora 0 20 the cert ar your messags bufors she costing? = A Wigan Lm» , GQ. on you Find that ern offansiva? 2 A Wo 4 6. LEOPOLD. can you spel | it For th a eocord, plese 3 THE BI IRLSS: Ne 1-g-g 3 WROTE Ma, no, na You are wo yairg ' 0 Le siKing yueskions. 8 We IORALD: 1k nol inking questicns 9 I'm asking for the racard tho Word to be ps!les "0 hocause us don’ C lave a video here today. " MR, TCI: Thess GXAIDITS are part af the { Is —— in We LEOPOLD: Gell, it's not marked an an exnibic. 1s WR. TEI: Sop interrupt ng mo. ® We Eoopld. | have norced and identified as an » exhibie and you will go it © WR. LRIPOLO: thers has boon no i dant Fication of this document in the record 20 WR. TEIN W Lepeld, stop interrupting 2 this dopas tion 2 UR. LEOPOLD: What is the mhIDIT nurkser ”» srk for identification” 2 HREM: 51000 2 IK. LEOROLD: Do we Fave copies? 15 it or Page 17 # 0629104. 747 { 7 1 the record snyshore? 2 evim. TEM 3 a tet me ask you [I dia you in rac 4 Arie yaw Tied thy sssie about this epesition? 5 a ves. 5 © Sorgen pRBMGNGEE ROETRC ING TPIS so muse ESE, a A we fA © Hocaure yon think This deposition [3 stupid 10 Court sohel-t. dul you? n AoW 12 Q Vou vrata That to your Trice. din'L yur 12 A Yes 1a 4. Tou Think Ul court is supid, den't ya 1s A In sere cases ( * 0. Ad you think that court is hull 5 hit. d dort your 10 som wn Q And you kink this deposition is hull 0 shin dant your 2 am » 0 You wrote ta 1a your friend, didn't your a WL LEOPOLD: Objection. Asked and 2 ansveced 2 We TEI that 5 nat en objection 2 1m TE 2 Q Vou arate that to your Tr end, didn'L you? a GR. LEOPOLD: Bhjactior. skal sed a wrsnered, or he Fourth time. fags 18 Ie 0520106, TXT : s Wa TEIN: You are impeogerly objasting, 6 Mr. Lsuaold. Yeu sve na gronads ta ohject. And 3 That's 0 an oly eetiv e FORO: IT 15 an objection, 5 WR TEN: Then Torminats the deposition If Ww OU THINK iL been asked and answered 1 WR LLOPOLD: Counsel. | om no precluded 12 fram just making an ohjoction Lu Lhe Torr of the AH auestion, As the courts wall know, and it you tl practice tera 1 Koss Palm Beach, nany of the as Judges raquire you fo st the cbjscLion ith 1 specificity, And | will da that. and if you i don’t yank To to, you can make the record. KUT | ® will do trac. 18 We. TEIN: Here's wat we'll da. fen Yu 20 an 1 will allow you To reserve an o3jecticn wo ( n TE FY rnerwkse, ail you're doing is cbatructing 23 WR, LEOVOLD: | won't do Lat. 2 AR. TE: OF course: because you want to 2 oastruct a 1 WR. LEOPOLD: &F1 right. ZB TEM ® Q. Saige. you Think Tal yiving Lestinany 4 Tosay. usr vath, is bull shoi-T, dort you? 5 A he © 0. Ad you arote hat ta your friend an 7 dySpace lass week, Alon’t you? ® WK LLOFOLD: Objectiva. Asked and Page 1¢ ‘ cesta. it ! s ensverad w TE WITRESS: He, | did rar wa mn 12 Go vou dient wale Lhis exhibit? " A 1 wrote tha. bur tf du U rite hat you amin 15 4. You woe in his sehibie. “1 gor som 16 stupid court 5 hi Fan tho 200 Bull shit iden 7 you write wir ® Ae 1 Q Korarring to This degosition, cide © yout » A. Rafarricg tn the crt. | ws lotr 21 informed hat st aus a deposition 2 @ 1m ger to sk you sone questions mow 23 about uhal happend hen you kent To JT Epstein’ hause 20 hres years spo. Okay? ( 2 A thn 2 1 a. GAL STE RSE Vea yeu, sre anne BWA So aly 4h BBLELOE IRM WA Share DIV § Sous SATE GLEE RE Aen as0s 5 60 1 ARE L] Ba News * UR DIE SRI IRAE She pe z wh Nobh AES SENESETEE pave REE TOE Whkh din # Sid EE rR ans Te Sporn in mspatakn pus com arty oy sae JI » wa 12 0 Hom Ue civil corplaint ches you itor 15 against Br. Fpstin Tor TefLy million dollars alkaged Fags 23 ¢ ~omrsins. ixT % 14 thst yoo were ual ly stucked hy wat bapnonod Anen yoo gor there, 1. awe ” 0. ern you totally shotkud by vit tuypened 0 aben yu ut Zo Exstein’s house? 1 A ves 20 a ou deer sxpect Lab atl. did you? 2 A to » WYETH RE beens idea php RED IIT 2 [SE ROT BOTT GE Sin hese pia 2% ECE ITO a Snag as We ALL DUTLEHRNG Was ens ong 03. Ps PRE a & Rod ony L 3 © serwregw pes rsszsser BE SSO (OPS 0 Fo AIR AT OT BSE RIES Ros 5 I d (6 ATARI Sen Epatnia & RUSG Pl pe be pe ——— Bed SUCCES EE 0 a wo n © oi Zook [ler ry to convince you ra 12 nga in any sal Arty with Stine 1 Alo “ 0 oi aruony [EEE covery try to convince 15 yor to engage In any Sexucl ac.ivily wish (patoin? ® A dent aon who Anon EE = ” Qo you havo a friend Anttory? Page 71 I'd ~0e2106. 1X1 { » Am »n Re DRaps PEROT FOI ROTH SRAPSLOAn Sulplisg Sl Har ASO GALE SR Ri sed Em) GA. 21 Be cma AADC ERG 2 Pr = ES A 5 wn RECTEE PIII = 4 ECE 2 Q. Vowra sure that lot ms ask Uh question 3 san a ound irs LL ATER BOWE qT Be wd eons a, GSESLANE BA RETA Ep 3 ( ? We. HORLD: Obyoc ior. Asked ond » amvmered 9 TUSOESE Fee fod | va alrondy 10 ansoarcd that a baz lon Lines ney TEM a2 0. Kes coaching you ow. So 1m gaing to ask 15 the question " IRL LEOROI I: Counce, Ivo mide sin xs ouecLion for the record . AR TER: Stop spusking. ” BRL LLOPOLD: | ot. going to stop © specking. Yau can't. INEOrFIOE ho Whi | m wing » the record WR. TEIN You're zoncaing The witacs P) VR LEGPOLO: Counsel -- 2 TER Stop costing the witness ‘ coger. mar ¥ 23 BY WR. TEIN: . 2 o [EE er no ask you oe 2 Wr. LEOPOLD: IF you sonkinus ta ! We TEM: than Snnorri ng my eestiars, ’ UR LEOROLD. 1 vou de it one nore rim, 0 oem tem . lL —— ; 4 rs Ieee shi Fon AE » JT NR 1 yori Bpontnams zur etther foMlomy 10 dn w tie ser " We TEN: Cate dean, sir 0 Wh. LEOROLI: trust ae, 1 sary calm hors ” Spon nei dn, HE = 90% Caring So Narass fer In the demmancr that a ww. En: fre you donor = WR EROLD: Ther you. 1 an, ) bag 23 { { e108. XT % ) WR TEIN: Sten misrepresenting The rocore > and cal domi. 1m owing Lo ask my question 3 stan it 4 am TE 5 a I. . IR. LEGROLD: | Wink Lhe record is ory, H crear 0 IR. GOLOBFHGHR. Lok me Just lorry a SouTalNg. hen you object ta tho form of © 1 RUGS D7, yer NOE INSEIUCTing Lhe wi Lows not + AR. LEOPOLD: Mo. And I'm or pking char 2 ahjection: only on atturhuy/cl inl privilsge. 1 RTE X11 you stop sposking wes so | » com ss my quesLion? Are you cone? ( io Okay I'm going to ask my questica. TRE ww 0 Liston, NE -- ® UR. LEOPOLL: Hold on Stop. 2 I"ve Youn dong this far 20 plus yours an 2 ave wa a 10% of utturmuys, but 1 ve oor had an 2 experience | ike This were |v -- 2 We TEIN: Stop your sacccres. os IR. LEOPOLD: I yau continue To dp This. 2 Whether ITS wth a0 ov with my client, | will not » 1 PUL up ith [Land | don’t. nad Ta put up WIT iL » Ang 175 nol sppropriate. Ard I'm sara we B Baldor gat kas al | nis. beceusa | know that he A wouldnt da thes. Su € pill iL put up ith i. Pui 24 I [4 0820104. TXT s And | TIRE ITs ighty ineparepriste ta ca this 6 with this ch i1e SISting Nara. the say you're 7 acting, primarily owns mo, ane | NIT ROL put a up win ie 9 WR TEI KIT you Flease stop your specch 0 so 1 can ask cuostions? n WR LEGROID: Sa long as you ac » provessicratly, | will do so. Bu if yon continue I 0 do it this way. | m1 leave. 1 WR. TEIN: Suit yorsat as memo om ® or I SO TATE ot te TASTES Remon snc BE HGD WETS N fi JE SERDEUABI Rysaienn Epaus ind fons moneys, 1 I. LOPOLD: Ascod and arsmered 2 GjucLion. ( a [AR — 2 THE GORI AHORIZR: Ko, | did not a2 Rial snd A 25 WF bere ash EGER TID IEICIOE DEBE yaue ES 1 SBI Pn hy es OGASD z wees edd ead il SLATES a A dames 5 RAS OTIS ® wo es 5 doa VRE BSI SILT Bi : 3 wo ded » BE ARE SRE BRATTICE S h ne BE So 1 ER Page 28 { ~owranne wr H a Fd a CBE ACE Sa PE BE SAUTE A GORGE BEBE RE a Ems \ 3 OB yunouch da ERIE ERIE 61 DSIRE Seer a EI aw TE BOTOR Fonrant to stats ELBERT THT EEE TTF THON rs 6 KRUZ E EO a Va BIER Rese as BSBA iL BO SA REET SOE BA ER 153 mw Gl WEE ERE ES PERE rh ads » Ao REGIA BY SE SY SECA RRA Sabin BE EGevOr nine athe WABIIGIE SOY Ei 3 Ai Vesy { 2% BW Vous ewes SARIN TITHE = 1 Aw 2 QAI Tig Lot me 93k you tao inal areas 3 Or questioning abuse this and we 11 move onto Seriethiny © alse okay 5 Ann ves. 1m sary. 5 Re ESATO EO wd lsc 0 RGR AIL ETT ne meea yma eni Thi BIRESIG TO DORSET [FY SA Bes HUAN © inn EAIAL AEST a" AW a © BEES ed i OE 92 ERIE Ene eo tant WO CDTIIG TREE FE ASCTES OPE mips dG EE IS RYE BYE Ia 0929104, TXT k 14 AT setae mie = wwe ax I ol So A OE TE JRETEEESR 008. hamonOr MIDAIN AED DENTE RAT wwe uw ar 2 —_— BH. wars 1 the other girl in 21 the car vho you rede ver with to Epston’s house? » «I ” #0 ws the other girl a the car ith you 2 hat day? 2 A 1 honestly dane kaon «2 1 Q. Had you aver seen er arora? 2 PEE ( 4 a. You tald tha police that aon you rade wer to Epstein’ you ud no ides wha ste wns, right’ s a Gorroat “ 0. Yeu sald the police that you didn’t iow 7 ber name, bi she kes Like rally dark, kind of |iko a & Spanish girl? 9 Aves 10 0 Thess were you words. righ n A es 12 4. 0a you ok kaow ahi sha is? 1 A wa sie " 0 so it wen fi tho told you so Hie shock 15 your age to JufT Epstein? 3 A ves, ir ” [EET I Page 1 i ~ (920104 TXT 1] TE SN Mais USE STEN 10 BE Shen El 0 AHL Fig. Loris AIK Tur a minuze about 21 hon yeu Ties mee Jefe. Okay? = A swe 2 When you First mel JIT he tried to find 20 oul how ald you sere, right 2 A Excuse ne? ax 1 (3 WAR) pot CE CEE 0 BS To EEE HEH 3 BI ETI hac SEATON WN AER 5 0. During Une massage Jeff asked you hay old 3 you sere, carracr? ( i A Yes, yes ~ s ow hadn't you alreacy sold Jats 5 assistant. the ons vho valor You LpsTe 1s, Lhat vod sens 10 ta cotlege an ld just moved down here From Ohi? " A 1 mover spoke to Lie lady 2 0. De you want 0 retaNK tral ase u ME. LEGPOLD. is Tar a cuostion? oar em: 1 © Wn you gant to ruth uk hat answer? 1 A. Mo. 1 dicnT really speak with hr that Ww moh 18 0. Da you war. Lo try to refrash your rery 19 on thar » BRIEWO Du you teva something ta ” refresh har remary wit? ” WR TEI: Do you want th stop making Foch 70 { ( -osznoa. ie . 2 speaking ouwtions? 21 We ILOPOLD: No. BUL Lo refresh sonsona’s 25 memory you show thom a document EY 1 WR TCI: 1 Knok bon Lo do this, 2 HR. LEOPALE: Thon shuk bur 4 document, 3 HR. TEIN. Stop speak ng a me ILOFOLD: 1m nol. going to Sop 5 speaking. 1's gaing Tu enrtinue wo nake the 5 rund 7 WR, EN You're obstructing. Ploass i] 5.00. 5 NI. LEOPOLD: I'm nor chatrucsing. BL IT 0 youu want €a rafrash her resol lection, yan ned to n ston ber someLhing a the foundation end the predicate of that fuestion u WR TEIN: Are you done? Ws MR. LEOPOLD: 1 am nor, Thank you. 16 avam TEM 7 Q D3 you want ta try to refresh your memory 8 an To aheTher you had any conversation wih the asm sho 19 saiked you upstairs a Epslein's heuse ir which you fold 20 fer hel you uit to col lage and bud just moved down fron 2 ohio? v2 WR. LEOPOLD: Cbjection. Dhject to ie zs Yorn of the ywstion. Lack of Foundation and 2 frodicate 25 BYR. TEIN: Page 20 i { 0920104. TXT % 1 A. You ean ansuer Uhe question > A sure 5 0. 1s thers anything that meal refresh your a memory that in fat yuu told Mr. Epstein’s assistant. Lic 3 one who walked yor Upstairs, Ul you kers zo cof lege and 5 you bud juss moves down hora from oniv? 3 A.) don’t remeuer saying That, but IT you -- 8 1 don't romembor saying that myself, so il Q. “hat would be a lia. right? w A No i really don't romombor. Lig AGS OTE Raat WALA ETRE. AT Ohm GETEET. REY Ae ESE " @ Ue you remcsber Detective Hichells Pagan of 15 the ol ice Department. Palm cach Pol Ice Deparinent? Is ® A Yas h 7 Q 69 you roms you spoke to her? " A ves. 19 0. Du you remember that you tala atest ivy 20 Pagan EHMANRTIN SSO SHOUT i SEY TRE CERI EEE ya a ACERS CL J di Ee JE TUE reat Sheds SRT IE BH CSGERRER THVT] BN Ios IRE 1 E23 Q. And do you remoaber tolling Detective Pugen Ed 1 thot shen you lied ta Ipstein about your age that. yo 2 sid it really fast so Epstein wwuldn't realize you ware ER « A Ma, | den’z cemorhor saying those meres Page 30 ¢ son iT N 5 axactly fo hor. ITER A Trier thew btgld # EpLlB JES ’ J —— 8 ltt ogo ate mah ce a nd bp ets w US. BFIGHARK: Objosticn. Asad and n annered vem em ws 0 nein HL Shi Hh 0 vere "igi ws UR LEOROLD: Objection. daked at © wu Tem 2 Pee] VIC BITES: 1 Forget. re queszion, non 2 » Tem Ew 2 ew me put is. mguin 3 “Boers ait och FI GE RIL HEIDI AT TT FERRO REED SU NAL liana: LUBE FUGIIS Our AT & Beefy pate inp So WE IX I THR (RCE n my BEE RansER BACLT. S000 LED CREE Rio 7 ME. LEOFOLU: Objection Lack of ) Faun 31 i 5 HEHEHE § CEA BE BE ® pur nore Tem ” BD Eada ERI 0 68 on 3B I Sea 9 HIE PA Vedic RE EDN CIO ha SE SREY hose sh @ mouse & © ME ren SATIRE Se Ww BEIGE x were on Pe — we ens Fo SEAS = ww 2 ASE TENTION Soka { 25 od M ' nove 2 Qi one sheer Shs a & we . Aves 5 Ti EI SERA SI FARO » #5 we a U. hu Noll ingtan the onl Inge that you tid 9 eft 5 assistant thal you mere actenaing? 0 A det rember ering That conversat (an UW aith her, 0 | atdn'T Kn iF at's abet | said w Q That as a lie. Shou, ment ie? wu H. LEOROLU: _Objaction to She form of the } Page 4 onz104. TAT “ weszion. ack of Foundation. You're waking sn sssunpion. She juss answored you she can’t tell i Yau that. ” WEE: Speaking objection. dnd vau 1 well know saat. Wr Loogold 19 MWe. LEGROLD: She can © ansnor that mn question. The aay you phrased that Qunstion. 2 You're purposely waking her nut be honest 1 her = testimony. She can't snswor a question [ike Lal ” Sha toesn'L remember. Sc then yu say. “So you u wera 1ying "TAT 5 wrproper and yeu know thet. = Thats net a proper quastien. Aud uny allurnsy = 1 That would do That £0 4 WITNGSSS br La 8 Darvon ¢ " TALS Sitting in this chair is non acting \ 3 professionally. You can't ask u queszion ike 5 wi. Youzan co it. BUF ITS not proper. Md s 1m Ure you wsren’L Lrainsd that way, cortainiy 5 nor. arhical ly. 7 Ww TEM: WE you stp? u SR. LEOPOLD. I'm not going ta stop, 9 beans The wey You're asking thax question is 10 improper nc you knas it n Ww. TEIN: You're lasing your cool yu TER wu o IE u UR LLOPOLD: Trust ma, |'m very cain 15 hen | lose my cool. yeu 1 know it. we TEI: 1 do knw it Term Em: 2 “age 3 i i ™ CO TE ARIR IN GH OF Gok Tia AGE J) OnE Ire ® Gh ARTE ENG EE A DIRE ZN WYRE HA DR ETS I Gs = Ar a FEEL ST LH ANE J SAE 23 WS son paint TEAL RETNA Snes PRR me scar 2 MR. LECPOLD. Uhjoction. fowndatran “0 1 predicate 2 THE WITRESS: Corrsct, 4 BYR TEIN a DE SOREN BUR Sb ob po GG TOE BOT Per & [C0 ( Ld a BOGE ® dw SE BR TTT? 1) Qe Yeung ONE ITER am wo Waskaresineg mw ee a J 3 SERIE TL GAREY we ax wwe a GF WSEAS Roun aie Pit BUTS RE ECE as w= ows $i 65 ASHIRIRIGI ON Roh (RSE AB GEIR a a ow E 0 dns Sod SBE BEED 7 ho incorrect. 2 Gell you ald che pica, RCo tine 910 { i 0020104. TXT 25 ba touch me.” Tore you Iying To Tw police Lien? 2 A Mo Hel 1 wasn aumg Fully Truth, ss me 1 went tying « . Yeu ald the police rice wen vod spk Lo 2 dicho! lo Ragen tial "at mo Sim dic m0 touch mn." Didn't 5 yeu say thar to the pel ive? i A vest 5 And you're saying That TART vas mT Tu ly 5 truthful 1s That shal you're saying naw? 7 A tarracn. a Qa you're saying it you're aot 2utly 9 ermarul, TTS nor & 11s. Correct? 0 Aa SOUTER SADA STROBES I edna Ly ” BOE BUR CREA Tosokien my Sia i ME ar TEBE TE RET he Stier caring YY THR FRR Jd MA BRICITDEAY "a 0. Vou Lele the police. "AE no tines dif ho 16 touch me. You agree WIth tht. correct? 1 A. Ho. denmageoo with that, because ne did 7 tone me 0 Did you tell the police thas he did nor 19 Louch you, yes ar nat = A IUs 2 possibility, but | da wit svmmber. 2 BEEP Ad RESTA SE STR A CTH Warten pe www 2 © eS REY I Sree BY RPE Peer eRe Page 38 { «029104. TXT € P : PE 2 Re MewSyra. of EEKIGICIE RIT TF ERE a dy SerEagiiy . PE ———— 5 a oy ; Gr the mag oY Ep A ota ta BEING your thin siscer back so she could ke o some mmy. carrares w I —— 2 a camoct © sna you ave I very meh. dont you? PN a ve 1 Bf whom you ors, th vase you ware Joking { 16 wilh ihe olhe- girls, veren's yu? 1 a wert, son JE cut ue other gir in the 20 tala th poise THE you mere joking aftercare. fre you 21 saying that thoy aera 110g © the pol Ics about. Lrat? 2 A Mo. Buta ection ar questias Tron 20 joking Sho mes Kind GF 11ka In a huspy say. ike, ‘Oh. 2 wnat aid you dor Whe cid you or Like hese Kine of © : 0 Yeu Joka abet It. Gidn't your 5 PE } . oo is co yi id Uni { ~0829104 TXT = 5 ovary weskend vou d be rich, didat your 5 a ne tees soo JE tod ne. ' ev mans wn tow [EY 8 RRO Onjoction. Asked end ° arsered. 0 TE UITHESS. No WR TEN 2 Tr NEESER LPR © ese POURLICK LE #1 any snes spe IIR oo evar Ee 1s A Incorrect. | didn’t spend wy of the 15 woruy I 4 Yew wn Lo Marshals, dics you? 1 A 1 vent along, yor. BU 1 dlanT 1m Q rd ii SHEE L5H WEEN EIR SER MATRA Se 7+ A annoys %. 2 ML LEG Ohjoction 2 THE WITNESS: | guess you cauld say oat, 2 I. LOOLD: Objection. Luck of pred cate 2 and Foundation. Hischaractorizetion of varl 6 ES rustiwny. i CT CT " A SA — a 0. nd you warn with for the whole tine ot 5 Wshalls. correct? 3 Aves ; G. ow Tell mo dbual shan the federal 2 prosscitars told you about golting reinbursed Page 31 ¢ 02101. THT { a A 1 rave no igea WAT you're talk abet. 0 0. Toll we about chen te faderal prosscitors 1 spoke to you about Gort iy mney you feel you re antitled 12 Ls from br. Epstein n Aoi dent know shat yeu rs Falking sod i MDa you keow aho Warie Vil lafona is 5 Ao Wo, sir. 6 Q Did you ever moss with any Tedural 17 presesutors? it] A 1 TANK -- yeah. {think they wero | 19 think hey were like 41 w Q. Un-tuh. Did you mect with “edoral 21 prosecutors? 22 A. They came To my a0use tio Lime, yas. 23 Q. When did they came ta your house? 2 A vary long ago. ( Ed Qos it this yoar, 20087 a 1 A ites not this yoor, mo. 2 a we IL 200m H A. 1'% have ta say aL lest to years aga er a 4 your ugo, yeah. So it would bo 2007, 2006; bul it sas © 5 win ago. 5 0. How many Federal prosecutors or FHI agents 7 core to your nose” a A. I'ntrying to rosemer. | aent Lo say four 9 people cons. 0 Q Did Ley give you their bisirnss cards? n A 17 thay did. | don't renesber, and thiy 32 recent toward mi Maybu wy parants have them. 1 con't 13 knox Fagy 38 i fi 0020104. TXT - Ei] Qed They ave you Tell cell phune umber? 15 A Me 15 0. Did you ever speak ta then on their coll 7 phones? i A sir 12 Dic thay speak To your grits? 20 A. “nas somelhing you'd have to ask ny 21 paronss. 22 0. Ba you knax wnotuar Hhioy spoke Lo your 23 porencs? os A Mo sic 2 van have aa iba? 1 A wo. sir . z WR. LEOFOLD: Objection fsked and A Bram TE 5 0. Sc il I aay the nave to you Marte B Villefona. you dor L Kner sho thal is? 7 A we sic [ 0. Hew nang women and he neny mon came ta ® your house? 10 A 1 want to say too ladies and Loo gugs. kt 0. Did souonn named JerTiay Slomn com to 12 yw house? 3 A 1 dunT know names. sir 1 2. Da you know elie Ja Trey Slomn is? ® A Nasir ig Qa you know via JorTrey Kerman 152 n A ves Fags 33 { I ~oazn ioe TXT { i GQ. hats Lhe tacyer una First sued pate n on 19 your benalf, right? ES A ves. 2 Qs Mr. Herman advanced your asi ly ary 22 money? 2 Mi LIOKD: ny conversslions Lhat you've 2 had with Mr. Herren egarding that issue, vou ure 25 not 10 disclose. IF you ve learned in same other a7 i Tashlon, you nay ansoer. 2 TE WITNESS: kay. 2 | weuldn’t know 4 Lm TEI: 5 a You don't knoa? s A Mo ( : MR. LEOPOLD. Objection. Foundation - e Atarrey/aliont privi legs. o BY NR TEIN: w 0 And you say you don © know oha dort Sloman nist 12 A Mo wir i Q Dows iL refresh your racel loation that no's 1 tha number TY ProSCCUTEr aT the U.S. Attorney's Stine? 15 A we Ww Q. That he s weria Villatona's boss? 7 Am Ws ©. Does It refresh your memary that he's the 19 ex-partnar of Jnff Horman, the [esl [anys aho sued 20 you -- sued k=. Epstein an your bekall for Fifty million 2 dollars? ” A. No. | don’t know aho Fo is. Page 21 i Fi -ouzsi0a. TXT : 23 i. WITOOUT Telling me any conversations that 21 you've had aich your tawyors, a is IL at you selected 25 We. Herren 35 your Lamyor fram Sh 51,000 members ur Che « 1 Florio Bar? 2 A did nan sats hin . owed a A wy mathe 5 A ome i DE dant tell me shat you dissed 3 with hin. ere dit you wot hin a A 1 wos Supping in ay -- he shoued up at ny p " QO Whose house? ( » a ny reiens [EEE Ed aos nse Eo I «IR IN A Yes © 0. fad did you have reeLing with him at 17 coe 10 © and wo wie was Were? 2 a wy ore EE 2 [SR ———— on WR. LEOPOLD: Cbjestian mas calls Tor » sttornayret tart. privilege a wm En 5 4 har discussion dd you have with Page 11 i “023104 TXT " 1 tr tormen in the presorce of [I 2 A wo 3 0. Wr discussions did you luvs in Ue s Be GOHDGSER: (Ls Une witness's aunt 3 wm Tem " a On, of your aunt 5 A Tho only ona That sve wer discussed or 0 ta n Qed 5 you aere in a conersation ith 12 dr. Herman and your aunt? nw A ves, si ns Q. And you discussed privi aged artes during 15 that comersariont ( w AR. L700 Object th to form. | think - a You nigh live Lo educate Fer an thar asrion. © BYR TEI ° 0. You discussed tho aeeit 20 PR 2 0 oi EE v1 vou about any 22 conversations Un. she had with tr. Varma? » AA Fares I'm concarmed, she's oer Spin 20 or she's mowr had u ComursaLion. She only opened the 25 door and then IatE. She's tho unc oho unswered the door wo ' Oy uid te mein take piace a [EE 2 IE osc? 3 AL spat oh ght Us nigh ot her house. 4 0. dnd when on, this? Page 42 Ie vurrea FI Lo s A Awhile ag. fi G4. ew tong age? 7 A. Aronth ard a halt ago. 1m guessing 8 a. A month ard a half sgn? ° A Un-hun 1° Gi SETIRIRTONY SIT ME teonae. filed TM hee H IE CEERTAR SRST ORGENIE Glink: 2 EAE 3 Q Bld you mot chat an FBI agan= named Nashir. 1 Kirkendall, a wan? 15 A 1 dunt kaon. A fo Dis Kirkendall soeak La you sbout 17 geting reimbursed fron Mr. Ipsta a7 Wn A. Fv rever had a dissussion with anyon about getting ro wbursed trom Nr. Egstuin. / 20 0. Have you mer with an agort named Jus % 2H charde? 2 Kum to my KoKlodge. 23 Q. Hox about an agent nawed 11m Slater? 2 A Mo, sir 2 Q. liow about an agent nswed Junior Ortiz? 5 1 A we z Q. And we've loarnad ToL many of Uh girs 2 som of whom are zs old 3s 23, weer told by the 4 GOVernent that Lbey would Get mney at the ond of the 5 criminal prosecution. Doss that scund Familiar te you? 5 Ama sir d 0. other than 0. Loagold here -- I'm not 2 uskiry sbout Ne. Wernan either —- Paye 43 i o A nn, ELT © a od anyone ever discuss with you tat 11 you could get reimbursament for your domeyes? wv A ts, sin 1s 0 Out yw or any menber -- " I IHSOLD: Are yo referring © 8 1s criminal mattar or a civil astter? Bow Tn: ww 4. bid you or ony meets 1° WR LEWOLD: Dncuso 09. Let me object ta Ww th form af the question. 2 aw nm a 0d you or any mswor of your Family ever 2 gots viclim motif cation letcar fram enyonc? 2 A 1 no longer live at what residence and | 24 soulent know, { ES RSs your testimeny is that you havo navor 5 1 receives a vicLim oli Fiction letter, corrost? 2 Rp — 3 Qo your easimony 15 ERAT you dor'L kc 4 IT your paras have ever received A victim notITicetion «© tantar. correct? . A correct 7 Q Have you given any cvidence to prosecutors Bor lan cforcumnt. in this cass? 5 A Shat do you oman by svidenca’ 10 Q Nall Anything thst you can touch ar fal? n P— 12 WR. LEOPOID: chjoctiar Lo the form of the nw auestion Page as I -0029104. TXT A MoE mw Tn 15 U. Sa you haven't. given anyEhing physical -- 1 At Wu 0. = any item to any prosezurar, police 6 afficer ar law anforcenont agent. correct? i A Wy cerl phen “pir yoars agu ur threw years 20 age. bul that's ‘t 7 0. You yas your cell pore ta wham 22 A uiewl le pagan E 2 a. Did sho keep ity 2 A Ask har 25 a. vow gava it 30 lor and hen you din’t get 5 1 iL back at the and of tho meRTIngY z A Wo. They. yesh. ha. They have IT. I'm 1 Q. tlw much money arg you heping Lu gat cut of 5 ur. Epstein? 3 SR. LEOPOLD: Objection to ~he “orm of the ? questian actarmay/client provi lsgs 0 aR. TEIN fl Q low much money are you hoping to ger. you. 10 yourself, haping to got cat of Epslein? n WR LEOROL: Same. Sams ulywlion. 2 allorey/ctient privilege El Don’t ansuwr the question WR mL IN 15 0.10 nat asking asout what your lasyer tald 5 you ” WR LEGROLD: 1% Instructing hor not to Pagy 15 { p onzoign rir ® oa vr " TEL Semi thet n 2 LEOROD, Plows. = JE— Ju" % So Sot, on Vd ek oof 2 demesition, didn yout wl : I pg—— 3 TO Te Yo ST 0 ten Sa BE s WS, Lior: ot te the fore of oho . inn, Sah ot Sao Freee ( : TIE RITHESS: Ho. ro pra some ® El] hera and ralking to yuu. TE 0 Ant tr te geening sores whe» Vout I —— 7 “ Ri Po AES POE ———— 1 wr PUD: Dbjosts to the “orm of the " aston ® ink 4 to Bors of som nmin, " of “oun ion » We TEI 19 0 AR A ” Bon - [—— el { 0029104. TXT N 23 WROTCIK: Sereify it = 1 & weenie. OFRTICIED BIESTION. ERR . I toes montt ; " o cay. vou gar your frien JE co C1 L 12 by SWItehing name Logs wilh you, carrect? 2 I. LESTOLD: Now of them be ben sak orion Ter " i has nen markof Tor IdenCHTicetion yut. wr rem s o EE a We TEI om oot. seking bp you , IR. LEOFOLD: Chay. Then can't speok to no . thon. it 1°11 speck to Wr. Goluberger. perhaps 12 UR. GOLDBFIK: 0 WH Wo sar Lut the is WR. LEpoln: hk yon ( www rom R ” a EE ve pt a pretogroph marked 13-001 » 0 vo is that in te phate? 2 . I 2 o EEE soo trios othe wu ) PE % a Eyer fried. who you soy the day tome i ; 829101 Ti * § cainticenca. Aas tearing you- 0m tag? 5 A Yes sir 7 0 Aud just by coincidence, you ero aarirg hor name tag, correct? “ A Yes wo 0. Your tastiony undo cath is That's ust No comcidunce, ight? J A lotal honosty. 1 QE just Banpans tn he the eay TRAT You kors 12 going to be served uth 3 subpoena, torrent? as A THE wasnt the Fs day hel -- ® we. ewer: J sc ssw <he ” question. It alts for 2 yes ar no i UC HESS: vas. EY TEM: " 2 LE £ ER a EE 22 Wihseeaask EEE 23 A Lun sev. 2 0 YEE EER BARRE 25 ary on sien [IIR cours che paresis ORGS BEE 1 tacking for you, didn't your 2 A Mo 1 kaen 2 WR. LEGROLD: Just amswer it. St calls fer ’ a yor or ro. 5 IH RIES: Okay. Ro. 5 ev TEM 7 Wow you can explain the anspor That your 8 counsel stopped yeu from explaining. Page 48 { -0020708. TAT H i A Oy verk or EEE a0 poopie 0 wore tol ing ne Sul people ere ioking For mo So yos. 111 ves sare that people ser searcaing for me. bu | Fac 12 no idea who they mere ar WaT Tie © nteditions vere. ut 131 Uugat they rere just people | dit wat Lo Lalk Le 18S 1 JUSt di wnt Lu Lak Zo ther. And ovory Tim 15 they'd com ta rk aL Uiere. And 50 hoppans the 15 night that they came in mo and my TF lend sxitehed ram 17 tags. Ko big deal 1. 0 Tess He, dss ie kd WLIPDLD: ODjeeTion. Dun't ansuer Lhat Ed Question. That's herassvort and | will Ret al tun 2 I. Ko could sn Lhe questions and we'll al on a ES fury to make that dete minalivar. but not counsel 23 Iwill ror of low her to snswer that 2s question, { 25 WR TEIN Gorzity st LY 0 ; MR. LEOPOLD: 1°11 eartily iL. > Ceeerei CERTIFIED QUESTION... oo, ooo. ® She's ansanren that question. She's explained it five 4 vimes already. Ihe fact not Conse! dossn' dike the 5 arsasr, that's a di Freront query © MR. TEIN: Siop making speaking objections 7 We. LCOPOLD: 1° nol. 1'm not going ta 2 PUE Up with IT. brcause ILS in upprepricle. _ack. ° and you know it. | will not al lox Counsel Lu. 0 Borale a Aitness. ahether t's in c-iriral Case n ar a wiv: | vase, wheher my client or 12 TEI: Caln doan 13 WR LLOPOLD: Excuse me Sage 50 Ie ~e9n108. XT : i No. I'm not gaing tn aliny it. That 15 nat 5 proper. Ws AR. GOLOBERGER: Okay. u @RLOMOLD: IT hie wants To say That she's ® tying after asking (t Tive Tinos and hor Ws explaming in grec detail, he con do that fut EY I'm hot goirg tu elon hur Lo amar, nor be El harassed ay him, It's {proper ” WR. COLOBERGER: Okay. Fut your respansc El That Counsol dosnt like the question -- or 2 dosn't like the answer —- Just 100 ws Finish, 25 HR. LEGPOLD. absolutely. | wasn’t gaing 50 1 to inter rept you 2 IR. GOLCBERGER: Jast recuires us to say ve 4 You and | or you and Ur. Tein eho are testitying 5 here. It's the vitness. 5 MI IEOKOLD: Line. But after the sien 7 tims of asking the same questicn and thon epaing 1 hack and painting @ “inger at her 2nd saving. ° you're a liar — © WR. TEM: That didn't happen ] WR. LEOPOLD: That's fins. But I'm rt 2 going To allo hur to arses Liat gusstion because *% she's ansaored The sam LOSTION and has iT] explained it. 15 Nok Ccunsel might ka sitring Thors rubning 1" his head with a migraine. “rat's his probion Ww BUT IF ho can’L ask a question appropriate y in a Page 31 { " professional srr, e011 leave, ail rat : n Siior hur Lo be berated [ko that. 2 1%. COLOBERGER. Actual y. war very happy 2 with tha answer 2% We LED hats ret pt We. GOLDBERGER: lla you want us tu got. into 2 hac? 2 wm Todo & + We LEORILD: THIS i realy big Tuff ther 2 you're going throcgh, aut That's Tins ust ask s Your question ard move on. rm dn iT oie Tims 4 IF yo sont wndor stand 1E. 1°11 tet you fal lov s Up, Bat I'm nat qeing to ator you Lo ask the sare 5 estion Lh kine and again and thon call hor Is 7 liar. ust ask tho questivn. get the answer and % » move Lu the nest subject matter ML TER: Ted, 1m sitning right acres 10 the table rom you, n WR. LEOPOLD. Ves. ir. 22 WROTEIR. Please be quis. ton't yoil. a WR AEOPOLD: 1 will not be quiet. " We. TEI: Sap voli ing a» UR. LEOFOLD: Levin, wher I'm yolling i our 1 know it. 1 wil not = ” RTL: Hy rane 13 tol Lexis © WE LEOPOLD: 1 theught your irs mace wes 1s Lows, Wr, Tein. m IR. TEIN. You watched me for thao days a 7 the cridentiary fearing abars you sat 1 the back 2 of Tha courtrou. Yeu steule know iho | an, Puge 32 \ 5, ES 3R. LEOPOLD: Well, Lhat s che inpression w ” I LSOPOD: 1 i11 ke ch recs wat = [| ng Lhat aes going on ( po " s A Eating rachon 4 2. At the |B . A touing . 0 You Just got hua Lo Fie for you, din's a 6 © he cok ear upon sel? " Vt 14 true chat Nr. Fpstain's prose % Al WR. LEOPOLD: Objection. Lack of 1 era Tem a We LIOROLD: 17 you Koen, Dent guess. = THE WSs: th. Gon you reper the [RT = TET — w : TEN: Thess a coaching . whe atom ‘ We Wo You dont do Unt Kono { { Eee TXT ; s THE WITHESS: Can you repeat The question? 6 WR LEOPOLD: Le me ust sate for the 7 record BEY TEN ® Q. Once the police — isn't it. trua that ur. Fpatoin’s procoss serves had Le sk Lhe police to get 11 you aut of the restaurant sa that thoy could su wy you? 2 A ftacarrect. 3 boss cal led the palice IH © md once Lhe pol ics shored Up, =a SEOf you Fron tying =o aveid service, won wd up another |ie thet 15 the process servers hd harassed you, tn’ That correct? Ed A incorrect Ed 0 You lie all the time, can't you? i WR. LEOFOLD: Oblaction. 20 THE WITNESS: Incarrac. 2 dl. Yeu hav a Myspace page. don't you? 2 A. Me larger do | have 3 WySpce page. | 73 dolores iL. 25 a when rd you elute your MySpace nage? 65 1 A a ceupta days ogo. 2 0. ¥no totd you to taka your MySpace page dom 3 a couple of days age? 4 A. Nobody. |'m sick snd tired of Myspace. 5 Q vou ail of 4 sudden cot sick and irae of 5 MySpace and just 3 Tow days before Tals cepusiticn you 7 desided tn elas your WSPACE PAGE. Correct? B A carrent ; Pag 56 { [4 pL 0029104 TXT " 4 5 PRT aL —— © Aes " Q. lie yo take your WySpeca page dom bucnuse 12 ‘You Ussigt. the gaveramen; mig subgame 102 PU Qa you Space poge been ip for over 16! (HSS Retort you Soc 18 Hons ww JS ——— 1 WySpaces ovr the fast years. | just. qo Lind of Thom 16 und dalotn thom hocauee drm nd ke nen ues » @ We're going ta far aout thor. ” S¢ you caloLe your Space page ATCar you 21 von alvandy unter bpuons Tor. Unis deposition. correct? FE] a. Thal abrul Lhe MySpace page dint you want 2 us vo soe. IIR ( 2 A Nothing. w 2 ina ent, B A You do that ‘ [RT ——— Sahu uty you is about your age so often. okay? . I LEOPOLD: Objection Lo the fora. h Arunentntivo 0 um Tem s Bow oe soot your gel tive thems dont w yr PB [TT — “2 TE ws: (vores 15 ram. Tem: i Ie 0026101. TXT " dau lio Shar year dc Lo get body 15 piercings. dor't your 1" A Incerrect. 7 Q You eve body piercings. don T. you? w A ves 1 0. You nave Sour bady pioreIngs: Isnt ial rhe »n A Five. 22 0. har Than the piareoirgs on your ears -- 23 1x ot talking about shat —- En A On Un ro; just one. 2 © And uhare 15 the ans bedy piercing? 51 1 a smelly 2 a. When did you get that? ( s A Hor fy Ulritaay, wiv ry stepeocher ard my 1 father. 3 Q. And wien was that? 5 A Wher 1 ows 12 ? 0. okay So yon had that boy piercing shen © you met Epstein. correct? ® A. IL Wight have been, or maybe that - yeah, 10 either my 13th birthdsy or wy 1501 | lonestly dow'L 1 remsmber. 12 0. Mow you've Tied abaut your age to get into 1 2rs by Using drivers licenses that aren t yours 1 eorract? i A nearest. ig Q. Ae you SUGSTInG WAST 0TH THAT YoU ve AT never cons shot? } Page 57 ; ~ones104. x1 i © A Yor. | sour under sath 1 4. nd you've fod sbout your age co bay beer, 2 correct n A Ineorrsce 2 Q Yours swan ing under sath That you'va 2 weer lied to stares Shout your ug? 2 A Ue never lied To a Fron wel by ue of 2 anything . © You wy Le look much alder than you aro, 2 do your z A incorrect. a 0. youve lied shout your age on your 5 Myspace pages, don't your “ A Incarract ( Fr QA raght. Lez's losk at Exhibit 25 21 5 US. BELOHLAVER: 75 0017 © RTE: Yes, nos Tem: I 05 OB JS Be Ore TL ol REE SE “" Be ames 1s Let's ga to wing 23 0 MS. BELOMLAVEK: hat 5 33 0017 wr TEIN: Correct. erm. TEI Tw Qn this page you lied Lo everycna that. you 2 mere 16, in’ your 2 A incorrect. 2 UR. LEOPOLD: ust sneer tho qustion “age Bo i i ~oazsr0a, 1x1 . El THE WITIESS. Oh. incorroer 20 aw wo 6 © Wao you can explain your answer. 5 ' A 1 Kuow thet 1 Juve seen all of Shes: ane | 2 know tht this on is mine 3 an you go com? a NR. LEOPOLD. Just fer the rocard, you're H poiating to tha photo. 5 THE WITIESS: 1m part ng Lo sow TEN: 8 ® DDILG RE Sneha an 9 Jor reson aie 10 AE CORR. r nw 0 Tees yous, ign % ” A. Correct. That's wing Troma couple years ) 13 ago that | have nol been on base | don't use That. WM Flease keep going Goan. please. Au | think het 's it. 15 botusu Lhare's na she —- Just. that one is mine. is SOMBIE YSSEansatn i BE EES 17 message USN BAI YIORA wirsetd 10 Wi CRE. 1 0. nd wen you arate 1B 5 your age a1 your 20 uyspace page. that wes 4 lie, wealdn't it? A A Correct 2 © Did you fic about your WSpace pugs back 23 ton becuse you coLicn't post an WSpece UnIsss yeu mers 2 mr rs A Correct. There sas a rule many yours ago rage 55 ¢ 0529104 TXT L 0 1 that you had to be 18 Lu have a VySpace 2 © 52 you 110d sbout your age 50 you cul 3 post cn MySpace, right” 5 A Yes B © Lal's gu back Lo te t5p one on this page, 5 mo 7 HES EET TRIN DRI artis BMS Hage afi EERE DE FANE IRMA 4 tm nw I REIS CAR mime 1 tment wicisa ise sas IE mr IR + is os NAVEL DR: BR pe 13 BE QUES “e Q. Row las go back fa the one That yeu Bre 16 pointing ta hefare on tis page, ahare iL says your age ( 10 15 16 and you lied bout. your aga fa ust RySpace, okay? - PR 1% Allright Wy did you Cally put your 15 true ge un you SySpice prarilo Fru days bera'e yuu 0 HRRSSERS A oC IDET AE IDLMEEIE LI Grate 2 A ESAT TY dat 22 WR LEGPOID: IT you don’t understand, ask = Nil asi Ue question again P We TEI: Don couch 2 IHL BIIRLSS: dont know eich MySpace n . you're talking shout. 2 aw TE 3 Q The ypc pags Lal you're just po’nting ) 6 be sere isang an. ¢ “amzmios. 1x1 5 A ves. 6 TE AE SA ADR YUE DAE TS ‘ mo mers s hy did yas Finally post your true ags an 9 your ySpuce profile -- 10 Awe " a Four days before you sets scheduled to 12 Leslify before the Srand Jury? n A 1 honssely don't know uhich Myspace a because |ve wd | ka x buat! ion WySpaces and in that 15 year, | bad to, that are and anathor an aid Lil oo’ 46 Loon welled. So | do's know ohich ane you! “n revere ng wom ® EY 10 oun Sis oc BA 16 KC AT Thrice ¢ 20 eran par wor GRE ISIE TSE ST a A ta 2 9 You don’ U rember iat. 2 PRS 2 Q. Do you reuember Darastive scarey? Dad you 5 over Bad 4 DotesL ive Recarey? i A 1 don’t know the names, 3 Qo mony diferent detectives hive you met © with on this case from Pain Beach? 4 K. Prosbly e good six or seven. myba 5 0. Did ona of the detect ves tall you botora § You testified In Lh Crend Jury that yeu should take your J Myspace ego a put your true age? a PRS Page 31 i { s ©. DidwL Deinciivn Baceray na to voms Le 10 your hase So pick YI Up 0 gat you Te TostiTy In fret 1 of the Grand u-ye » A ossitly, main because | didn'L Save a 5 ride (me only 19 or 15 at the Tim: " a our wm div arive yor Ws Aw Q Suepmn didn aw your A Chink my dad. oh. my cad / ny dad rove 1 ze. 1 0 Your dad aro your 2 Aves wi 2 4.50 your testimeny is Detective Rcarsy did 22 not dive you, correct? Fe WR. LEOPOLD. Objection /asked snd 2 amssnron ( ES THE WITHFSS: Nom pretty sure my dad n ) Grove me because ho ans thare ul th me 2 wm mn 3 © Nid any detwctive tel! yeu co change yar 4 306 In your MySoaze page to put your true uge? 5 A wo sie 5 4 ow you alse Lied on your wspass pays 7 uboul. your income, dicn’t your s A ves “ Wh A TD SO Bs QAR OR Gor: AYE TTS or LE 12 Others li snl ie iN A ves Page 2 | 1" KF Fi yousal saz beck an, oll ASHER BANE 1S EH ETAT SOI Drum ind. boli dni ta SOE A) aw PY v auk Abi G A RUBBLE EN 2a 17 EFOSC ff pres " ' wwe ( #:: Tov Eoutatntrind tortor ay Sather . a Behe 3 THE i or Wi nt et 1 Coen tal wig ee Sp Pi ; ‘ -oazeno. TXT { 10 snest killed him.” n Dt you say thar? 2 AW To uy Kioutedys or recol tection. | 21 have never said anything 1ike et. ” Gr DEERME EDI ts 2 swe FER zu A Youn Fl Because te, fpstoin over cane to yeur ws 1 dad's house. corrcer? > A Correct 3 0 ad no on oho works fer Ne. Epstein mer 4 did something ta your dad's Tiros. 00d Ley? s AR. LEOPOLD: Objection Lack of } 5 Findaeion, predicate. ( , bone guns - a wow Ton o GIT nat true SL ir Epstein almost 0 Kil your Father. is it? n UR. LEOFOLD: Dajection. Asked and 2 anemorod. lack or Foun on, predicate. a arm TEM: in QO You can anmaer. » I ® 4. How you to1d tho pol ice that yuu didn't 17 now who was in the car with you and llaylcy on the day 10 you went to Easterns house. didn © you? ww PE 2 0 Awl Sat ws a lis, wan't it 2 A ies tho trum. 2 0 Yau told the sole ist wre as somone / Fa 58 *d ~cazsi0a. TAY 73 in tha car noXt Ta you and yeu svesiMical ly said you 20d dnt know her nos, Fant? x A correct 1 do not Kaw Ler news. i i You said. 1 Gen'T Kook her rad. bul she 2 was dark ike a Spanish girl." That wore yor nrds, 3 right a PR 5 WR IEE Objet ip, Asked wd 5 Je oar Ton s GC Who was in the par thar day with you wud o 0 A AGN 1 do Hot Kno. A " [—— | L 7 went or Ws Ao to. E don't Know o EE u Q. You lied to the police about sho wes sa ho 15 car with you ant [EE icin’ your 13 A Incorrect w Q der wn ask you soe questions about oho you “0 sey tue spoken Lo about this case All right i AG una ES) a vid you spon to your I sisuer EEE 2 A War tn derail but or courso sie keewsi 22 sre's Temily and yes » 0 ft he emit? » AT dont THK she has an e-sail 2 © mt 1s her phang umber? Fuge 85 ( ? -osagtod XT » ’ A Oh gh 1 don't kro oF tho Tp af ny 3 [SR — 5 bo the ives with wy wm 5 on oven . PRE ; a. vat sbour SEs bey trond Paul? Di © you speak to Niu about Epstein’s cane? . A Thecs my wns buy friend. dy siseer 10 dows’ have a boy Frio. Wy ms oOING'S rate is 11 Foul, 50 maybe you cel them confused ES Go you kaw us phot muster? 1 I 1 0 tere dees he live? PRI { 15 o. n the same Bouse oth her? LE: 7 A. Ves. They re married. ® © So nor bay rien: send? © A Ven. husband » 0. Have you spoken vo rere JEN ovo 2 at nappa in Ur, EpSSEIN'S Meuse? 2 A dos in desail. ban i none th basics a yes va a mat is hes emai? = PO —- » ) PR FE TR—— f IR R— f Q vm is his ph nosber? ‘ a I Pogo 0 / —— * 5 a Wat 5 Nis home address? s Adm ; a Where dees he liu? o J — 1 A ves n 0 You dant know aha his address 167 2 MK. LEOROLD. OBjection. Asked and as ansaid Sho Just sard she doesnt kao WF vont sone 48. LEOPOLD: Objection. asked and 2s pr— oem Tem FA ————-——— 1 At dent Know The exact dirs py » QO wae strest ia iw ont < n A IT an upartmen complex: its ro» 2 street = Q. hats the name af the apartment compli? » «I = a. sar aprrient ner 15 167 - : At ewlart tl) you 2 Q When ras the act tim you wal Unrer 3 A ut visited this pase sookend. | hares to © rest ans 10st time | went there. s [TR — Er ———— 7 A te. mo longo speak s 2 What's his phase mbar? Actually. we sage 57 f { 0029104. TXT { 9 airoady Fave his pune masher rho a -feil 0 now shou. [1c vou vor ES PO] | ws 0 ave you over ve: [EE 1 A Be Buc just to let you knoe, | don't 15 really kno names. 17 you hese pictures, of Shara faces 1 sould cell you 1 0. MII right. Let mace it 1 can reriesh 1 your menary. a ay » 6 toes it refresh your nesory ooo 2 1s the tne girl mo ans ul legatiors abou HpStOIN, but 72 refused Lo show ta the Grand Jury shen she hod to testify 2 abeur than under ose 2 A te sir 1 have no entadge of any cther ( 75 gris in shix shale situation Fors nul al loved te kno ow r— 2 BE er GG CEDAR Ponds x 3 a . a vs wna vo [eve ve aren noe 6 A ho, wr ’ 0 Let's seq iT 1 can raiesh your mamery on her. Shas Lue other porson reprosonted by your laver 9 We. ormen. wo 1s suing Epstein for Tivty million 10 collars " A 1 hw ro knoutadge of her 2 a Newer wt hort ws JE ———— bio 08 r 2 -0s2910. 1X : i a rey ER 1s A 1 don't knan sha Uhl is sicher 16 a i persen named anthony wie kee: JY 1s tran Tory EE ww A 1 dont kom, si 1 Ga you remeadir macing a scoement to 20 Datective Pagan tars in the police roparts? a A We 2 tave you usd Lhe pel ice reparts in this 2 case 2 Kove 2 4. They im or Uns Interns, right? o1 , A Yes, | think . 2 yon we WG ON FBO ERS 3 ® GORGE EERIE Ohta arn A a i BRACES 1 ERE BED 5 Be YER o 0. You didet went to ss thet happen. rignt? Hl P— ° 0. So you're saying you dowt know a “any - I w WR. LEOFOLD: Objection. Asked and " ansacron 12 am. TEM ” Dues it refresh your morcry That ho ws 16 sombody wna 1a gare Le jail for drugs and car Ther? 1s A ne wr 1s a somone eno kon 7 Po Page 61 Fi -CuzuIDg. dl ] ww 0 ou en's nan IF he rat mith Detsctive ) 19 Recarey? » A ho sir 2 a bow vont zook JE » A Yen. remember. | Aw who chat 33 us nid you ever spank to sack J] cbc hot 2 A He om mes ioppened four years ago. to o | dows’ know his 15 65111 golug on Loday. , OOhrs his address wn serry. | have his ‘ A dors won 5 [:} Hay avout Nick [I 3 «I { ¥ a. Yas kaow who that 15? E 8 A. 1 know ah that. is. yes . 6. Wars the we you stayed out drinking al 10 mig ce night “as your en you dau reported you JR — A wer w 0. denaabor to bacabul| gam you ners 1 apposed 19 go 7 i a te si i wo Did you speak to tick JE shout this Tae w A We sie 1 PR—— Tiel ay sister's exbay friend a 4 e's Who one with the saved o°T shotgun 22 with the obliraratos Sorel mer? Foie 18 i i 0920104. TT : uw A nekhin 1 wuts mr knoe Tia PIT —— 2s 0 2 yw spe to rack [Ebr this I 2 A Ho wie * I ——— [pen s PRS peer———— . EN — 7 hawk ry paras . Q Luts ses iT 1 can rafrash your memory as 4 town hos akayr 10 A unm 7 n © WEEE IT Smee soma \ ERG ARIST SSO Sr 13 Be KORE ETRE TEER eee 04 EO IA ea EOL ing ar Kidd ALT CATUEE [TE BASTIRMRIRNG 5 ch CST MES | DEL KE NE 15 Seurknstiobingsrhors shia shat SIANEAIKEL, ” BY Fok made Fac abo SE SIOTEL 08 RII ISHERTE Soli Bre bh Sa by oF EITECDEREE 19 ATE an w RE Amara Sno TE 15 801 2 0. Hom much money did John Connot ly give Ta 2 yor tenor = A 1 don't oven know he gave seey to a dad zn 0 msn = didn’ oven know ho gave mono To my dod Pago 71 { -ouzer08. 1x1 % 1 0. Wee do you know adnut the deal that Joli 2 Cannally tas wilh your Tather? 3 At ealy know Lhey spoke on tha Telephnae 4 ence. | don't knaw anything clue. s a. hey was that s A Ths use hile ago. a yoar or Tao or 5 7 year aro. | honestly don't know El 0. Did Jshe Comal ly Ta Vanity Fait reper ler & atfor any money Ww your Father? i Kot den't knew. n Q. Did Jahn Connally, the Vemly Fair WW ragortor, give you sny mney? 13 hos i 0. Did he affar you ay menoy? i A Mo sir Never spake to him ( 1 A. What reportors lve you spoken to? an Azer. 1 OWL bout your family mesbers? #hat 19 reporters have thay spekan tu? 0 A. The uhole Palm Bosch fanty, obviwusiy. as 21 you ean 560 In thal newspupar 2 Q. Imilae let's go trough each one thar. 23 you remember. Osher then the Vanity Fair reporter, John 74 Gonnclly. MT cther reporters have sny momber of your 25 ramily spoken to? ss 1 A lden't know. fort | eon my mom has spcken 7 ta zare ty sister spoke =o vera My fathor wl 3 stepaother, | wouldn't know. Yeu'd have ta ask ther. | 4 dor t contact Thon, " Fage 72 Ie 042104. L 5 A. Well, | just vant to know -- | don war. 6 you to | WANT To Knca IRS In your mind? ALL rights 7 WR (KOPDLD- Sho JUST Tod You. Sue JLst ° ansnersd -- © HR. TEIN. Be quiet. wav ER TON n Q. What | ent. to know is what You know Crum 12 your personal know adge. My opin-an question To you is: 13 har knowl alge to You hove about Family mesbers of yours 1 speaking wa reprrtars: Ws WR. LEOPOLD: Objection asked and 1% answered id And IT you can’t tall professionally, we're ws going Lo feevs wu WR, TEL D6 what you wal Lo co. EY BLEW: Aro you going to coin Ly ( a alk is wy? 2 WILE I'm nol going Lo answer any 2 question that you ask me, W. Leopold. 2a WR LEOPOLD. Okay PY WTC Dut you ars misrepresenting the a 1 vocard and you wr grarstancing for your cf int 2 and it's arang So bo quit. Aad you know fow to 3 make an ohjection. ska T, Otherwise slop Bl talking. 5 SUR TOI: 5 0 sage -- ? WK LLOILU: Excuse he. H WE TEIN IF you wnt to leave the Page 12 i _cozetoa. 1x0 4 1 deposition. leave. LUC youl by back vere 0 WR. LEGROID: xeuso we. 17 1 coal just n make he record, insesd of interrupting me, v plesse, Thal" uhal we do prefessionaily. There's ES & recorder hore 13 wrtairly not being EY] obstructionist. 1m going fo make the “word Cl BE wre going =o wct AIT some smblancs of i professional ism, hoperul ly, by all parties in tre 7 room. That gaos fo ne, That ges Ta your un Co-volmsel silting behind you and noxt to you, the Ww CAUCE FPETUr and wveryens else in the raom 20 Everyona gaes entitled to that. 2 Vou ve zsked a question, Sho answerer the on QuOST In Fully and she's not goirg to be Aarnssed 22 bacausa you dont like the anseor. 17 you want to 2 Tollon up -- ( Ea WR TCIK: Stop engacing me. lake your a1 1 spacch and then wo’ 14 wk Lhe questions. : HR LEOPULL: Well. you won't I6U ma Tirish 3 aking Une ujection, so it's Ait=icult to da a hat. BU IT you nant ta Folia with an 5 approariste question, Teel fre to do tat But 3 ws’ pct gaing a harass The witness. 7 WE. TEIN: | disagree with everything 8 you've said. Lez's uk Lhe cusstions. Okay? B WR. LEOPOLD: Ask an appropriate question. 10 WR. TEIN: Are you goiry to stop Lalking? n WR. LECPOID: 1m going to make -- protect 2 my client and make appropriate cbjaction, hut 3 here's met a wuestion pending right non. Fage 14 Fi 0020104. TXT Wem Tem a IEE co I occ to any reporters? in PA ” IR LLOPOLD: Objection. sked and © ersered ov TER 0 a ose given mavey by any 21 reporters? 2» Pa 2 Haw your mom spoken ta any roportare? 2 We 1FOPOLD: Objection. Asked and a ansnerad. en 1 THE WH THESS: Wo py 2 ww Tom 3 Q. 1ias your men's husband Paul spoken to ary + roportars? s A te “ Q. fins your moa’ husband Paul received any 7 wonoy from reporters? a a we a 0 are you sure you eon'e kno [I 10 WR. LEOFOLU: Objection. Asked wad n were. 2 HE WITHESS: 1’; aositive RY MRL TEN 1" 1°11 try again to refresh sour memory. 5 A okay " A. Does it rafresh your monory Thos sho had 17 been arrostad for drugs and was caoperating with ange 75 { 18 Dutectiue Bacarey againat LpSein Lo gal hersel a EeLtar 1 dear? 20 A Ma 1 don't knox she sha is a Qa you spoken Lo anyone else kn 5 boon 2 at Esstain's house? 2 a to » 0. Witt telling me vhst was said! don't 25 ae ta know shout any cowersoLions kith ery lasyers. © 1 ska 2 PR 2 4 ee id you or your parents spesk to any 4 oxo tan tires hosides Berman anc le, Lecsold's Lak 5 meme 5 PA 7 1 0 Mon witht tolling me sous anyehing thar x Bn said, ahat —- 2d one Just ooo To wine? s A No. Iwas thinking about samathing ise wo wat wore you Linking abou? n A Doss family cows wmtrar? 2 0 Oy. Without tolling ms ens vas said, v5 ahe propard you for todays uepusition? 1 A Sar da you mean propa? 1s 0. Did you alk abou. This deposition, about ADT woud happen. mith anybody? i A ws 18 QO Dent teil no what vas se 0? 1 A oa. x QI mot asking that 1 ons ent to keow a that 2 CE , - 0529104. T3T % 2 Qn prepared you for Loday = depositicn? 21 A wr ieapold 2 © daybocy elser 5 1 PR 2 0. hex dict you meot with Hr. Loapald to 3 preparc tor tudy's deposition? 4 A ths wraing 5 Q. And hou long did Thar wasting tase? . A Uni it started : Q. Hom you told ue Lia you previously had 8 read the police reports in tas ase? a A ves. wu ©. live you read your statenent chat yeu gave - TM to wy pelice? 3 © Air ohat Tor eas Ural stazement? 1 A har ca you mean? U. Ha iL in Lhe form of a police report ons 16 tramseript? RL Ao Wns the differences Wn QA transcript has questiors and answers on 18 iT. A pallies report 15 Just Lyped oul narrative 20 Ao Oh ITs a pative report. 21 Qed cher did you read the pol ivy reorl? 2 A. A Tew dys ago. | averread it a fu days 2 ag. Ph A Had You read aL sefors that? 2 A wa, Page 77 i Ia 0976104 137 ” 1 2. Mov you Toid me -- again. | don’L want ta 2 know nat was sad. H A hen El 9. You raid we Wal you met wich 4-. espold 5 this morning to prepare for you depasiLion, right? s A Yes H QO. Uhr 8d you seL up that meating with 8 Wr. Lespold ta take place This morring? El A Gee, like, like Five days ago, Tour dvs 0 an n 0 So you're sears thal Mr. Leopald tald us 17 that he could not start. the fepesition this wornitg 13 because he had 8 Court eppearancs, correct 2] GR ILOFOLL: Don’L answer that quastion, 1" Calls For atecrray/clisnt cow nicat ons. { 16 avin TEI L EH 9. Have you seon tho letter that k=. Leasold 18 arcs ta us siaticy tet he -- an ooall That J. Leoold 19 arote to We. Goldbarger Stalling Lic he couid not. bo ners 20 this morning secausc healed 3 court appeurznce? Gic you 21 son that emai? 2 WA. LEOPOLD: You can nasser that question 22 TWINS: Ro 24 um. TEIN: ES 0. Have you listenad to your tape-rocordad % 1 statement £3 the police? 2 A Yes 3 0. Where did you listen ta thi? ‘ All ink. this building.) dont con Fage 6 i Fd -0029108. TXT x 5 it was here. 5 Uo nen 0d you 11st to Wa sta.smenl? 7 A Taiz wrming 5 Aud abo was presear aban you |istencd to ther statement? © AW Leopold <= und | Forget Sour name " WR GUIDBERGLR: te. Dolohlavok. 12 THE BITHESS: Ms. Balen avrk ava Tom 1" GQ. And yo hadn't Histor To your sation 5 dors Una correc as A we, si ” Have you mer with layers rupreseuLing 1B anyonu alse suing Epstein? w LOT » Be SU SA i BTELA ( 2 ARE ED Pu erty 2 Wi EIS NIG RBCS UTE 20 amg a Cou HAE, SH HPA SE ins n 9 Ten was Une les Line you spoke vith 25 aFFizers af the Palu fcach Pol ics Dopar ners? a , A Aun ego. 10 sy a yeer ogo 2 a. Ayer ager 3 A ean. thaybe a year and a hat s 0. 00 you rember DelecLive Recarry? N A wa 5 4. 50 you ronebor Whetle Pagan, Detective 7 Pagar? 5 A Ves. Fane 70 4 -0026124 . TXT { o Q. low smn Times aU Jou Speken To Delactive n A Shaws the unly ons © spoke ta about. this 12 LIL for some reason she when’ L or Une cose anynors iH 0 tren as that? " A Tw First nesting | svar fad ws arth hor 5 and chen | nin like | wel wilh her bide Sm SE 16 XMS for somethinR dL IRI FIRED et inh. EE a we a and eno acs tha? ® 51 dont romonhar wn And wnat type of questions id hey ask 2 yor 2 A The sam a Q Tho same questions all ovor gain? 2 A nasically. ( 25 @. Haw many taped statemsnts have yod given ta a 1 the slicer 2 A One tia | non of. s QJ the one win Detective Pagan? 4 Aves. mir. . Q How about Zo the HIT DIA You give any 5 scene to thor 7 A Ma Wil, sctially, | dont reatly 5 “uxember if Et eas taped or Not to by hunest mith vou 91 0 one meeling with the at my boso and don L on if 0 it wns tapes n 4 van wore incerviensd or I 2 house? © A Me thee was uy Lie lawyer Tage 80 * 1a a. on, boy the louyer? .

Related Documents (6)

Court UnsealedNov 8, 2019

Alan Dershowitz Extended Rebuttal to Virginia Giuffre Allegations

Case 1:19-cv-03377-LAP Document 90 Filed 11/07/19 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA L. GIUFFRE, Plaintiff, Civil Action No. 19-cv-03377-LAP v. ALAN DERSHOWITZ, Defendant. ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTERCLAIMS Defendant Alan Dershowitz (“Dershowitz”) hereby answers the Complaint of Plaintiff Virginia Roberts Giuffre (“Giuffre”) and asserts Affirmative Defenses and Counterclaims as follows: ANSWER NATURE OF THE ACTION 1. This paragrap

274p
Court UnsealedNov 8, 2019

Epstein Exhibits

Case 18-2868, Document 278, 08/09/2019, 2628230, Page1 of 648 EXHIBIT A Case 18-2868, Document 278, 08/09/2019, 2628230, Page2 of 648 6114:2016 Prince Andrew and girl, 17, who sex o?er?er friend flew to Britain to meet him Daily Mail Ontine Daily ail .com Home I U.K. Sports Showbiz [Australia [Femail [Health [Science [Money [Video [Travel [Columnists tr am .22: ,t Latest wisestii?tr?e Prince Andrew and the 17-year-old girl his 1 sex offender friend flew to Britain to

648p
Court UnsealedNov 19, 2025

HOUSE OVERSIGHT 016698-mailing

November 12, 2025 release of Jeffrey Epstein documents by the House Committee on Oversight and Government Reform. Microsoft Excel Spreadsheets converted to PDF. Originals in NATIVES/001 folder

73p
Court UnsealedJan 4, 2024

Unsealed Jeffrey Epstein court papers

January 3, 2024 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Pursuant to the Court’s December 18, 2023, unsealing order, and following conferral with Defendant, Plaintiff files this set of documents ordered unsealed. The filing of these documents ordered unsealed will be done on a rolling basis until c

943p
Court UnsealedFeb 3, 2024

Epstein Drop One

January 3, 2024 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Pursuant to the Court’s December 18, 2023, unsealing order, and following conferral with Defendant, Plaintiff files this set of documents ordered unsealed. The filing of these documents ordered unsealed will be done on a rolling basis until c

943p
Court UnsealedAug 9, 2019

Epstein Docs

Case 18-2868, Document 271, 08/09/2019, 2628203, Page1 of 1 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT _____________________________________________ At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 9th day of August, two thousand nineteen. ________________________________________ Julie Brown, Miami Herald Media Company, Intervenors - Appellants. v.

2024p

Forum Discussions

This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.

Annotations powered by Hypothesis. Select any text on this page to annotate or highlight it.